Ethics, compliance and transparency

GRI 102-17, GRI 205-1, GRI 205-2, 408-1, 409-1, 411-1, 412-2, 406-1

Ethics and transparency are unquestionable principles for the Company, which are highlighted in its Code of Ethics. It is a Guide of Conduct which states that it is the responibity of all to ensure that each workday is filled with respect, courtesy, and professionalism, in compliance with the law, prohibiting any form of abuse, harassment, corruption and discrimination, as well as prohibiting employees from performing activities that may constitute conflicts of interest. No employee, regardless of their position or under any circumstances, has the power to request or take action contrary to the regulations established in the document, nor to omit in this regard.

From the moment an employee joins the Company or whenever there is an update in the rules of conduct, employees must read and sign the terms, as well as participate in training in this regard. In 2018, after the revision on the Code of Ethics – Guide to Ethical Conduct, training was conducted for employees regarding the revision. The same procedure took place regarding updates to Minerva S.A. policies on; Securities Trading, Anti-corruption and anti-bribery practices and Prevention of Conflicts of Interests, the last two encompassing corporate employees, as well as supervisors, coordinators and managers in all business units.

Edison Ticle
Chief Financial Officer

The Company checks the registery from the department of the Ministry of Labor and Employment for employers who have imposed conditions similar to slavery, terminating the relationship with any such partner or supplier identified. Furthermore, all the contracts have terms reinforcing the commitment to eradicating slavery and child labor that may hinder the continuity of employment relationship in cases were non-compliance of these terms are identified.

Having particular concern towards Indigenous Lands, the Company frequently sends letters of notification to the regions belonging to the Fundação Nacional do Índio (Funai) in order to identify new reports of invasions in these lands. However, within the last year the Company has not been informed of any evidence of expansion into these rural areas. In order to identify the probability of encroachment into areas beyond the boundaries by farmers and ranchers as outlined on documents made available by Funai, the Company uses an analysis methodology by use of satellite, a procedure that in 2018, enabled the identification of a farmer who had infringe into indigenous land, therefore terminating negotiations.

The Company established Conexão Minerva, an ombudsman channel that listens to the internal and external public, ensuring anonymity and the privacy of information allowing for suggestions, praises and the reporting of possible violations to its rules of conduct or current legislation. The channel is available 24 hours per day, seven days a week, by internet, telephone, email and letters. The internal channel is for the exclusive use of the employees, they may still address their supervisors for assistance if needed; the external channel is open to the general public.

For the processing of cases received, there is an ombudsman who responds directly to the Ethics and Integrity Committee. The internal consequences may vary, depending on the severity and nature of the violation, from a simple warning up to termination or the termination of contracts with outside vendors, service providers, etc. Such measures do not substitute or exempt the offender of potential applicable legal action and related legal penalties.

The Company there is responsibility ethics and integrity to all the audiences of the relationship.