Policies and Procedures

OGMA is based on values that underpin its organizational culture and on actions guided by ethics, transparency and integrity.

 

In what concerns Ethics & Compliance internal guidelines, OGMA defines its expected conduct in internal policies and procedures that are widely disseminated among all our people and all our stakeholders for them to be aware of and apply.

 

See the documents below to find out more about our Ethics & Compliance guidelines:

Based on OGMA's values, our Code of Ethics and Conduct reflects our commitment to conducting business with ethics, transparency, integrity and social responsibility, valuing healthy relationships between our people and with all those we interact with, respecting the environment and contributing to the development of the community in which we operate.

 

In this context, our Code of Ethics and Conduct provides for strict observation of corporate management and accounting good practices, and provides guidelines so that our actions and decisions are taken with responsibility, quality, honesty, trust, respect and loyalty, at all times.

Download

The Anticorruption Policy reiterates OGMA's commitment to preventing corruption and to conducting business in accordance with the highest ethics, integrity and transparency standards.

 

This policy is the formalization of a set of OGMA guidelines intended to prevent, detect and combat any type of corrupt practice, and applies across the Company to all our people and to all third parties we interact with (customers, suppliers, business partners, etc.), in every location where we operate. 

Download

Anti-money laundering and combating the financing of terrorism are increasingly present concerns in the several international legal systems.

 

In this regard, through the Anti-money Laundering and Combating the Financing of Terrorism Policy, OGMA has formalized a set of instructions intended to prevent, detect and combat any type of money laundering and financing of terrorism. This Policy applies across the Company to all our people and to all third parties we interact with (customers, suppliers, business partners, etc.), in every location where we operate. 

 

Most countries control export, re-export, re-transfer or other procedures on controlled and non-controlled items for reasons of national security, non-proliferation of weapons of mass destruction, anti-terrorism, protection of human rights and scarce natural resources, geopolitical stability or foreign policy interests.

 

As a global company, OGMA complies with all such procedures.

 

In order to ensure that all our people and all third parties we interact with (customers, suppliers, business partners, etc.), in every location where we operate, also know and comply with such procedures, we have developed our Export Control Policy. 

 

 

OGMA is committed to conducting business in accordance with the highest integrity, transparency and social responsibility standards. In this sense, the Helpline Policy establishes how all our people and all third parties we interact with must report to the Company, in a responsible and effective manner, any case, situation, occurrence and/or information that may represent misconduct or non-compliance with the applicable laws, OGMA Code of Ethics and Conduct, its Ethics & Compliance Program and related Directives and Procedures.

 

This Policy establishes the principle of non-retaliation and the appropriate protection for all the people who make reports in good faith.

OGMA conducts its business activity in a transparent, safe and responsible manner, free from conflict of interest and consistent with its Values.

 

The Conflict of Interest procedure establishes the guidelines for preventing situations where the private interests of a specified person or someone related to them may override the Company interests. In this regard, both our people (including the members of the Board of Directors) and the third parties we interact with are expected to report any situations of potential and/or actual conflict of interest that they identify, so that such situations can be assessed and the related risks mitigated.

 

Our employees and the Members of the Board of Directors are aware that they must report to the Compliance Department all circumstances related to a possible conflict of interest, including:

   - Personal investments or transactions with any OGMA supplier, competitor or customer;

   - Personal relationships of friends or relatives at OGMA;

   - Close personal relationship with a Government Official;

   - Business or other external interests that affect one’s objectivity, motivation or performance.

 

In addition to spontaneous reporting from our people, in some situations OGMA requires verification of conflict of interest, as follows:

   - Before hiring or issuing a job offer to a potential employee;

   - Prior to the appointment of the list of Members of the Board of Directors;

   - Before an employee is transferred between OGMA departments; and

   - Before promoting an employee.

 

Violations of this procedure involving an intentional failure by our employee to disclose a conflict of interest situation may result in disciplinary action under the terms of the applicable law and, in the case of Members of the Board of Directors, their possible dismissal by the General Meeting of Shareholders upon prior alignment with OGMA's Compliance Department and Embraer's Audit and Risk Committee (CARE).

OGMA recognizes and understands that there are social and professional customs and rules regarding the offering/receiving of hospitality and promotional gifts to individuals or entities outside OGMA, not only in Portugal, but also in other countries where OGMA operates.

 

For this reason, OGMA has established a set of procedures that define the conditions for offering/receiving hospitality and/or promotional gifts by OGMA and our people, within the scope of business relationships, explaining concepts, defining limits and frequency, as well as alerting to points of attention and giving practical examples.

 

In general, OGMA and our people may receive hospitality or promotional gifts when such courtesies:

   - Do not appear to be, or are not, intended to influence the recipient, i.e., they must not appear to be an exchange of favors (undue advantage);

   - Are not attributed to any person/entity, whether public or private, when any contract or regulatory decision by OGMA is pending with such person/entity;

   - Are not too expensive;

   - Are not offered very often;

   - Are not offered in cash or other means easily convertible into cash (such as gift cards or vouchers).

As part of its corporate and social responsibility, OGMA may donate products, services or financial resources to support scientific research, arts and culture, social, educational or sporting projects. All donations must comply with transparency requirements, with clear and objective purposes, without the expectation of return or consideration, and must be supported by complete and rigorous documentation, with appropriate accounting records maintained in accordance with the relevant laws and regulations.

 

Sponsorships are permitted when used to promote the brand, carry out advertising, create opportunities for OGMA to demonstrate or promote its products and services, or exercise its corporate responsibility.

 

We do not donate to political parties and we do not allow third parties to donate on behalf of OGMA.

 

Donations and sponsorships must never be used as a means of obtaining undue advantage, directly or indirectly, either for the Company or for any other person.

 

OGMA's donations and sponsorships must be provided in a transparent manner and achieve the legitimate objectives they are intended for. Therefore, the necessary guidelines and precautions must be observed, as described in OGMA donation and sponsorship policies and procedures.

 

OGMA holds and participates in events as part of its business and institutional strategies, where it maximizes the exposition of OGMA brand, promotes its products and services, establishes and strengthens relationships with stakeholders, and reinforces its institutional presence.

 

Since they are of great importance to OGMA's strategy, events must provide the best experience and contact with the brand, products and/or services for stakeholders. For this reason, all the elements that make up the event must be planned, analyzed and carried out with high levels of quality, ethics and integrity, as described in our Corporate Event Procedure.

 

OGMA conducts its business ethically and with absolute integrity in all its operations around the world.

 

In compliance with the commitments set out in our Code of Ethics and Conduct and all other OGMA Ethics & Compliance guidelines, we have established a set of due diligence procedures that must be observed by all our people and by all third parties we interact with (customers, suppliers, business partners, etc.), in every location where we operate. In what concerns suppliers, OGMA's Procurement Department must be involved, at all times, as it is ultimately responsible for overseeing the Company's supplier database.

 

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).

 

As a rule, such procedures correspond to the following practices:

- Collecting information from the third party necessary to assess its reputation and related risk;

- Risk classification (high, medium or low), according to OGMA Risk Matrix. OGMA recognizes the corruption risks associated with operating in different markets and has a risk assessment process in place to account for such specific risks, with clear risk management procedures. Risk assessment results have a direct impact on our business decisions and provide information on the development and implementation of additional controls;

- The greater the risk presented, the more frequent and detailed the due diligence procedure carried out by OGMA on the third party will be. For instance, depending on the risk, the effective beneficiary and corporate composition of the third party seeking to do business with OGMA will be verified, additional questionnaires and declarations will be required and the respective due diligence procedure will include a clear statement that the relationship between OGMA and the specified third party will be subject to review and possible termination if any red flags highlighted upon the due diligence process cannot be mitigated;

- Requirement that third parties, depending on the risk presented, have appropriate anticorruption policies and procedures, as well as policies and procedures for dealing with conflict of interest, gifts and hospitality and whistleblowing, in addition to the obligation to comply with OGMA Ethics & Compliance policies and procedures; etc.

 

Such procedures provide OGMA with important information about the potential third party we propose to do business with, so that we can not only comply with legal requirements, but above all, maintain ethics, transparency and integrity standards in all our business relationships.

 

In addition to the procedures above, the hiring of agency services or business representation is prohibited at OGMA, due to the high risk such services represent.