CATEGORIA

SPIC Brasil’s Ethics Channel

April 21, 2021

SPIC Brasil’s Integrity Program aims to combat fraud, corruption and any conduct that is not in accordance with what is established in our Code of Conduct and Ethics. It is an important tool for detecting and remediating irregularities. However, to trigger it, it is first necessary to understand the difference between error and fraud.

Error
It is an unintentional act of omission, inattention, ignorance or misinterpretation of facts in the preparation of records and documents, transmission of information or conducting processes.

Examples:
• Incorrect accounting records
• Receipt or release of materials without checking all relevant documentation
• Divergence in the procedure for performing a task

Fraud
It is an intentional act of omission, manipulation or tampering with records, documents, results, processes, etc.

Examples:
• Adulteration of financial statements to obtain benefits for the corporation
• Lower declaration of the amount of materials that were received, to take advantage of the withheld items
• Forge achievement of goals

Therefore, it is worth clarifying that errors are not cases of denunciation, but of dealing, together with the managers of the area where the failure occurred. However, when the fraudulent intent in the act is perceived – whether for undue gains by the company or the individual – these cases must be reported in the Ethics Channel, so that the facts are properly investigated and the appropriate disciplinary measures are applied.

In addition to situations of fraud, corruption and bribery, the Ethics Channel can also be activated in cases of violations of legislation, non-compliance with internal regulations, damage to the environment and behavioral deviations, such as: discrimination, moral harassment and sexual harassment.

For the investigation to be carried out properly, it is necessary that the report provides as much information as possible about what happened, and may even attach evidence, if available and if desired. Thus, we list questions that must be considered when reporting:

• What happened?
• Where?
• When?
• Who are involved?
• How did the irregularity occur?
• If there are amounts involved, what is the amount?
• What was the reason for the irregularity to happen?

We also emphasize that, if the report does not have the minimum elements for starting the investigation, the investigation team will request more information through the protocol opened in the Ethics Channel.

Therefore, it is important that the complainant keeps the records of the protocol and that he regularly consults the complaint, not only to provide further clarification on what is considered pending, but also to monitor the progress of the investigation.

Remember that reports can be made anonymously or identified. In both situations, the investigation will occur confidentially and will be conducted impartially, as we value the well-being of all our employees, our own and third parties, and for the non-retaliation of those involved.

We encourage the reporting of identified irregularities and suspected violations so that we can not only continuously improve internal processes, but also collaborate with the construction and maintenance of a healthy work environment for all.

E-mail:
spicbrasil@linhaetica.com.br

Website:
www.linhaetica.com.br/etica/SPICBrasil

Phone:
0800 713 0109 (available Monday through Friday, 8:00am to 8:00pm)

P.O.BOX:
79518

 

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