COMPLIANCE

We give full support in COMPLIANCE PROGRAM planning and implementation through the creation and maintenance of specific programs in the area, within the COSO (The Committee of Sponsoring Organizations of the Treadway Commission) methodology, including the training of managers, employees, and other professionals who are involved in this important and essential corporate activity.

DEVELOPMENT AND IMPLEMENTATION OF COMPLIANCE ACTIVITY

COSO Methodology

The Committee of Sponsoring Organizations of the Treadway Commission

Diagnosis, Implementation, Training, and Maintenance of Compliance Activity, in compliance with national or foreign legal provisions (Brazilian Anticorruption, FCPA, Sarbanes-Oxley, UK-BA, Antitrust), Receipt of Complaints (Ethics Channel), and Work/Adaptation to the standards of collegiate bodies (Directors and Fiscal Boards, Audit Committee, Ethics Committee). Background analysis of business partners and entities subject to merging and acquisitions that were accomplished, or are under consideration.

Determination of conduct deviations regarding internal corporate laws, and norms.

The Compliance Program consists of 9 items:

Promotion and Culture Strengthening

Detection