Policies, internal rules and codes
The Company relies on a Conduct Committee, which is independent and autonomous, reports directly to the Board of Directors, and is responsible for implementing, sharing, training, reviewing and updating the Code of Ethics and Conduct, as well as managing the Whistleblower Channel, investigating and recommending corrective measures related to possible offenses.
The Code is established and approved by the Board of Directors, and is applicable to all employees, including senior management. When onboarded, employees receive the document and acknowledge it. The document establishes sanctions in case of non-compliance with the rules.
The Company also has a manual on conflict of interests linked to the Code of Ethics and Conduct that is provided to all employees. Possible conflicts are reported to the Ethics Committee, which assesses if the Company’s principles and guidelines have been impacted. In addition, the donation policy determines the guidelines on voluntary contributions, including those related to political activities, whose donation ceiling have been discussed and approved by the Board of Directors.