Responsible for Sustainability | Mônica Alcântara

Responsible for the publication | Guilherme Bourroul

GRI Consultancy and Editorial Coordination | usina82

Graphic design and web development | GIZ Propaganda

Photography | Eduardo Moody e acervo Odebrecht Agroindustrial

Ethics, Transparency and Integrity

Business Performance Commitment Towards Members


Since our foundation, based on the principles and concepts of Odebrecht Entrepreneurial Technology (TEO), we have developed our business with transparency and ethics in the relationship with all stakeholders in our value chain. This form of operation was reinforced and expanded in the last harvest, based on the Odebrecht Group’s Policy on Compliance, approved in November 2016.

Based on the guidance of the Controlling Shareholders, we have reviewed and approved our Compliance Policy, which is more stringent in aspects relevant to our Business. Our policy forbids, for instance, donations to political parties, even if Brazilian law allows this form of contribution.

In addition to the Policy, we created the Compliance Committee in 2016, which assists the Administration Board in the follow-up of the implementation of the Policy and related action plans. In its formation, the Committee counts on up to five Company’s advisers, and one of them is an independent member. Another requirement is that at least one of the Committee’s members has a recognized experience and knowledge in the areas of corporate accounting and accounting and financial auditing.

In our operational structure, we have strengthened the Compliance area, which responded to the Executive Board and started reporting directly to the Committee. In addition, the area will be invited to participate in the Administration Board meetings, to present its main indicators and results. Thereby, we maintain our commitment to be in line with the best practices in the market.

After structuring this governance, our objective is, in the 2017/2018 harvest, to consolidate the Company’s Compliance System and to act in the communication and training of all Members to disclose and consolidate the Compliance Policy among all the teams, demonstrating how the guidelines and aspects covered in the document are related to their daily routines.

The expansion of the Compliance area reinforces the commitment towards ethics and transparency that we have always maintained, and whose guidelines are also outlined in the Code of Ethical Conduct for Members and in the Code of Ethics for Suppliers, both available to all those interested in it, on the Company’s website.

Click here to get to know the Odebrecht Agroindustrial Compliance Policy.

In the 2016/2017 harvest, we strengthened our management with the creation of the Compliance Committee and the expansion of the Company’s Compliance area.

Compliance System

Our Compliance System is supported by three pillars – Prevent, Detect and Remedy – and ten integrated measures to guarantee our commitment to an ethical, fair and transparent action. It has been created and structured to support all Members, especially Leaders, in managing risks that can jeopardize the generation of value in our business.

Leaders are responsible for the implementation and practice of the Compliance System in their areas. Prevention measures are the most important ones to be implemented and followed.

Nevertheless, no matter how good they may be, they may be insufficient to ensure that the Company is not exposed to the risks of non-compliance.

Therefore, to ensure the effectiveness of the Compliance System, it is essential that detection and remediation measures are also taken. Once exposure to risk is detected, it should be treated. In the event of non-compliance, initiatives to remedy the impacts and strengthen preventive and detection measures should be adopted. Depending on the nature, appropriate disciplinary measures should also be taken.
Based on three pillars, our Compliance System is implemented by Leaders in their respective areas.

Risk Management

One of the main areas of activity in the Compliance area was the development of a methodology for identifying and classifying the different types of risks to which our business is exposed. In an integrated way with the administrative and operational areas, we will carry out a complete mapping of the processes and the prioritization of action plans to mitigate risks, according to the degree of exposure and to the Company’s financial and reputation impact.

Based on the risks identified and prioritized, we will define our audit plans for the crop year, focusing on loss prevention and productivity enhancement. Annually, the audits carried out are aimed at pointing out to Area Leaders whether the established procedures for risk mitigation are being satisfactorily met and in accordance with our principles and policies.

In the 2016/2017 harvest, we performed five audit plans covering items such as people management, product dispatch, vehicle supply, relationship with Agricultural Partners and validation of access to control and administrative systems. In this procedure, we involved 100% of the Productive Poles and defined action plans to be developed in the next crop year, contributing to the continuous improvement of our operations.

In our Units, we have developed an operational risk matrix that assists Leaders in assessing possible scenarios and their consequent social, environmental, asset and corporate image and reputation impacts. This tool reinforces decision-making on measures to be adopted, to prevent situations that may compromise the business continuity.
Ethics Line

Following the guidelines of our Compliance Policy, we have the Ethics Line to receive complaints of irregularities, misconduct and actions that are not in compliance with the legislation by our Members or other stakeholders in our value chain. The channel is always open, through the internet or telephone, for communications to be made and can be used by Members, Suppliers, Clients and other partners.

The Ethics Line is managed by an external and independent company, which increases the security and guarantee of information secrecy regarding the people that get in touch. Furthermore, through the online platform, it is possible to request additional information from the reported facts, even in the case of anonymous communications. Complainants may additionally monitor the development of verification and investigation through the protocol number generated by the system itself.

In the last year, we received 453 communications through the Ethics Line, an increase of 12.7% compared to the 2015/2016 harvest. Of this total, 290 were considered by the Company (19% less than in the previous period). We have noticed a reduction in reports related to moral harassment and internal policies, as a result of actions taken to improve the relationship between Leaders and Led and compliance with corporate guidelines. On the other hand, growth in communications categorized as abuse of power and those related to Health, Security and the Environment (HSE) indicate opportunities to enhance Leadership awareness.
Ethics Line – reports received by theme *Reports with requests for general information from the Odebrecht Group. A disclosure campaign will be implemented in 2017/2018 aiming at the best use of the channel.

Click here to access the Ethics Line

In the 2016/2017 harvest, we concluded the investigation into a fraud report involving illicit payments to a Supplier. The case was well founded and resulted in the dismissal of the Member and the bounce of the beneficiary company. G4-SO5

Voluntary Commitments

Membership and participation in external initiatives that contribute to the sustainable development of societies are important to reinforce our commitment to ethical, integrity and transparency. To this end, in 2016, we became part of the Brazilian network of the Global Compact, a UN initiative that mobilizes the global business community around 10 Principles that encourage respect for human rights, decent working conditions, protection of the environment and fight against corruption.

In our first year of operation, we sought to understand how our Business and investments for sustainable development are already aligned with the Global Compact guidelines, correlating the global vision with the local reality of the regions in which we operate. We participated in two working groups of the Brazilian network – Food & Agriculture and Energy & Climate -, forums in which we could share experiences with other business entities and strengthen our position as inducers of the reduction of greenhouse gas (GHG) emissions in the country. Adherence in the Global Pact and engagement in its working groups strengthen our contribution to sustainable development

Beginning with the 2017/2018 harvest, we will deepen the evaluation of the relationship between our practices and the commitments made under the Global Compact, guiding us through the 10 Principles to identify opportunities for improvement in our operation and governance. To this end, we will expand our participation to more thematic groups (Anticorruption, Human Rights and ODS) of the Brazilian network and will continue to disseminate and reinforce our commitment among Members and other stakeholders in the value chain.

Contributions to the 10 Global Pact Principles
Corporate Initiatives
By participating in business initiatives recognized by research and networking, we seek to transform the main trends in sustainability into practical opportunities for the development and growth of our business. In this sense, we highlight our participation in the Business for the Climate (EPC) platform, an initiative by GVCes – Center for Sustainability Studies by the Getulio Vargas Foundation, to mobilize the business community in terms of stimulating a low carbon economy.

By participating in this forum, we were able to capture and incorporate in our strategy the main challenges for measuring, regulating and valuing the environmental benefits of our business, especially those related to climate change. We also contributed to broadening the discussion of sector-specific issues to the theme in the dialogue between the private sector, academia and the public sector. We participate, for example, in the creation of the Agriculture working group within the Emissions Trading System Simulation, one of the activities of the EPC.

The first meeting of the group occurred in April 2017 and one of the points discussed was the deepening of the impact on the balance sheets of GHG emissions produced by companies brought about by issues such as changes in land use.

Over the past year, we have also become signatories to the “Corporate Positioning on Carbon Pricing in Brazil”, released by the Business Climate Initiative (IEC), which advocates carbon pricing as an efficient alternative to reduce GHG emissions and drive the adoption of more sustainable practices in the value chain. The IEC is a national multi-stakeholder movement that brings together institutions such as the Brazilian Business Council for Sustainable Development (CEBDS), EPC, Ethos Institute, Carbon Disclosure Project (CDP) and the Global Pact Brazilian network. Hydrous ethanol life cycle analysis stands out Through our participation in the Applied Life Cycle Initiative (Civia), by the GVCes, we conducted during the 2016/2017 harvest a study on the water footprint and hydrous ethanol carbon that we produce. The project was selected from more than 400 papers to be presented at the eighth edition of the International Conference on Life Cycle Management (LCM 2017) in September, in Luxembourg.

Entitled “Carbon and hydrocarbon footprint of hydrated ethanol from Brazilian sugarcane produced by Odebrecht Agroindustrial”, the study will be presented at the panel on sustainable practices in agricultural value chains in emerging countries. The study shows how we were able to incorporate open software as a tool for monitoring and developing improvements in our agricultural and industrial processes, considering the water and emissions aspects.