All operations were assessed for risks related to corruption, in a process conducted in accordance with the RGE Anti-Corruption Policy (internal document) and with Bracell Anti-Bribery and Anti-Corruption Policy (see Bracell Anti-Bribery and Anti-Corruption Policy for more about Bracell’s operational structure).

The Internal Audit, Compliance and Risk Management teams lead assessments of risks related to ethics and corruption. Identified risks are documented in internal procedures that form part of Bracell’s Integrated Management System (see GRI 2-13). These documents formalize our approach to identifying potential corruption-related risks, implementing preventive measures, and mitigating impacts.

Corruption risks, identified in the compliance risk matrix, are defined as corruption, bribery, fraud or similar acts committed by employees or third parties in Bracell’s name, by granting an unfair advantage or other acts defined as corruption in applicable legislation. The process of identifying and evaluating these risks was based on an assessment prepared by the Compliance department, following meetings with different departments and senior management. Interviews were carried out with the Audit, Human Resources, Enterprise Risk Management (ERM), Procurement and Communication teams, as well as operations teams with greater exposure to these risks.

The Compliance department also joined the process and risk design workshops led by the ERM department together with technical departments, assessing integrity risks.

The main causes identified include relationships with licensing, regulatory and oversight bodies, the absence of policies setting out procedures for contacting government officials, relationships with political actors and interaction with public officials by third parties acting on behalf of Bracell. Risks were also highlighted relating to the hiring of employees historically linked to the public sector or to government-owned companies, inadequate controls for the award of funding, presents, hospitality, donations and sponsorship, as well as the engagement of suppliers with a negative compliance recommendation in due diligence, but whose engagement was approved by senior management. Other issues identified include the lack of moral effect from monitoring and sanctions measures for non-compliance and the bad faith of employees or third parties who attempt to commit unlawful acts. The process of evaluating and managing corruption risk is continually being improved to strengthen Bracell’s culture of integrity and compliance.

Bracell also has a specific Whistleblowing Policy  for inaccuracies in financial reporting, aimed at all its own employees. This document sets out fundamental principles and procedures for reporting and investigating concerns. The policy presents the means whereby:

1. Employees raise concerns about possible inaccuracies in financial reports, internal controls or any other related matters.
2. A fair and independent investigation is carried out, with adequate follow-up to address each concern raised by employees.

Across all operations, whistleblowers are instructed to report potential inaccuracies to the Internal Audit departments. Reports can be made by telephone, email, snail mail, face-to-face meetings, and other means of communication.

Bracell has formal channels for submitting concerns and complaints (Fale Conosco and Contato Seguro — see more under GRI 2-25). Bracell formalizes its commitment to ethics and sustainability by means of a Code of Conduct and corporate policies that are public and disclosed to all stakeholders. Our policies are available on our website at Governance and Our Commitment.