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Compliance Program

The Program is based on 7 pillars that guide our efforts in the search for compliance. They represent important issues for the organization and receive special attention from our leaders, who shall instruct their teams to guarantee:



I.   Compliance with Laws and Regulations and with the commitments assumed under the signed Contracts and Agreements;

II.   Obtainment of the Licenses, Authorizations and Certificates required for our operations;

III.   The quality and truth of all External Reports issued by us; and

IV.   The commitment of the entire Votorantim company with Antitrust, Fraud and Corruption Prevention.

Duties

Capture of Laws and Rules

Management of critical documents

Acculturation

Effective communication lines

Internal monitoring of the obligations

Consequence Management

Pillars

Laws and Regulations

X

Laws and Regulations

Our Companies have operations in several countries, and for that reason they are subject to several laws and regulations that may vary in accordance with the location of their operations. Irrespective of the above, the increment of new laws in Brazil requires more attention by each of us. Each employee is responsible for guaranteeing compliance with all obligations associated to the activities of his or her duties, including the identification, management and communication of any breaches of compliance. Some examples of laws and regulations applicable to our business: mining laws and technical rules, environmental and health and safety law; power regulations, rules on product quality, labor laws etc.

Licenses, Authorizations and Certifications

X

Licenses, Authorizations and Certifications

Operate our business establishments with the necessary licenses, authorizations and certifications, using efforts so that all obligations linked to them are timely observed. Some examples of licenses, authorizations and certificates: Operating License, Social License, Fire Department Inspection (AVCB), Permits, Certificate of Occupancy, Vegetation Suppression Authorization from the Brazilian Institute of the Environment and Renewable Natural Resources (IBAMA) etc.c

Contracts and Agreements

X

Contracts and Agreements

Comply with the contracts and agreements signed by our companies within the judicial or extrajudicial scope, involving compliance with statutory obligations and obligations originating from technical requirements the counterparty of which are inspection and control bodies, Public Prosecutor’s Office, bodies of the Judicial Branch, as well as bodies with authority to bring class actions. Some usual agreements in our activities: Consent Decrees (TACs), Consent Order, Memorandum of Understanding, Collective-Bargaining Agreement/Collective Labor Agreement, Instrument of Liability for the Preservation of Legal Reserve.

External Reports

X

External Reports

Disclose Financial and Sustainability Reports in line with the regulations and policies in effect, showing our commitment in relation to corporate liability, transparency and accounting to our stakeholders. Reports such as the GRI and the Annual Report are known as one of the main sources of information of the Company. The information contained therein originates from different areas, and it is therefore subject to errors. It is extremely important that this information be reviewed before we send it and they it truly represents the reality of our business.

Defense of Competition / Antitrust

X

Defense of Competition / Antitrust

The antitrust law is the repression to anticompetitive conducts, especially cartels/price-fixing, in addition to the control of concentration acts. The following are examples of cartel:

  • To agree, combine, manipulate or adjust prices, production or sale of goods and services, as well as conditions, advantages or abstention in public bidding;
  • To promote, obtain or influence the adoption of uniform commercial conduct among competitors.

For that reason, much caution should be taken:

Information such as the following shall not be discussed with competitors in any event: current and future prices, profit margins, discount policies, capacity, processes, methods and production costs, measures to prevent the entry of new competitors, among other sensitive information.

Loss and Fraud Prevention

X

Loss and Fraud Prevention

To prevent, detect and cure (sic)

The term fraud refers to intentional and deceitful act carried out to one’s own benefit or to the benefit of third parties, such as:

  • Omission or manipulation of transactions;
  • Adulteration/forgery of documents, records and reports;
  • Misappropriation of assets;
  • Corruption.

These actions may be a fraudulent act, generating consequences such as dismissal or even criminal charges.

Therefore, it is important for everyone to know the processes and controls and policies of the organization.

A loss/fraud prevention program consists in the structuring of a procedure to prevent, detect and cure the risk of fraud, with strict monitoring of the transactions.

Prevention to Corruption

X

Prevention to Corruption

Known as the practice of offering payment, offer or promise to pay an amount in cash or anything of value to public officials to obtain undue advantage or advantages in business.

To protect oneself and to protect Votorantim, it is important that everyone is attentive and knows how to avoid it. Some examples of care to be taken:

  • Never to offer or accept payment, offer or promise to pay (in cash or not) to public officials or to any governmental authority, irrespective of the amount involved;
  • Souvenirs and gifts cannot be accepted or offered, because they may be seen as a conduct aiming at influencing decisions that affect the company’s interests or personal interests. The same care shall be taken in the event of hospitality and entertainment benefits;
  • Facilitating payments are illegal according to most of the laws and, therefore, they are strictly prohibited;
  • No political contribution or election donations may be made in the name of Votorantim. In the event of doubts, please refer to the policy on Election Donations;
  • Care should be taken in the hiring of third parties. We recommend that a due diligence be conducted, ensuring the service provider acts in compliance with the law.

Instruments

Regulatory Framework

Policies and Procedures

Education and Training

Ombudsman’s Channel

Obligations Systems

Disciplinary Measures and Instructions



Access here the full Compliance Program Manual (link to the Manual)