Investor Presentaiton
26 GOVERNANCE
ETHICS AND
TRANSPARENCY
(G4-56, G4-LA9 and G4-S03)
ELDORADO BRASIL 2016 SUSTAINABILITY REPORT 27
The Eldorado Code of Conduct sets
forth the ethical guidelines that all
employees must follow in internal
and external relationships, includ-
ing interactions with customers,
suppliers, service providers, share-
holders, government and commu-
nities. After being presented and
trained under the Code of Conduct
all new employees must formally
commit to comply with the rules
outlined in the document.
Eldorado's Code of Conduct en-
compasses the applicable laws
in all the countries in which the
company operates. It addresses
different topics such as equality of
opportunity and treatment for all
employees, harassment and abuse
of power, child and slave labor,
conflicts of interest, political par-
ticipation, gifts and relations with
public entities, underscoring the
prohibition of the offer of any kind
of advantage or privilege for public
authorities.
The Ethics Committee, compris-
ing representatives of the Human
Resources, Legal, Finance and
Supplies departments, must ensure
the code is being strictly followed.
The committee meets every two
months or whenever necessary to
analyze reports received via the
Ombudsman channel and to decide
on courses of action (further infor-
Código de Conduta
Widely disseminated, the Code
of Conduct may be accessed
via the website:
www.eldoradobrasil.com.br
mation on the Ombudsman ahead).
The Ethics Committee activities are
reported to the People and Devel-
opment Committee, which provides
support for the Board of Directors,
on a quarterly basis.
In 2016, a workshop was orga-
nized for company leaders on Code
of Conduct and compliance to em-
phasize their role in disseminating
best practices within the company.
The company also carries out peri-
odic audits to ensure the accuracy
of its accounting practices. In July
and September, two search and sei-
zure warrants were issued against
the Eldorado head office as part of
cautionary measures taken by the
federal public prosecution service
to investigate alleged irregulari-
ties in FI-FGTS fund management
and in investments made by four
supplementary pension plans
(Petros, Funcef, Previ and Postalis).
The warrants were aimed at col-
lecting evidence of supposed illicit
practices that might have been
documented by the company. The
company contracted the services of
the legal practice Veirano Advo-
gados Associados and an audit by
Ernst&Young to conduct an inde-
pendent investigation, which found
no indications that the Public Pros-
ecution service allegations were
grounded.
Eldorado reaffirms its willingness
to collaborate with the competent
authorities in fully clarifying the
facts. Committed to transparency
and continuous improvement, the
company is now analyzing the
establishment of a Compliance de-
partment to strengthen its internal
controls.
Eldorado Ombudsman
E-mail:
[email protected]
Telephone: 0800 5275 280
Consolidation of the
Ombudsman
(G4-58, G4-S03)
One of Eldorado's main commu-
nication channels with its stake-
holders, the Ombudsman receives
reports, complaints, praise and
suggestions from employees, ex-
employees, suppliers and business
partners, members of neighboring
communities, customers and the
press. In 2016, management of
the Ombudsman service was taken
over by a specialized external
company, reinforcing the channel's
credibility. Contacts may be made
in Portuguese and English, with full
confidentiality guaranteed.
Other company communication
channels include the Sustainability
area email address, face to face
meetings with community mem-
bers and neighbors, the Contact Us
channel on the institutional web-
site and the company's pages on
Facebook and LinkedIn.
In November 2016 and February
2017, measures to disseminate
contact information for the Om-
budsman and the Sustainability
area in 16 communities with which
Eldorado maintains relations
were taken.View entire presentation