?We Need to Get Rid of the Idea that It is Just About Laws”

For Everson Zaczuk Bassinello, Compliance cannot be a topic restricted only to standards and regulations. It needs to be a daily topic, both in our personal and professional lives. Read the interview the Chief Compliance Officer (CCO) of Braskem granted us about this and other topics associated with our change process

How does the Compliance evolution at Braskem differ from the process that the entire Odebrecht Group is undergoing?

The models are very similar. Our Compliance System is closely aligned with that of the Group of which we are part. Both are anchored on three pillars: prevention, detection, and remediation – together with 10 structured measures to make this system work. What changes is that every measure had to be analyzed, adopted, and adjusted to meet the specific characteristics, maturity, and need of Braskem, a publicly traded company with its own regulatory issues and operations in the United States, Mexico, and Europe, in addition to Brazil.

On this point, does Braskem’s reality make the process more complex?

Yes, but the fact that we are a publicly traded company makes things easier, since we already completed a process to structure our control and Governance environment. I view this movement not as one of rupture, but rather of evolution, which will make the company more robust and better prepared.

The Braskem Compliance System has always been recognized as one of the most advanced in the Odebrecht Group. Has this been a differential?

Despite the fact that our Compliance System is a reference internally, when we compare ourselves with best market practices, there is still a ways to go. Our Compliance Program includes over 160 initiatives for improvement. We have already been able to move forward with new Guidelines and Procedures focused on Compliance themes, for example. Currently, we have a global structured plan for Training and Communication on Compliance, all with a specific focus for each region in which we operate. Another change involved the management of the Ethics Hotline. Good market practice suggests that this channel be outsourced. We followed this line and currently have a more professional and independent channel, with a report management tool considered a reference. We also established a new third party evaluation process (Due Diligence). Additionally, we formalized the Internal Audit feature, which began to objectively and independently evaluate the effectiveness of the processes and controls.

Is the Braskem Ethics Hotline methodology different than that followed by the Ethics Hotline of the other Odebrecht Group Businesses?

We work with the same provider (ICTS). The design of the processes is very similar. What changes is that the contracts and environments are separate and distinct, guaranteeing adequate Governance for report management at each Business. Today, Braskem has 90 test protocols to be followed for each type of report, tailored to its reality.

How would you evaluate the first months of this Channel at Braskem?

We have noticed that the report is good quality. Before, we had several reports without any connection with the Code of Conduct, non-productive from an information standpoint and which hindered the investigative work greatly. Today, there has been a significant increase in the number of reports, but we have noted an improvement in the quality of these reports: they are better structured and complete, which facilitates the investigation. Statistically, the majority of the reports are associated with a conflict of interest first, and then issues involving the work environment second. We already have several investigated and well-founded cases for which disciplinary measures have been taken, including dismissal with just cause.

The Compliance teams are still viewed as the “front line” of our change process. What is the main challenge of taking this empowerment to the leaders and team members?

What I’m trying to do at Braskem is the same thing we did with Health and Safety, a topic that became something daily for people and the leaders’ APs. The idea is that Compliance is found in members’ DNA the same way as Health and Safety. At Braskem, in any work environment you visit, you can find safety videos and guidelines. During the meetings, you have indicators on the topic.  Compliance has to reach this level. The industrial plants hold the Daily Safety Dialogues (DSDs), but during my visits, I have not yet seen dialogues about the Code of Conduct, Compliance Policy… This is what needs to happen. When we reach this phase, we will achieve our objective. It is a long journey, not an overnight change, and this work needs to be automatic and natural. It is a topic that needs to mature further.

Why?

Compliance is still a new topic. What has been the motto of our work? To associate Workplace Safety with personal and family safety. It is this analogy we are creating: associating Compliance in the business setting with issues of ethics from a personal-family perspective. We need to get rid of the idea that we are only talking about following laws, standards, and regulations. That is not all. It is integrity that we need to discuss here, and we have prompted leaders to disseminate this concept.

Braskem has its own independent monitors. What will their interaction be like with the independent Odebrecht Group monitors?

They are entirely separate and distinct leniency agreements. The Odebrecht Group monitors do not interfere with the work of the Braskem monitors: American Guy Singer an Brazilian Henrique Vergara. The first reports to the DOJ (U.S. Department of Justice) and the second, to the MPF (Brazilian Federal Prosecutor).

With 41 industrial units and offices in the Americas, Europe, and Asia, Braskem serves Clients in over 70 countries. How can you guarantee the alignment of Compliance within such an extensive geographic, political, and cultural context?

This is indeed a major challenge. We aligned a global orientation for all regions so that we can reach all sites in a macro fashion. However, we have seen that we need to make some adjustments at the procedure level, since we are dealing with different laws and cultures. In Europe, for example, there is a more mature process, a much more evolved educational culture. Many risk scenarios do not even appear; they are unimaginable. We need to adopt a global vision that can adapt to the reality and specific characteristics of each region. Remembering always that, if a specific unit wants to be more conservative or restrictive, it can be. The opposite is not true. This is the principle we are adopting.