Investor Presentaiton
18
Board of Executive Officers
Michael Amalfitano, José Antonio de Almeida Filippo, John Stephen Slattery, Paulo Cesar de Souza e Silva,
Jackson Medeiros de Faria Schneider, Fabiana Klajner Leschziner, Mauro Kern Junior, Mauricio Rodrigues
Aveiro, Johann Christian Jean Charles Bordais and Nelson Krahenbuhl Salgado (absent)
Compliance |G4-DMA: Fighting corruption, G4-
S03, G4-S04|
The Compliance Program aims to ensure
the adoption of the highest standards of
integrity and international good practices
as well as the adherence to the laws of
the countries in which Embraer is present,
above all those that govern anti-corruption
practices and export control. The initiative
is coordinated by the department of Compli-
ance and supervised by the Board of Direc-
tors, the Audit and Risk Committee, and by
the President and CEO.
em-
During the fiscal year, the program inten-
sified its relationship with the group of
more than 200 compliance agents
ployees from various departments, in Bra-
zil and abroad - who act as multipliers of
the culture of ethics and compliance in the
company. Workshops were also held to en-
sure full comprehension of the company's
policies and how to execute them during
daily tasks. The training plan includes lec-
tures on ethics and integrity administered
by Marjorie Doyle, member of the Society of
Corporate Compliance and Ethics (SCCE).
Lectures were attended by more than 500
employees from several departments and
by members of the Board of Directors.
Among the advances in the Compliance
Program, we highlight the development of
the Know Your Customer procedure, which
requires a reputational analysis of potential
clients based on risk factors, and the adop-
tion of a continuous audit system that per-
forms monitoring of critical operations, such
as supplier payments, travel expenses, do-
nations and sponsorships. The intention is
to expand the system, which already serves
the Internal Audit area, to other processes
in the coming years.
In 2010, when potential nonconformities
in certain overseas business transactions
were questioned by U.S. authorities, the
company hired external lawyers to conduct
independent investigations, proactively ex-
panding the initial scope and sharing the
findings with the competent authorities.
These investigations found that the com-
pany was responsible for irregular actions
in four transactions involving 16 aircraft
between 2007 and 2011 in Saudi Arabia,
India, Mozambique and the Dominican Re-
public. On October 24, 2016, Embraer an-
nounced the terms for closing this case,
which had been investigated by U.S. author-
ities - the United States Department of Jus-
tice (DOJ) and the Securities and Exchange
Commission (SEC) - and by Brazilian au-
thorities Federal Public Prosecutor (MPF)
and the Securities and Exchange Commis-
sion (CVM). As part of the agreements, the
company agreed to contract external and
independent monitoring for three years to
monitor compliance with the terms and will
make a payment of US$205.5 million to
U.S. and Brazilian authorities. Upon timely
fulfilment of the agreements, no charges will
be brought against Embraer (see more infor-
mation in the GRI Indicators).
―
ETHICS AND
INTEGRITY
|G4-DMA: Non-discrimination, G4-DMA: Fighting
corruption, G4-56, G4-S03|
The Anti-Corruption Policy and
the Code of Ethics and Conduct
ensure the company's integrity in all
operations. The former establishes
guidelines to prevent conflicts of
interest, deal with donations and
sponsorships, the offering and receiv-
ing of gifts, and outsourcing. It also
establishes mechanisms for investi-
gations to be carried out prior to the
formation of company partnerships.
The Code of Ethics and Conduct
shares norms for responsible busi-
ness management in all operations.
The document is guided by internal
business values and by the Global
Compact of the United Nations, in
addition to complying with anti-cor-
ruption laws, international trade,
and initiatives such as the Interna-
tional Forum on Business Ethical
Conduct (IFBEC) and the Partnering
Against Corruption Initiative of the
World Economic Forum (PACI-WEF).
In 2016, the Board of Directors
approved a revision regarding the
prohibition of contributions to politi-
cal parties. The Code is available at
http://compliance.embraer.com.br/
en/SitePages/Home.aspx and all
board members, members of the
Board of Executive Officers, employ-
ees and third-party collaborators are
trained in the document's guidelines.View entire presentation