Compliance system

We have adopted a Compliance System inspired by world best practices and respect for laws. The Compliance System consists of 3 pillars: Prevention, Detection and Remediation of risks and misconduct. These pillars unfold into 10 integrated measures for the promotion of an organizational culture that supports the Code of Conduct, our commitment to ethical, integrity and transparency.

Our Compliance System is an organic structure, with interdependence between the 10 measures. It works effectively when there is harmony between its pillars and when implemented in an integrated manner with our other policies.

In 2023, Novonor S.A. completed the second maintenance audit for its ISO 37001 Anti-Bribery Management Systems certification. The seal, awarded in 2021, attests to the excellence of its Anti-Bribery Management System, in compliance with the requirements of the standard, and is valid until June 2024.

Novonor S.A.'s Compliance System was designed and complies with the main national and international guidelines issued by Brazilian law, the US Department of Justice, the OECD, the World Bank, ISO Standard 37001 on Anti-Bribery Management Systems, among others, and has been evaluated and approved by many of these authorities and organizations. Novonor S.A.'s Compliance System policy serves as the basis for several of the Group's subsidiaries.

By conviction, we undertake the commitment to act in an ethical, integral and transparent way. This commitment, reinforced by our Compliance System, is essential for our survival, growth and perpetuity. 

The Code of Conduct brings together, in a clear and objective manner, a set of guidelines and presents the conduct expected from our members.

The Novonor Commitment presents the 10 principles undertaken by all of our members in the fight against and non toleration of corruption in any of its forms in the conduct of our Business and Investments.

These principles are aligned with Our Culture and should be practiced responsibly in all areas of work, without flexibility.

This is the Novonor Commitment:

• To fight and not to tolerate corruption in any of its forms, including extortion and bribery.
• To say no, with firmness and determination, to business opportunities that conflict with this Commitment.
• To adopt ethical, integrity and transparent principles in the relationship with public and private agents.
• Not to invoke cultural or usual market conditions as justification for undue actions.
• To ensure transparency in information about Novonor, which should be accurate, comprehensive and accessible and regularly disclosed.
• To be aware that deviations of conduct, whether by action, omission or complacency, hurt society, hurt the laws and destroy the image and reputation of all Novonor.
• To guarantee at Novonor and throughout the Business value chain the practice of the Compliance System, always updated with the best references.
• To contribute individually and collectively to necessary changes in markets and environments where there may be induction to conduct deviation.
• To incorporate in the Action Programs of the members performance evaluation in compliance with the Compliance System.
• To be convinced that this Commitment will keep us on the path of Survival, Growth and Perpetuity.

The Ethics Line Channel is an exclusive and confidential tool for safe and, if desired, anonymous communication of conduct that violates the Novonor Commitment, our Code of Conduct and/or any policy, guideline, internal regulations and current laws. The information is received by an independent and specialized company, ensuring absolute secrecy and no retaliation from the whistleblower.

Click here to access the channel.

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