Ethics and Conduct

Since 2012, Estre Ambiental has been reinforcing its integrity tools. In 2015, the company created a department for Risk Management and Compliance. Since then, it has been working to strengthen the Estre Integrity Program and bring it in line with best practices and Brazil’s anticorruption law (No. 12.846/2013). The initiatives implemented and the proposals for the year 2017 are in line with the company strategy and a fundamental part of Estre Ambiental’s commitment to business ethics.

INTEGRITY PROGRAM


The Estre Integrity Program consists of five pillars:

COMMITMENT

The support of Estre’s top management is essential for the encouragement of an ethical culture and respect for the law, and for the effective application of the Integrity Program.

EXAMPLES:

– Compliance Day

– Corporate goal for completing the Integrity Program

– Subscription to Integrity Compacts (Ethos and UN)

– Ethics Committee

– Integrity Program supervised by the Board of Directors

RISK MANAGEMENT

Estre is familiar with its procedures and its organizational structure, identifies the area where it operates, its key business partners and, above all, its level of interaction with the public sector, in Brazil and abroad, and this allows us to assess fully the risks of corruption (Law No. 12846/2013).

EXAMPLES:

– Integrity Program control matrix

– Map of relations with Public Agents

– Profile report

– Corporate risks

MONITORING

The company has procedures to check the application of the Integrity Program and mechanisms to ensure that deficiencies found in any area be corrected and updated.

EXAMPLES:

– Due Diligence on suppliers, clients, sponsorship and donations, acquisitions, contracts and staff

– Monitoring of the media

– Independent assessment of the program

– Reporting Channel

RESPONSIBILITY

Estre has an autonomous, independent and impartial area with responsibility for these issues. It has all the necessary material, human and financial resources, and has direct access, in need, to the Board of Directors.

EXAMPLES:

– Risk Management and Compliance area

– Internal Audit

– Compliance policy

– Annual budget

RULES

Estre has anti-corruption policies and procedures. We have created detection mechanisms and reports of irregularities, and we impose disciplinary measures and take remedial measures in the case of violations.

EXAMPLES:

– Code of Ethics (click here for download)

– Policies: Anticorruption, Bidding processes, Sponsorship and Donations, Balance of Consequences and procedures to investigate reports, and Due Diligence

– Reporting Channel

– Training


Financial reports, shareholder structure, main clients and others informations must be requested to compliance@estre.com.br