Focused on the Culture of Integrity, the Avibras Anti-corruption Compliance Programme has rules, policies and procedures for the fulfilment of legal regulations established for the business and activities of the company, as well as to prevent, identify and mitigate any deviations or non-conformities. 

Part of the Avibras por Excelência (AVPEX) (AVPEX) programme, it is an important corporate governance instrument supported by pillars that reinforce the ethics and transparency in the conduct of business:

• Top Management Support

- Ethics Committee and proper regulations for deliberation of Ethics Channel reports in order to support the company’s governance/management, promoting legitimisation, respect, fulfilment, and improvement of the Code of Conduct.

- Audit and Risks Committee and proper regulations based on the best practices of Corporate Governance recommended by the Brazilian Institute of Corporate Governance (IBGC). 

• Risk Assessment

- General assessment of risks for identification and management of corporate risks and planning of internal audits;

- Meetings with Risk Owners to mitigate the identified risks;

- Risk Management Policy;

- Export Control Program.

• Code of Conduct and Internal Policies

- Avibras’ Code of Ethics issued in 2015 and revised in 2018;

- Information Security Policy;

- Anti-corruption Policies;

- Anti-corruption Compliance Policies.

• Training and Communication

- Anti-corruption Compliance training for leaders with the participation of the company’s directors;

- Continuous trainings on Ethics and Compliance for all employees;

- Specific trainings for critical areas;

- Brazilian Data Protection Law (LGPD) training;

- Labour Relations training for leadership;

- Regular communication regarding Compliance with all members of the company.

• Third Party Management

- Due Diligence and Background Check process of commercial partners and suppliers to identify risks of corruption related to third parties;

- Due Diligence report prepared by specialised company and Compliance risk assessment performed by Avibras;

- Presentation of Due Diligence that show Compliance risk for deliberation of the Audit and Risks Committee;

- Inclusion of Compliance clauses in contracts with suppliers and commercial agents;

- Management process of commercial agents;

- Commercial agents Anti-corruption Policy;

- Adhesion to Avibras’ Code of Ethics and Conduct as requirement for contract with third parties;

- Identification and assessment of possible conflict of interest performed annually with all employees through Relationship Mapping.

• Reporting Channel and Internal Investigations

- The Ethics Channel is managed by an independent and specialised company to ensure the secrecy and proper treatment of each report;

- Investigations carried out by Avibras’ Compliance team and periodically reported to the Ethics Committee, responsible for deciding on possible corrective actions;

- Periodic follow up of the disciplinary measures and other actions decided by the Ethics Committee;

- The Ethics Channel is widely disseminated in the company through the Ethics and Compliance trainings and periodical publications.

• Internal Controls
• Regular Audits
• Continuous Monitoring

Click here for more information regarding Avibras’ Anti-corruption Compliance Guidelines