We are Reaffirming Our “Commitment to Brazil”

In response to the investigations opened by Brazil’s Federal Supreme Court against politicians and lawmakers within the sphere of “Operation Car Wash,” the Odebrecht Group released a statement yesterday reaffirming its “Commitment to Brazil,” a position it established in March 2016 to fully collaborate with the investigations.

“The measures adopted now result from a decision Odebrecht consciously made a little over one year ago,” emphasized the text, which can be read in full on the Our Commitment website.

The document also reinforces the point that Odebrecht “has adopted a new governance model and is implementing strict standards to fight corruption, with permanent surveillance so that all of its actions, primarily those involving public officials, take place ethically and with integrity and transparency.”

Channel for Reports

This posture reflects a series of measures adopted by the company in response to its members, the justice system and society. One of these is the reformulation of the Ethics Hotline, which will make changes to its member interface still during this half of the year. These will include improved transparency during the investigation proceedings and more security for those who want to report an incident.

In 2016, the channel received a total of 3,121 records of reports associated with possible conducts that did not comply with ethical, upstanding and transparent operations. All of these records were analyzed based on the criteria of confidentiality and independence, guaranteeing the anonymity of the reporting parties and secure verification.

The analysis of the 3,121 reports concluded that 377 were founded or could generate process-related improvement opportunities. For all of these cases, Odebrecht spared no effort to mitigate the risks, implement the necessary improvements, and in certain cases, take corrective and disciplinary measures. Some of these included the dismissal of 30 members and termination of the partnership with four suppliers. From January to the start of April 2017, the channel received over 1,000 reports.

Internal Inspection

Another recent initiative was the contracting of independent monitors as part of an agreement signed with the Brazilian, U.S. and Swiss governments. The monitors are Compliance specialists and began working within the group to monitor fulfillment with the commitments assumed by Odebrecht as part of the Leniency Agreement signed with the Brazilian Federal Prosecutor (MPF), U.S. Department of Justice and Swiss Attorney General’s Office.

The two professionals will check, for example, whether the internal measures recently intensified through the Compliance System – prevention, detection and remediation – are being fully implemented.

Reinforcement of Teams

At the same time, the teams from Odebrecht S.A. Compliance and the Businesses have been reinforced since December 2016. The idea is to support the leaders during the implementation of the provisions established in the new Odebrecht Group Compliance Policy released in January.

The document expands the Code of Conduct, which was replaced. The Compliance Policy puts emphasis back on the values of the Odebrecht Entrepreneurial Technology (TEO) and reinforces how all members, regardless of their duties and hierarchical positions, can adopt an ethical, upstanding and transparent posture.