Ethics, compliance and data privacy

Scope

Dissemination of the principles that govern the relationship between RD Saúde and its stakeholders, including the fight against labor and human rights violations in the supply chain, and compliance with laws and regulations. The topic also considers RD Saúde’s measures to prevent negative impacts related to the improper use of customer, supplier, and employee data; cyber-attacks and system failures.

Impact Sphere

Employees, contractors, customers, suppliers, government, society

Disclosures

GRI 205: Anti-corruption
GRI 308: Supplier Environmental Assessment
GRI 414: Supplier Social Assessment
GRI 418: Customer Privacy

Sustainable Development Goals

Theme management

Policies

In order to ensure an ethical culture and righteous conduct in all RD Saúde’s activities, we rely on management policies and guidelines approved by the Board of Directors. The documents are part of the Integrity Program and aim, in addition to controlling risks, to guide the mitigation, remediation and management of consequences of any ethical, moral or legal deviation.

Conflict of Interest

Employees and managers must declare potential situations of conflict of interest through a statement to the Ethics and Compliance area. If an administrator is faced with a potential conflict of interest in a decision, he/she must communicate this conflict and abstain from participating in the discussion about and vote on such matter. These actions must be recorded in the minutes of meetings or resolutions in which the matter was discussed.

We also communicate potential conflicts of interest to stakeholders, mainly regarding cross-board membership, cross-shareholding with suppliers and other stakeholders, existence of controlling shareholders and related parties, their relationships, transactions and outstanding balances.

Human Rights

We have a non-negotiable commitment to ensuring universal human rights. On a daily basis, the People Code and Human Rights Policy define internal guidelines, as well as the responsibilities of each RD Saúde employee. We do not tolerate any form of exploitation, harassment, disrespect, or prejudice within our facilities and activities. We reject any form of child labor or forced labor, respect diversity and inclusion, and comply with labor laws, including freedom of association.

To fulfill our commitment to respecting human rights, we have established a continuous due diligence process to identify, prevent, mitigate, monitor, and report on human rights impacts in our operations and value chain. We identify human rights impacts from our activities and commercial relationships based on the Guiding Principles methodology. Additionally, we assess human rights risks using the Guiding Principles methodology, which considers severity and probability criteria, as well as RD Saúde’s Corporate Risk Management methodology. The results of these assessments will be incorporated into the Company’s processes, policies, operations and activities, and we will monitor the effectiveness of the preventive and mitigation measures adopted. We also continuously seek to incorporate international standards and best practices in human rights into our operations and activities.

We will communicate annually about addressing the human rights impacts identified in the Annual and Sustainability Report and will conduct periodic training and awareness sessions with employees at various hierarchical levels to ensure everyone is committed to and engaged in promoting human rights within the Company.

When it is found that RD Saúde has caused or contributed to negative human rights impacts, we will seek to implement measures to mitigate or remediate these impacts, either directly or through partnerships, seeking to involve the participation of the affected rights holders.

Furthermore, we acknowledge the importance of maintaining effective relationships and engagement with stakeholders, especially potentially impacted individuals and groups. In order to ensure respect for the rights of our stakeholders, RD Saúde has established communication and dialogue channels with employees, contractors, customers, investors, suppliers, business partners, governmental and non-governmental organizations, trade unions, trade associations, the media, society in general, and the communities in which we operate.

Canal Conversa Éthica (anonymous ethics hotline)

We are pleased to offer the Canal Conversa Ética, our Whistleblowing Channel, to the entire society. This channel is available 24/7, and receives complaints about any conduct that violates national laws, our policies, procedures, and values. The channel allows for anonymous reporting and provides you with the ability to track the progress of your report.

Privacy and Information Security

Our Data Protection and Privacy Program complies with the Brazilian General Data Protection Law (LGPD), providing data security, confidentiality, integrity and availability to all data holders sharing personal data with us. We have a full compliance program, encompassing not only permanent technical and organizational measures capable of ensuring data security, but also robust internal governance, besides continuous training for our teams and professionals with the aim of accounting for compliance with guidelines, principles and legal obligations in a transparent manner.

Risk Management

Our risk management is based on the best national and international practices, such as ISO 31000 and COSO ERM, and those of the Brazilian Institute of Corporate Governance (IBGC) and the Institute of Internal Auditors of Brazil (IIA). Additionally, the risk management process undergoes periodic auditing, conducted by internal auditing in conjunction with specialized external consultancy. Internally, our operations are guided by the Risk Management Policy, which establishes guidelines and responsibilities for each employee, in addition to describing the methodology applied to the processes of identification, evaluation, processing, monitoring and communication of situations.

Check out more details of our initiatives related to ethics, compliance and data privacy in the GRI disclosures listed in this dashboard or in the Annual and Sustainability Report.

Related Policies

* People Code – Ethics and Conduct in RD Saúde
* RD Supplier Code of Ethics & Conduct
* Related Party Transactions Policy
* Anti-corruption, Anti-fraud, and Relations with Public Entities/Agencies Policy
* Conflict of Interest Policy
* Integrity Program
* Responsible Marketing and Communication Policy
* Privacy Policy