INTEGRITY PROGRAM
Our program is a mechanism used in the prevention, detection, response and remediation of irregularities, which violate or may violate the Anticorruption Law, the Anti-bribery Management System and the Code of Ethics and Conduct of the Grupo Nova Participações.
Supported by five pillars necessary for its development and sustainability, it aims, above all, to promote a culture of integrity in our companies, through its policies, procedures and internal controls that are part of a structured Integrated Management System certified under the ISO 9001, ISO 14001, ISO 45001 and ISO 37001 standards – Quality, Environment, Health, Safety and Anti-Bribery, respectively.
PREVENTION
- adequacy of internal rules for hiring suppliers;
- adequacy of internal rules for the preparation of proposals;
- adequacy of codes of ethics and conduct.
CONTROL AND AUDIT
CONTROL AND AUDIT
- improved management of the reporting channel tool;
- resource input and output mapping;
- conducting contract audits using integrated management system data;
- employee training on internal rules and policies.
REMEDIATION
REMEDIATION
- solução dos registros realizados no canal de ética;
- constitution of committee to analyze possible infractions and to apply penalties.
COMMITMENT AND SUPPORT FROM THE TOP MANAGEMENT
Although it is everyone's responsibility, the Group's top management is the main supporter of the Program, incorporating and spreading its values, rules and policies in each of its goals and speeches - public and private - in addition to providing material and sponsorship, necessary to its continuous improvement.
RESPONSIBLE INSTANCE
The Governance and Integrity Directorate is endowed with autonomy, impartiality and resources, being responsible for the development, application and monitoring of the Program. It also has the support of an independent committee, a collegiate and technical advisory body, formed by highly qualified external consultants, whose purpose is to encourage and recommend good practices, indicating and evaluating the effectiveness of our risk prevention mechanisms.
RISK ASSESSMENT
Necessary for the identification and mitigation of the main risks inherent in our business segment, the periodic assessment serves to measure our degree of exposure and vulnerability, mainly preventing situations that may facilitate or hide the offer of undue advantage to public agents, or contribute to the occurrence of fraud in bids and contracts, especially in relation to the provisions of Anti-Corruption Law No. 12,846 / 2013.
TRAINING AND COMMUNICATION
Fundamental to the effective promotion of the Program, we have developed a comprehensive training and communication plan, which aims to guide the different target audiences of our companies - regardless of their hierarchical levels - on the content and practical aspects of the law and our policies and procedures. At Nova Participações Group, knowledge about general values and guidelines for ethics and integrity is accessible and widely disseminated to all stakeholders.
POLICIES AND PROCEDURES
Also known as instruments of the Program, they are joint and systemic tools that enable their continuous improvement, based on our risk matrix. We highlight our Code of Ethics and Conduct, which guides each and every business of Nova Participações Group. Bearing in mind that, our policies and procedures are periodically reviewed by our area of ethics and integrity, in order to effectively supervise each of our internal processes.
See our Code of Ethics and Conduct and our integrity policies, available for download:
POLICIES
ETHICS CHANNEL
Exclusive and confidential tool for safe and, if desired, anonymous communication of conducts that violate the law, the Code of Ethics and Conduct and/or company policies, accessible to the internal and external public.
All reports are treated with confidentiality and secrecy, without exposure of the reporting person. It is simple, safe and anonymous.