Corporate behavior

Policies & Practices

Does the company conduct audit of its anti-corruption policies?

We have an Audit Committee, wich is responsible for analyzing the financial statements and supervising risk management activities, internal auditing, compliance, internal controls, data management and cybersecurity, stakeholder relationships and management of the Conversa Ética Channel.

Regular audits of ethical standards

Since 2023, the Ethics and Compliance Program has been subject to biennial external audits, with results reported to the Audit Committee. The effectiveness of the reporting channel is assessed through the employee engagement survey, which measures employees’ perceptions of the Company’s ethical culture.

Does the company state that it audits ALL operations?

The complete Compliance and Ethics Program is audited.

Responsibility for ethics issues

Board level committee

Employee training on ethical standards

In 2025, all 73,379 employees (100%) received communications regarding the Company’s anti-corruption policies. A total of 17,398 employees (24%) completed at least one course within the Ethics and Compliance learning track, which includes the Code of Conduct, Relations with Public Authorities, Anti-Corruption and Anti-Fraud, and Conflicts of Interest. Detailed information on training participation by employee category and region is available on page 66 of our Sustainability Report.

Policy against bribery and corruption

The Conflict of Interest Policy requires directors, officers, and employees to disclose any situations that may represent a conflict of interest with the Company’s business and interests.

Whistleblower protection

The Ethical Conversation Channel is availablev24 hours a day, and is operated by an external, independent company, ensuring confidentiality, proper handling of reports, and protection against retaliation against the whistleblower. It can be used by employees, former employees, customers, suppliers, and other stakeholders. Reports may be anonymous or identified.

Policy against bribery and corruption for suppliers

Ethical standards also apply to business partners. To receive approval, suppliers must adhere to the Supplier Code of Ethics and Conduct and anti-corruption policies.