Entrepreneurial transformation

Since we undertook our commitment to Brazil and
decided to collaborate freely with the investigations under
Operation Car Wash in early 2016, we have evolved and fulfilled
our goals and actions to ensure that all of our Businesses
operate ethically, with integrity and transparency.

Our contribution to the Sustainable Development Goals

We embarked on an authentic journey to ensure integrity, ethics and transparency in our Businesses and undertook a commitment to combat corruption.

Our Commitment

The Commitment signed by our leaders,
in July 2016, expresses through ten principles
our conviction to operate ethically, with integrity
and transparency. It also demonstrates our strong market-oriented
positioning to conduct our business activities with a clear
determination to combat and not tolerate corruption.

 

01
Fight and show zero tolerance for corruption in all its forms, including extortion and bribery.
02
Say no firmly and determinedly to business opportunities that conflict with this commitment.
03
Adopt principles firmly grounded on ethics, integrity and transparency in relations with public and private agents.
04
Never rely on cultural or customary market conditions as a justification for illicit actions.
05
Ensure transparency in information about Odebrecht, which should be accurate, comprehensive and accessible and published on a regular basis.
06
Be aware that misconduct, whether by action or omission or disregard is harmful to society, breaks laws and destroys the image and reputation of the Odebrecht Group as a whole.
07
Ensure that Odebrecht practices the Compliance System throughout the Businesses’ value chain, always up to date with the best benchmarks.
08
Individually and collectively contribute to necessary changes in the markets and settings where misconduct may be induced.
09
Incorporate into Members’ Action Programs evaluations on performance concerning the Compliance System practice.
10
Have the conviction that this commitment will keep us on the path of Survival, Growth and Perpetuity.

Ethics Line

In 2017, an external independent company began receiving
and managing reports made via the Ethics Line channel
This change imparted greater reliability to the process
given the independence and better preparation of those
receiving the reports.
The Ethics Line channel, which operates 24/7
issues a case number that enables the
whistleblower to follow up on the report.

All reports received are forwarded
to the Chief Compliance Officers,
who conducts the investigations.

68

reports received at the holding company

11

cases investigated at the holding company

8

cases deemed unsubstantiated

How do I access the
Ethics Line channel?

The Ethics line can be accessed by anyone

Internet

www.linhadeeticaodebrecht.com

click here

Tel: 0800 377 8011

The channel is available 24/7. Service in Portuguese, English and Spanish.



Compliance
System

The Compliance System consists
of ten integrated measures to prevent,
detect and remedy non-compliance,
as defined in the Policy on Compliance with Ethics,
Integrity and Transparency.

These measures seek to control any risks of
non-compliance with legislation and of conflicts
with Our Commitment and with other internal
guidelines, in accordance with the
Compliance Policy.



PLEA
AGREEMENTS

The agreement signed with the Brazilian Federal Prosecution Office (MPF)
the United States Department of Justice (DoJ) and the
Swiss Office of the Attorney General stipulates
the payment of a fine of BRL$ 3.828 billion
as well as external monitoring to oversee
the evolution of our Compliance System and
the improvement of internal controls.
In 2017, we allocated a total of BRL$ 550 million to pay the fine.

Independent Monitoring

The agreements reached with Brazil’s Federal Prosecution Office (MPF), the U.S. Department of Justice (DoJ) and the Swiss Office of the Attorney General provides for the payment of financial penalties in the amount of BRL$3.828 billion and external monitorship to accompany the evolution in our Compliance System and the improvement in our internal controls. In 2017, we allocated BRL$550 million to the payment of financial penalties.

TIMELINE

The path we already have traveled

We have concluded our structural internal transformations and will continue to enhance our concepts and practices.
Click here to read about our journey