Our work is guided by ethical principles, complying with the country's laws and the best market practices. The Code of Conduct embodies our commitment as an ethical company working under the Brazilian legislation and our operating market – as a way to contribute to an ever better society – and guides our employees to adopt a transparent approach when solving issues, creating a work environment making it possible to overcome obstacles in an honest, fair and equal way.
We have had an outsourced Ethics Channel since 2014, operating 24/7. We receive complaints on acts against the Company's ethical culture, ensuring anonymity and recording questions and suggestions on our Code of Conduct through this resource. After the complaint, the compliance area starts the investigation and the subsequent response to the case.
The complaints are made through Contato Seguro, an outsourced company that keeps the information confidential. Each complaint is assessed fairly and impartially with complete independence, caution, and responsibility. If the complaint is found to be true, the Company is informed to adopt the necessary measures. All complaints are answered and found on the Channel through the protocol informed when making the complaint.
Regularly, our employees undergo training on the Code of Conduct to answer questions and learn about any updates. In 2021, we conducted training at the construction works on our Compliance Program and Whistleblower Channel, reaching 91% attendance.
In the year, we updated the supplier procurement process and implemented the Supplier Code of Conduct, initially disclosed to the most significant and highest risk suppliers, which will be part of hiring new suppliers as of 2022.
A system guides the Compliance Program to map and mitigate ethical and integrity risks, with controls to prevent conflicts of interest, fight corruption and money laundering. The program is responsible for training and developing an integrity culture within the Company, monitoring gifts, policies and standards in line with the best market practices. Our practice is to promote, throughout our structure, the compliance culture based on our Code of Conduct.
We have forms on all risks for unethical conduct, corruption and fraud. As an action plan to improve our internal controls, we are structuring the Compliance Risk Assessment (“CRA”), a project that will diagnose and measure the classification of Compliance risks, to be implemented in 2022.
As a practice, we keep a continuous control aimed at fighting corruption. In 2021, we announced to employees the anti-corruption policies and procedures adopted by the organization, and we also carried out training on the subject through the e-learning system.
Employees who join Even are registered in a specific Compliance training tool and have seven days to complete the courses. In November 2021, we held the Integrity Week, aimed at all professionals to disseminate the Company’s ethics and integrity views.
Tool used to combat criminal and harmful conduct to Even and society. The system's mission is to identify criminals who intend to use our products to hide illicit money. In 2021, we adopted new technological tools to improve the program.
The Compliance Program helps establish guidelines and procedures to ensure that all members of the Company and those acting on our behalf are aware that they must adopt procedures following applicable laws. The Company also has several policies for Compliance, including:
We have a Conflict of Interest portal, which allows you to expose conflict of interest situations to the Compliance team, immediately taking the necessary measures to mitigate the risks. When hired, every employee must complete the conflict of interest form and suppliers during the due diligence process (supplier assessment).
The Compliance team analyzed the information and compiled it in our database, making it possible to reveal and anticipate possible conflicts of interest to stakeholders. A conflict of interest can be characterized as an act aimed at getting private advantages for oneself, family members or third parties to the company's detriment, exposing the organization to possible damages and/or losses. Additionally, there is an annual Conflicts of Interest refresher course.
