Ethics Line

We want to hear your report about some misconduct that you may have noticed in the Atvos work environment or of one of our partners.

We have created a dialogue channel with you. This is a way of transforming the future.

If you do not want to identify yourself, you do not have to. We protect all information received and ensure that your report is kept confidential.

All records will be cleared. We want to be the energy that renews the actions of tomorrow.

To help you, let us know what is important for you to tell us:

  • What is the violation or report you want to let us know?
  • How, when and where did it happen or will the violation take place?
  • Who are the people and/or place involved?
  • Are there any witnesses?
  • How many times did the violation happen?
  • What would be the cause, motive or incentive for this situation or violation to occur?
  • Have there been or are there any monetary values involved? Please advise.
  • If there are any evidences, how can we find them?

You can make your complaint here on this very channel or by calling 0800 721 8434,
available 24 hours a day.

FOR THE REPORT PAGE

Clarify your doubts about the Compliance Policy:

What is the Ethical, Integrity and Transparency Policy?

It is the unfolding of our corporate culture and was designed to guide the behavior and the internal and external relations of all our members, together and in an integrated way with the other Atvos Policies.

What is the Commitment to an Ethical, Fair and Transparent Action?

It is Atvos' commitment to its ethical principles, which must be followed by our members, suppliers and partners.

Why is the Commitment to Ethical, Fair and Transparency Important?

It is important so that our members, suppliers and partners know, practice and defend our ethical principles.

What is the Compliance System?

It is a system of prevention, detection and remediation of conducts that are in disagreement with our ethical principles. Through the Atvos Compliance System, it seeks to act with ethics, integrity and transparency, in accordance with the best global governance practices and with the laws.

Does the Ethics Line channel guarantee anonymity?

Yes, it does. The Ethics Line channel is confidential and everyone who uses it will be able to report without identifying themselves

What is a conflict of interest?

It occurs when a member uses their position, function or negotiating position to obtain undue advantage, including indirectly. That applies to this person or to others he or she has a connection with.

What is bullying?

It is the exposure of the members to humiliating and embarrassing, repetitive and prolonged situations during their work shift.

What is abuse of power?

It is when a member in the position of leader exceeds the performance of their duties, requiring a person to lead certain actions or activities that are not in accordance with our policy of ethical, integral and transparent action.

What conduct should be practiced by members and partners who interact with public agents?

All must respect the current legislation and act in an ethical, integrated and transparent manner. It is prohibited for our members and partners to promise or authorize, directly or indirectly, any undue advantage, whether in cash, good or service, to public agents and related persons, political parties and their members, or to any candidates for office public, whether in Brazil or abroad, with the purpose of obtaining personal benefit or for the Atvos.

OUR COMMITMENT

Our future is in our hands.

So, we have these commitments to our business, our people and the future./p>

  1. Combating and not tolerate corruption in any of its forms, including extortion and bribery.
  2. Saying no, with firmness and determination, to business opportunities that conflict with this Commitment.
  3. Adopting ethical, integrity and transparent principles in the relationship with public and private agents.
  4. Never invoking cultural or usual market conditions as a justification for undue actions.
  5. Ensuring transparency in Atvos information, which must be accurate, comprehensive and accessible and regularly disclosed.
  6. Being aware that misconduct, whether by action, omission or complacency, harms society, violates laws and destroys the image and reputation of the entire Odebrecht.
  7. Ensuring at Atvos, and throughout the business value chain, the practice of the Compliance System, always up to date with the best references.
  8. Individually and collectively contributing to necessary changes in markets and environments where there may be inducements to deviations from conduct.
  9. Incorporating in the Members' Action Programs the performance evaluation in compliance with the System of Compliance.
  10. Being convinced that this Commitment will keep us on the path to Survival, Growth and Perpetuity.

COMPLIANCE POLICY

Our tomorrow began to renew the future of all people. We build our relationships with ethics, integrity and transparency.

The members of the Board of Directors of Atvos defined that all activities of the Members must always be guided by the Compliance Policy of our company and the corporate culture built in all those years.

The Politics says:

- The Commitment with Ethical, Integrity and Transparency and with the implementation of the Compliance System begins on the Atvos Board of Directors and should extend to all Members.

- The creation and performance of the Compliance Committee in Atvos and its Subsidiaries, in support of the respective Board of Directors, as well as the direct linking of the Compliance Officer to this Committee, reinforces the condition for the Compliance System to be put into practice effectively.

- The presence of independent members on the Board promotes diversity and enhances transparency and independent judgment, including with respect to compliance issues.