Today, the Odebrecht Group is launching its new Ethics Line, a channel dedicated to receiving reports of conduct that is unethical or violates internal policies, rules or the law. All reports are now handled by an independent third party to guarantee security and confidentiality and prevent fear from retaliation. The change is consistent with the commitment undertaken by the Group to always act with ethics, integrity and transparency.
In addition to voicemail and text message, the new Ethics Line now allows users to speak directly with a service agent by telephone. A team of analysts trained in interviewing techniques is available to receive information and interact with whistleblowers. The new channel also allows whistleblowers to accompany anonymously progress on their reports using the case number generated. This functionality also allows Odebrecht to communicate anonymously with the whistleblower to request additional information or clarifications.
The improvements to the Ethics Line are being made at the holding company as well as at all Odebrecht Businesses. The Group first implemented the channel in 2014, when reports were made via technology managed by the Odebrecht IT team. With the changes, reports are now received by an outsourced firm via a dedicated system. ICTS is the firm that will manage the receipt of reports, which was selected after a competitive bid process.
Odebrecht S.A. and each Business have their own websites and telephone numbers (toll-free, 0800) for making reports, which can be found at www.odebrecht.com/ethicsline. The system functions 24 hours a day, seven days a week. The websites and toll-free telephone service of the new Ethics Line are available in Portuguese, English and Spanish.
“Strengthening the Compliance System is a commitment undertaken by Odebrecht that is being fulfilled over time. The improvements we’ve just made to the Ethics Line represent the realization of this process and an important tool for detecting any violations of our commitment, either by a Team Member or external agent," said Olga Pontes, Chief Compliance Officer at Odebrecht S.A.
The receipt of reports and initial assessment of the risks associated with the report are the responsibility of the team at our partner ICTS, which also issues a report with recommendations for conducting an investigation into the matter reported. This work is conducted by professionals with degrees and training in risk management, information security, preventive intelligence and analysis of oral and written content, based on the Scientific Content Analysis (SCAN) methodology. The entire data-transmission environment of ICTS, which manages the receipt of reports, adopts rigorous security and cryptographic communication standards.
All reports received are investigated. The Compliance teams of the holding company and the Businesses have specialized professionals to conduct the investigations and, when necessary, budgets to hire expert firms for such purpose. "Whistleblowing channels are also strategic management tools. The receipt and analysis of reports are part of a process that strengthens the Group’s culture of ethics and leverages opportunities for identifying improvements in the control environment," said Olga Pontes.
Studies show that the biggest contributors to a whistleblowing channel are the actual employees, who are the main party interested in strengthening the culture of ethics in their workplace and in resolving problems and irregularities. An analysis conducted by ICTS of the 140,000 reports it received from May 2009 to May 2016 for 141 clients indicates that 92% of reports are made by employees, 71.9% of which preferred to remain anonymous.
Approved in 2016, Odebrecht’s Compliance Policy establishes disciplinary measures applicable in cases of unethical conduct and violations of laws and regulations, based on the severity of the case and the degree of liability of the persons involved. Measures include verbal warnings to termination with cause.