Investor Presentaiton
Total number and percentage of operations submitted to risk evaluation related to corruption
and significant identified risks |G4-S03|
Operations
Due diligence of suppliers
Due diligence of sponsors
Due diligence of donations
Due diligence of class entities
Communication and training in policies and procedures for fighting corruption [G4-S04|
Total number of operations submitted to
risk evaluations related to corruption
Percentage of operations submitted to
risk evaluations related to corruption
Region*
Governance bodies established in the organization
Number of individuals and/or employees
that compose each governance body
Board of Directors
13
5,164
146
100
Southeast
100
Fiscal Counsil
Board of Executive Officers
10
9
34
96
100
Total
32
100
Risks related to corruption
Type of risk
evaluation
Conflicts of interest (improper or
incorrect payments in order to
obtain favors)
Qualitative
Improper accounting (incorrect
Qualitative
records and/or provisioning)
Improper commercial discounts
(absence of approval or alteration
of prices)
Qualitative
Failure to observe proper anti-
corruption procedures in the
M&A process
Qualitative
Improper or duplicated payment
(to public authorities and
certifying entities)
Bribery or improper benefits (improp-
erly receiving or paying suppliers,
commercial representatives, custom-
ers, public authorities and
external entities)
68
Qualitative
Qualitative
Action to mitigate risks
Inclusion of the subject of conflicts of interest in training that is related to
anti-corruption and to the Code of Ethics, analysis of suppliers through the
due diligence process, in addition to responses to periodic consultations
held with the Compliance team. Additionally, continuous surveillance was im-
plemented for payments considered critical and specific tests were included
for the departments analyzed by the Internal Audit. Control tests were also
performed for SOx certification, by the Internal Controls department.
Continuous surveillance was implemented for payments considered critical
and specific tests were included for the departments analyzed by the Internal
Audit. Additionally, control tests were also performed for SOx certification, by
the Internal Controls department.
Inclusion of specific tests in the departments analyzed by the Internal Audit.
The Compliance team's carrying out of the due diligence analyses, in addi-
tion to carrying out training on anti-corruption matters. Additionally, specific
tests for verifying due diligence in Mergers and Acquisitions (M&A) processes
were included in the Internal Audit's work plan.
Inclusion of the subject of conflicts of interest in training that is related to
anti-corruption and to the Code of Ethics, analysis of suppliers through the
due diligence process, in addition to responses to periodic consultations
held with the Compliance team. Additionally, continuous surveillance was im-
plemented for payments considered critical and specific tests were included
for the departments analyzed by the Internal Audit. Control tests were also
performed for SOx certification, by the Internal Controls department.
Continuous surveillance was implemented for payments considered critical
and specific tests were included for the departments analyzed by the Internal
Audit. Additionally, control tests are made for SOx certification, executed by
Internal Controls and training actions and responses to periodic consulta-
tions made to the Compliance team.
Region*
Number of individuals and/or
employees that compose each
governance body in each region
Southeast
32
* Considered only the Southeast region of Brazil
Functional categories
Leaders
Non-leaders
Types of trading partners
Suppliers
Third parties (commercial representatives,
law firms and logistics agents)
Functional category
Board of Executive Officers
Manager
Supervisor
Pilot
Engineer
Number of members of the
governance body to which anti-
corruption policies and procedures
have been communicated
Percentage of members of the
governance body to which anti-
corruption policies and procedures
have been communicated
32
100
Number of employees in each functional category
1,177
16,133
Number of each type of trading partner
5,064
100
Number of employees who were notified of the
anti-corruption procedures and policies
Percentage of employees who were notified of
the anti-corruption procedures and policies
87
98
382
97
629
99
77
99
3,680
100
Professional
0
0
Technical
3,223
95
Administrative
8,027
94
Operational
1,205
Total
17,310
99
97
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