Investor Presentaiton slide image

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.
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