What are we doing to improve our Compliance?

We are determined to turn the page and leave behind errors and acts that failed to comply with best business practices. Our goal is to make progress implementing new policies, controls, and conducts so that society views us as an ethical, upstanding, and transparent Group.
Over recent months, some of the changes we assumed help to answer this question. They are part of a continuous evolution process – one that does not end here. And remember: it’s a process in which you play a crucial role.

Commitment to Society

Besides apologizing for our participation in the illegal practices revealed by “Operation Car Wash” in Brazil, we have brought this information to light – for all of society and for our members and families – to assume a commitment to change. In Our Commitment to Ethical, Upstanding, and Transparent Operations, we are committed to adopting concrete Compliance measures, which are already being implemented and which demonstrate that corruption will no longer be tolerated in our relationship with suppliers, clients, public officials, sponsorship agreements, and political contributions.

Transparency in the Market

Certain measures that were recently adopted prove Odebrecht’s determination to increase the disclosure of its information. One example is the expansion in the number of independent members on the Odebrecht S.A. Board of Directors and its Businesses. The creation of the Compliance Committees at all the Businesses and implementation of a Compliance Policy – with clear rules about the company’s relationship with suppliers, clients, public officials, sponsorship agreements, and political contributions – is also a concrete measure for making its business operations transparent. The report elaborated by the NGO Transparency International, released at the end of 2016, shows that we moved up 47 positions in the ranking of best practices in transparency of information disclosed – from 97th position in 2013 to 50th in 2016. The study, which was based on data from 2015, evaluated the disclosure of information by the 100 largest multinationals in 15 emerging countries.

Compliance Committees

The creation of Compliance Committees at all of our Businesses (these are known in the market as audit committees) also reinforces our quest for transparency in the way we conduct our activities. The initiative is a complement to the elaboration and implementation of a new Compliance Policy – a concrete measure to make our business operations more ethical.

Changes in Governance

Our Governance was improved and expanded into all environments. We set up Boards of Directors at each Business. We also increased the number of independent professionals on these boards, guaranteeing at least 20% independent board members in each group (and no fewer than two participants with this characteristic). In 2015, there were six independent board member positions. Today, there are 13 openings. The plan is to reach 23 by the end of the year. These professionals are business experts and offer assistance through their experience.

Reinforcements of Teams

Perhaps there is no other business corporation in Brazil today with so many Heads of Compliance – in the market, they are called CCOs (Chief Compliance Officers) – as there are at Odebrecht.  There are nine at each Business. Furthermore, the Compliance area had 30 professionals in 2015 and increased this number to 49 in January 2017. This number should reach 60 by the end of the year. This team is responsible for creating and improving processes and controls, together with education and training projects, and the investigation of any reports. These activities are undertaken by internal teams, with the support of consultants and external companies. The investment also grew. It skyrocketed from R$ 11.4 million in 2015 to R$ 64 million in 2017.

Independent Monitors

Since February, any and every Odebrecht Group activity, including financial and accounting matters, has been monitored by two independent external monitors. One has been designated by the U.S. Department of Justice (DoJ) and the other by the Brazilian Federal Prosecutor (MPF). They verify primarily whether there is fulfillment of the requirements established in the Leniency Agreement we signed with the MPF, DoJ, and Swiss Attorney General’s Office as a result of whistle-blowing by 77 executives and former executives of the Group. Recently, the monitors answered a series of questions sent by Odebrecht News about what this work will be like and how it can impact your routine as a member.

New Ethics Hotline

We understand that the commitment to our company’s future belongs to us all. This is why we outsourced the Ethics Hotline to a specialized and independent company. The hotline is a channel that allows members, partners, or any person from society to report behaviors that violate Our Commitment. Independent and outsourced, the channel guarantees the reporting party’s anonymity, ensures the confidentiality and secrecy of the information, and improves the report receipt process. It is possible to make a report by calling a toll-free number and speaking directly with a specialist. There are also online resources or possibility of leaving a voice message. The new channel allows users to monitor – always anonymously – the verification and evaluation process for the complaint through a protocol.