Integrity And Ethics Program Pillars
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.
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.
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.
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.
Integrity And Ethics Program
Compliance and Internal Controls
Prevention of Money Laundering and Terrorist Financing