Governance

Compliance

COMPLIANCE POLICY

To guide the behavior and actions of all Odebrecht team members, a Compliance Policy was approved at the end of 2016. It is a solid and comprehensive document with detailed rules on how team members should behave in their relations with each other and with Shareholders, Clients, Suppliers, Competitors, Governments, Communities and society in general.

It is a more modern proposition that responds to society’s most current issues, with guidelines on anticorruption practices, money-laundering, conflicts of interest, relationship with suppliers and shareholders, among others. These are clear and objective rules that leave no room for doubt while the employee takes a decision.

>> Access the Policy on Compliance with Ethics, Integrity and Transparency of Odebrecht S.A.

COMPLIANCE SYSTEM

The Compliance Policy of Odebrecht S.A. established the Compliance System structure, which is divided into three pillars: i) prevention, ii) detection and iii) remediation. These are covered by ten different elements, and most of them relate to prevention because prevention is always better and less expensive than cure.

However, no matter how good prevention is, it may not be enough to eliminate risks. That’s why there are measures in place for detection and cure. Once an exposure to risk is detected, it must be quickly addressed in accordance with its nature and severity. The 10 elements of the system are detailed below.

ODEBRECHT COMMITMENT

Odebrecht Commitment introduces the 10 principles undertaken by the Group to fight and not tolerate corruption in any of its forms when conducting its Business. It is aligned with the Odebrecht Entrepreneurial Technology and must be practiced in a responsible manner in all areas of work, without any exceptions.

Following are the 10 points of the Odebrecht Commitment::

  • Fight and show zero tolerance for corruption in all its forms, including extortion and bribery.

  • Say no firmly and determinedly to business opportunities that conflict with this commitment.

  • Adopt principles firmly grounded on ethics, integrity and transparency in relations with public and private agents.

  • Never rely on cultural or customary market conditions as a justification for illicit actions.

  • Ensure transparency in information about Odebrecht, which should be accurate, comprehensive and accessible and published on a regular basis.

  • Be aware that misconduct, whether by action or omission or disregard is harmful to society, breaks laws and destroys the image and reputation of the Odebrecht Group as a whole.

  • Ensure that Odebrecht practices the Compliance System throughout the Businesses’ value chain, always up to date with the best benchmarks.

  • Individually and collectively contribute to necessary changes in the markets and settings where misconduct may be induced.

  • Incorporate into Members’ Action Programs evaluations on performance concerning the Compliance System practice.

  • Have the conviction that this commitment will keep us on the path of Survival, Growth and Perpetuity.

ETHICS LINE

The Ethics Line Channel is an exclusive and confidential tool for safe and, if desired, anonymous communication of any violation of the Odebrecht Commitment and/or any policy, guideline, charter and law.

The information is received by an independent specialist firm, which assures whistleblowers absolute secrecy and no reprisals.

>> Learn how to send your complaint in the Ethics Line