The Company also maintains a Global Policy for the Prevention of Conflicts of Interest whose guidelines are distributed to the employees of the corporate offices, coordinators, supervisors and all employees with administrative positions through the use of an online platform developed in the Fluig system. The Company adopts the premise that it is the duty of every employee to abstain from participating in any negotiations, hiring, approvals or management of third parties in situations that constitute or may constitute a conflict of interest. 102-25
Furthermore, it does not tolerate any act related to bribery or corruption and rejects any initiative connected to any process to hide or legitimize illicit financial resources. The guideline is expressed in the Code of Ethics – Guide to Conduct and the Global Anti-Bribery and Anti-Corruption Policy.
The internal control system consists of the mapping of processes and risks inherent to operational activities and the management of third-party risks. The phases of the compliance processes are related to the identification of risks, definition of requirements, structuring of evaluation, implementation of processes and controls, generating evidence, adjustments and retesting.
The organizational structure includes several support areas responsible for improving internal controls, advising and strengthening decisions and the activities related to internal risk management. The Ethics and Integrity Committee, the Executive and Risk Committee discuss decisions and measures that will be adopted. The Compliance area is responsible for preparing, disclosing and updating procedures that establish guidelines about the subject and regular compliance with administrative processes.
The Internal Audit unit is responsible for checking internal controls and their effectiveness. The Legal area is responsible for the agreement of contractual processes, establishing specific anti-corruption clauses in commercial contracts and their legal applicability. Finally, the areas of Sustainability and Integrated Management System (IMS) are responsible for the Food Safety, Social Responsibility, Occupational Health and Safety and Environmental chain.