A Compliance Program should aim to do more than just comply with legislation.
OGMA Ethics & Compliance Program goes much further! It consists of a set of practices adopted in the Company, based on transparency, honesty, integrity and trust, which are aimed at directing our people not only to comply with the law, but, most of all, to strengthen our ethical culture.
We define our expectations in internal policies and procedures that are widely disseminated, so that they are known and applied by all our people and by all third parties we interact with.
In addition to protecting our Company, preventing corruption and related offenses, fraud, money laundering and other illicit acts that can cause severe damage to our reputation, OGMA's Ethics & Compliance Department protects our people, safeguarding the sustainability of our business.
GOVERNANCE AND COMPLIANCE AT OGMA
OGMA conducts its business with ethics, transparency and integrity, in strict observation of national and international corporate governance best practices.
Governance structure of OGMA Ethics & Compliance Program is as follows:
The Board of Directors is responsible for providing appropriate support to the Ethics & Compliance Program and, consequently, for supporting the implementation of the Plan for the Prevention of Risks of Corruption and Related Offenses.
The CEO is responsible for executing, controlling, reviewing and supporting the Ethics & Compliance Program, providing for the integration of ethical commitment and of the requirements for the Prevention of Corruption and Related Offenses into business processes, as well as for the appropriate technological, human and financial resources, raising awareness for integrity issues and setting the "tone at the top".
The Compliance Department is responsible for conducting initiatives related to ethics and corporate integrity, and for promoting a culture of Ethics & Compliance at all levels in the company. It coordinates the Ethics & Compliance Program, establishing policies and procedures, training and communication for several targets (internal and external), monitoring the risks related to ethical deviations and conducting investigations into possible misconduct. Furthermore, the Compliance Department supports and guides business areas in case of doubt and monitors the work developed by Compliance Ambassadors and Agents.
The Ethics & Compliance structure is therefore reinforced by a team of Compliance Ambassadors and Agents, who are responsible for supporting the Ethics & Compliance Department in promoting a culture of Ethics & Compliance in business areas, ensuring that all our decisions are guided by ethics, transparency and integrity, with strict adherence to the company's policies and procedures.
OGMA Directors and Heads of Department promote all the Company's Ethics & Compliance initiatives, putting our Values into practice in all business transactions, in accordance with OGMA Ethics & Compliance Program. OGMA Directors and Heads of Department demonstrate, in their day-to-day work, by setting an example, their commitment to and leadership in conducting our business with the highest ethical standards, promoting a culture of Ethics & Compliance in line with the "walk the talk" concept throughout the organization.
Embraer's Audit and Risk Committee is responsible for overseeing the Ethics & Compliance function of Embraer and its affiliated companies, including OGMA, in accordance with the company's governing documents, which instruct the Audit and Risk Committee, including Embraer's Audit and Risk Committee Rules of Procedure.
Embraer's Internal Audit Department is responsible for auditing the implementation of the Ethics & Compliance Program at OGMA, as well as the Company's compliance with the applicable laws, including the Prevention of Corruption and Related Offenses laws. It is also responsible for conducting specified investigations related to Ethics & Compliance issues.
OGMA ETHICS & COMPLIANCE PROGRAM
Our Ethics & Compliance Program goes far beyond complying with the applicable laws and with our internal rules and procedures. It is a set of practices adopted in the Company, based on transparency, honesty, integrity and trust, which are aimed at directing our people not only to comply with the law, but, most of all, to strengthen our ethical culture. We are committed to preventing, mitigating and responding to corruption risks and to other internal risks that are not acceptable under our organizational Values.
In addition to the recent General Regime for the Prevention of Corruption, the construction of our Ethics & Compliance Program has taken into account the main international guidelines on the subject. We rely on the full commitment of OGMA's Top Management to promote our Ethics & Compliance initiatives and to constantly improve our Program.
Ethics & Compliance Program initiatives are based on Compliance risk assessments, which serve as a starting point for strategic planning applied to the other pillars. The purpose of Ethics & Compliance strategic planning is to ensure that all initiatives are aligned and incorporated throughout OGMA operations.
OGMA Code of Ethics and Conduct is the cornerstone of our Ethics & Compliance Program which, based on OGMA's values, reflects our commitment to conducting business with ethics, transparency, integrity and social responsibility, valuing healthy relationships between our people and with all third parties we interact with, respecting the environment and contributing to the development of the community in which we operate.
As a complement to the provisions in our Code of Ethics and Conduct, we have defined policies, procedures and internal controls, which are widely disseminated through communication and training sessions, so that they are known and applied by all our people and by all third parties we interact with.
Awareness of Ethics & Compliance issues is raised through ongoing communication and training, to prevent violations or any deviation from OGMA's Values, principles and guidelines.
Since we conduct business ethically and transparently in all our operations around the world, we have defined a set of due diligence procedures for third parties (customers, suppliers, business partners, etc.), in every location where we operate. These procedures are carried out on a regular basis, either when procuring business with potential customers, selecting suppliers and/or business partners, or during the contractual phase (for monitoring purposes).
OGMA Ethics & Compliance Program provides a communication channel - the Helpline - which can be accessed by all OGMA employees and also by people outside OGMA. This channel is managed by an external company specializing in this area, was developed based on four fundamental pillars: anonymous reporting (if that is the reporter's intention), guarantee of non-retaliation, confidentiality of information (regardless of whether or not the reporter has chosen to remain anonymous) and commitment to the truth of the matter. Reports on the Helpline are investigated by a specialized OGMA team and reported to Top Management on a regular basis.
All these initiatives are periodically monitored so that they can be improved in a continuous manner, thus making our Ethics & Compliance Program increasingly effective.
We are certain that the quality and effectiveness of our Ethics & Compliance Program is the result of the commitment and action of all our people, who are fundamental for the continuous strengthening of our ethical culture and for making a desirable positive impact on OGMA, on the entities we interact with and, most of all, on our society.
