Investor Presentaiton
OUR OPERATION
Code of Conduct
GRI 102-25
Our Code of Conduct informs
employees on expected behavior in
the relationship with colleagues and
other stakeholders (clients, suppliers,
government operatives, community
and the press). The Code covers several
topics, including laws, standards and
regulations, professional conduct,
transparency in relationships and mutual
responsibility. All employees must be
informed and accept the Company's
Code of Conduct by signing a statement
electronically. If applicable, they must
also inform the company about any
situation that might be considered a
possible conflict of interest.
Periodic reviews have enabled us to
keep our Code of Conduct up to date
regarding changes in social behaviors,
laws and regulations, such as the
Brazilian General Data Protection Act
(LGPD, in Portuguese).
Complying with the legislation
in force, the Company does
not make contributions to
political campaigns, political
parties, lobbyists or lobby
organizations, trade association
and other groups exempt from
paying taxes.
Anti-Corruption Corporate Policy
The main purposes of Rede D'Or São
Luiz's Anti-Corruption Corporate
Policy are to prevent bribes and
corruption, maintain our image and
reputation and enable the immediate
response to any matters on conduct.
The document covers specific topics,
such as the receipt and offer of gifts,
political contributions, recordkeeping
and internal controls, training and
rules enforcement. The Policy is
applicable to all of Rede D'Or São Luiz's
directors, executive officers, employees,
representatives and third parties.
Ethical guidelines campaigns
To help our Employees with
understanding attitudes that can
be considered potential acts that
violate our code of conduct's
ethical guidelines, we carried out
communication campaigns addressing
material topics to the company as well
as society, such as sexual harassment
and discrimination.
Integrity Program
Our Integrity Program
sets forth the implementation of mechanisms
used to prevent, identify and fight
corruption, bribery and frauds in bidding
processes and the relationship with Public
Authorities, ensuring Rede D'Or São Luiz's
full commitment to ethics and transparency.
It is based on the Brazilian Anti-Corruption
Law (12.846/13) and the respective decree
(8.420/15) and relies on the commitment of
the senior management, who safeguards its
application to the Company's daily activities.
Pillars of the Integrity
Program
Risks and Controls
Whistleblowing Channel
Accountability
and Independence
Policies, rules
and procedures
Communication and training
Senior management
commitment
Programa de
Integridade
REDE D'OR SÃO LUIZ
REDE POR
SÃO LUIZ
To spread and consolidate the
compliance and anti-corruption culture
at Rede D'Or São Luiz, we offer specific
training on the topics to our internal
stakeholders. Throughout 2020 and
2021, after the implementation of the
DL (distance learning platform), 55,855
employees completed the compliance
training, which have included topics
related to Rede D'Or São Luiz's code
of conduct and internal rules regarding
the topic, accounting for 87% of
our total staff. Furthermore, we also
made available a training focused on
anti-corruption practices, with 2,015
managers trained and approved,
accounting for 85% of our
target audience.
51 REDE D'OR SÃO LUIZ | Annual Sustainability Report 2021
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