Code. of Conduct for Suppliers

Transcription

1 Code of Conduct for Suppliers

2 Code of Conduct for Odebrecht Oil & Gas Suppliers 1 INTRODUCTION The operation in domestic and foreign markets and in different business units, geographical regions and cultural environments requires transparent standards and the compliance with different legislations. Odebrecht Oil & Gas ( Odebrecht Oil & Gas ) values its reputation and credibility, and the ethical principles guiding its operations contribute to maintain its image of a solid and trustworthy company before its Suppliers, Clients, Shareholders, Team Members, Employees and the society as a whole. Odebrecht Oil & Gas understands that it shall share its values and principles, and guide its Suppliers with respect to the main guidelines governing its relations, in order to comply with the best corporate governance practices, ethic and transparency requirements. 2 GUIDELINES All Odebrecht Oil & Gas Suppliers must conduct its business according to the guidelines of this Code. This Code of Conduct aims to clearly transmit the values and conducts expected from each of Odebrecht Oil & Gas Suppliers. 2.1 BUSINESS INTEGRITY Suppliers must, while conducting their business, adopt a honest and worthy conduct, strictly complying with the applicable laws, respecting the human rights, the environment and society s ethical standards. Suppliers must comply with all applicable laws and regulations in each Country or region where they operate during its corporate actions, with due observance of the highest honesty and integrity standards, avoiding any situations which might seem suspicious. This responsibility also involves the adoption of applicable measures, when becoming aware of irregularities by third parties which might jeopardize the name or interests of Odebrecht Oil & Gas. Suppliers must also watch over the selection of commercial partners, which have to perform their business in accordance with the legislation in force, particularly Brazilian Law No /2013 ( Anti-corruption Act ). Suppliers shall also conduct a procedure to verify the practices of their commercial partners before the decision of maintaining commercial relations with them, in order to identify any misconducts or risks of misconducts with respect to the principles and values of this Code. Suppliers are responsible for the losses arising from acts and omissions by their commercial partners which affect or might affect Odebrecht Oil & Gas. All matters related to Odebrecht Oil & Gas must be treated by its suppliers with secrecy, confidentiality and protection of intellectual property rights. The access to Odebrecht Oil & Gas information shall be limited to those people who need to receive such information, and its use shall be limited to the specific purpose of the provision of services or supply of goods. 1

3 2.2 CORRUPTION Odebrecht Oil & Gas does not tolerate the practice of any act related to corruption. The company values the meritocracy and fair competition in the markets. The same behavior is expected from its Suppliers. The Suppliers are prohibited from performing any of the harmful acts provided in the Anti-corruption Act. They are prevented from promising, offering or giving, directly or indirectly, improper benefits to a public, private or voluntary agent, or a third-party related to them, in order to influence any act or decision for its own or Odebrecht Oil & Gas interests. 2.3 ACCOUNTING RECORDS Odebrecht Oil & Gas values the reliability and transparency of its accounting records. Suppliers must adopt a similar conduct. The suppliers must strictly comply with the legislation, rules and generally acceptable accounting principles for the preparation and maintenance of accounting records. The accounting books and records must be prepared in a detailed and accurate manner, always based on reliable documents aiming to create solid reports which enable a proper assessment of the Suppliers operations. 2.4 RELATIONS UNDER THE AGREEMENT Odebrecht Oil & Gas expects cordiality, trustworthiness, respect and a dignified and honest conduct in the relations between its and Supplier s team members, regardless of any hierarchical position, job title or function. These conducts must also be expected within the relations between the members of the suppliers in their workplace Harassment No worker may be subject to physical punishment, abuse or harassment of any kind. No threats or harassments of any kind, particularly sexual or moral harassments will be tolerated under the agreement with the Supplier Discrimination Odebrecht Oil & Gas Suppliers shall not practice any prejudiced or discriminatory act against people, whether related to race, color, sex, ethnicity, social classes, age, physical characteristics, citizenship, religion, physical disability, marital status, sexual preference, union association, political party affiliation or beliefs Labor Practices Odebrecht Oil & Gas respects and promotes human rights in its activities and its business and work relationships. The company only permits the establishment of commercial relationships with suppliers who respect human rights and comply with the labor legislation, as well as the principles and values listed below. (A) Use of Forced and/or Child Labor, Sexual Exploitation of Children and Adolescents and Human Trafficking Odebrecht Oil & Gas Suppliers shall not tolerate, allow or agree with the use of forced and/or child labor, sexual exploitation of children and adolescents and human trafficking in any process related to their activities. Odebrecht Oil & Gas will not establish or maintain business relationships with Suppliers using irregular and/or illegal child and adolescent labor, who expose their employees to conditions which are degrading or similar to slave labor, or who agree with sexual exploitation of children and adolescents or human trafficking. 2

4 (B) Working Conditions Odebrecht Oil & Gas Suppliers shall offer decent working conditions to its team members with respect to work load, health and safety always complying with labor legislation of the country they are operating. Odebrecht Oil & Gas Suppliers must compensate their team members in a fair and decent manner, based on objective evaluation criteria, providing all benefits established by law. (C) Political Activities and Free Association Odebrecht Oil & Gas is a nonpartisan institution and respects the individual right of its Team Members and third parties with respect to political and union engagement. Therefore, its Suppliers must acknowledge and respect the freedom of association of its own team members. (D) Compliance with the Labor Legislation Odebrecht Oil & Gas requires that its Suppliers strictly comply with the labor legislation of the places where they perform their business activities and the collective bargaining agreements in force, and this shall not imply the establishment of any relationship with Odebrecht Oil & Gas. 2.5 ENVIRONMENT, HEALTH AND SAFETY The due care with environment, health and safety will always be of the essence. Suppliers must contribute to the ecologically sustainable development, continuously seeking to reduce the environmental impact of their inputs, operations, products and services. Suppliers must also ensure the safety of their team members and the compliance with the occupational health and safety rules applicable to their activities, including safety practices indicated by Odebrecht Oil & Gas. 2.6 INTERNAL COMMUNICATION Odebrecht Oil & Gas Suppliers shall disclose the existence of this Code and its provisions, disseminating the values contained herein to their own officers, members, shareholders, team members and respective suppliers and/or partners, making sure that the ethical principles mentioned herein are actually performed by all the company and throughout its value chain. Suppliers shall also hold periodical trainings of their team members in order to assure the understanding and compliance with the ethical principles and values of this Code. 2.7 MONITORING AND ASSESSMENT Odebrecht Oil & Gas follows the development and performance of its Suppliers with respect to the compliance with the agreement and the principles provided in this Code. This assessment aims to support the enhancement of the management and strengthen the business relationship. Therefore, Supplier must cooperate with Odebrecht Oil & Gas during the assessment provided in this item, providing information and facilitating the visits to its establishments at pre-established times and dates, whenever requested. 3

5 2.8 BREACH AND ITS CONSEQUENCES All Odebrecht Oil & Gas Suppliers must comply with the guidelines of this Code. Odebrecht Oil & Gas reserves the right to take the measures deemed necessary when Suppliers breaches any aspect of this Code. If Supplier, by its representatives or any of its team members, suspects or becomes aware of any breach of this Code, on the account of any person, it shall inform such fact to Odebrecht Oil & Gas Team Member in charge of the management of its agreement or via Odebrecht Oil & Gas Ethics Line. Ethics Line is Odebrecht Oil & Gas Compliance System s internal communication mean. Through this line, Odebrecht Oil & Gas Team Members, its suppliers or any individual may report facts or events where there is any actual or indications of noncompliance with the laws and other aspects provided in this Code. Ethics Line ensures the anonymity of this Code of Conduct violation report may be available: By free phone call, No ; On the Internet, at Odebrecht Oil & Gas website - by clicking in the Ethics Line icon at the home page. All reports will be analyzed, treated as confidential and with independence, thus ensuring the anonymity of communication and safety during the assessment of said reports. No retaliation against a Supplier reporting in good faith concern regarding an unlawful conduct or a conduct which does not comply with the provisions of this Code of Conduct will be allowed nor tolerated. If any event of breach of this Code is identified and duly confirmed, Odebrecht Oil & Gas may adopt the applicable measures to mitigate the damages and losses, such as: warning, cooperation with competent authorities in the investigations on illegal acts performed, seek compensation for damages, suspension/termination of the affected agreements, request of replacement of any persons involved in such violation and insertion of this fact in Odebrecht Oil & Gas internal records for future references. 4