Integrity and Ethics

Integrity and Ethics Program Pillars

Senior Management Commitment

By means of the Code of Ethics, the Executive Board determines the standards of ethical and moral conduct, and establishes internal guidelines required from Directors, employees, interns and young apprentices (“Employees”) of Oliveira Trust, also expressing values and principles guiding moral conduct for all those directly or indirectly related to the rendering of services by Oliveira Trust, to society and relationship areas, determining the internal discipline standards, duties and restrictions.

Policies And Procedures

It includes the preparation and updating of integrity and ethics guidelines, to ensure that they comply with the Code of Ethics, the applicable legislation, and good market practices.

Communication And Training

Educational and communication initiatives about the program enable administrators and employees to:
– Build in-depth knowledge of integrity and ethics guidelines, as well as their application to business and people and process management.
– Be able to identify, prevent, and resolve ethical conflicts and conflicts of interest, interpersonal conflicts, and misconduct inherent in their daily activities.
– Get to know the communication channels, such as: the whistle-blowing channel, ombudsman, and contact us.
Communication and education practices comprise:
– Communication Plan: includes awareness campaigns, press releases on specific ethics-related topics, and disclosure of policies and guidelines.
– Qualification and Training Program: it comprises the training initiatives in person and remotely.

Monitoring Of The Integrity And Ethics Program

The Compliance Board is responsible for the continuous monitoring of the program’s effectiveness and potential adjustment needs, directly involving several areas of the company and with periodic reports to the Compliance and
Risks Committee. This monitoring includes testing the processes by Internal Controls and Compliance, monitoring indicators, managing the whistleblower channel, and addressing new regulations affecting the program. Based on the monitoring results, we identify requirements for adapting and improving the Ethics and Integrity Program. Assessment of program compliance and possible opportunities for improvement can also be performed by an external auditing, certification, or accreditation company.

Whistleblowing Channel

Oliveira Trust’s whistleblower channel was developed to comply with the Brazilian Anticorruption Law 12,846/2013 and BACEN Resolution 4,567/17 and can be used by employees, interns, temporary workers, young apprentices, suppliers, service providers, customers and others who hold information that might help fight corruption, fraud, money laundering, other criminal practices, discrimination or misconduct. All information submitted will be considered confidential and restricted to those in charge of analyzing and investigating the claims, who may initiate internal investigations, as well as public authorities’ investigations, according to the reported fact.

Voluntary Acts

Oliveira Trust is determined to spread good business ethics practices that can eradicate corruption from the list of strategies to obtain economic results. Aware that the eradication of illegal, immoral and unethical practices depends on an effort by socially responsible economic agents to involve an higher number of companies and civil organizations in such initiatives.

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Integrity and Ethics Program

Code of

Compliance and Internal Controls


Prevention of Money Laundering and Terrorist Financing

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