Sustainability Report 2021 Vivara
Ethics and conduct
102-16 | 103-2|103-3 | 205-1 | 205-2 | 412-1
Our honesty and integrity background
allows us to have excellence in ethical
conduct. In 2021, we revised the Code of
Conduct, strengthening Human Rights pil-
lars and simplifying the code by drafting
internal policies regarding anti-corruption,
souvenirs, gifts and hospitality, and dona-
tions and sponsorships. The document
was approved by the Board of Directors in
February 2022, with immediate communi-
cation to the market.
In 2021, we strengthened our Money
Laundering Prevention Program, in ac-
cordance with Resolution no. 36 of the Fi-
nancial Activities Control Council (COAF),
published in June. With agile adjustment
of procedures, policies, and tools, we hired
a tool to automate and help manage this
program, whose changes were absorbed
into the company's internal policies.
The business corruption risks are limit-
ed to dealing with public agencies in the
case of inspections. In order to mitigate
any risk, inspections are centralized in the
corporate area. In 2021, we enhanced the
depth of reputational analysis by includ-
ing restrictive lists in the negative media
analysis, in a process formalized in Feb-
ruary 2022.
At the same time, we sought to strength-
en the culture of ethics and integrity with
our annual training schedule for our em-
ployees, ranging from expected behav-
iors according to our Code of Conduct to
procedures in compliance with current
legislation, such as the money launder-
ing prevention regulation and the General
Data Protection Law (LGPD).
In 2021, we provided all employees (corpo-
rate, stores and factory, including executive
officers) with two digital training sessions
on preventing money laundering and fight-
ing terrorism financing, lasting approxi-
mately 30 minutes each, to consolidate
the internal procedures adopted by Vivara.
This topic is also part of the mandatory
compliance training track, which includes
modules on the Code of Conduct, with
the goal of reinforcing the aspects of the
document. In 2021, 85% of our employees
participated in the activity. Also, in the year,
98% of the active employees were certified
in Vivara's Ethics course, which addresses
Human Rights, among other topics. There
were 1,585 certifications, totaling 2,847
hours of training in the Code of Conduct
course. 412-2
87% to 91% of our staff
adhered to the training
against money laundering and
terrorism financing
Open Channel
Our Open Channel enables safe communication, to be made anonymously
if desired, of any conduct considered to be anti-ethical or that breaches the
ethical principles and standards of conduct or the current legislation. In
2021, the policy and procedure related to this process were reviewed. The
channel can be contacted by phone at 0800 377 8024 or through the web-
site Canal Aberto Vivara (canalconfidencial.com.br). We handle all com-
plaints with impartiality and secrecy, with prior assessment by a third-party
company. Moreover, all the complaints have a corrective and/or preventive
action plan, which are monitored by the Compliance area until they are fully
handled. The Open Channel indicators are reported to the People, Culture
and Governance Committee for information and follow-up, besides being
the last resort in any deliberation of greater criticality. With the purpose of
stimulating its use, in 2021 we increased communication actions about
the topic. 102-17|102-33 | 102-34
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SUSTAINABILITY REPORT 2021 VIVARA
SUSTAINABILITY REPORT 2021 VIVARA
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