Compliance & Code of Conduct

Compliance Program

At Votorantim Cimentos, we are committed to customer success, empowered employees, sustainability and operational excellence. We also know that our success in these areas will only be achieved if we act ethically with integrity and transparency. That’s why our Values and Beliefs and Code of Conduct reinforce our companywide commitment to Compliance. We expect employees at all levels, from operational roles to our board of directors, and shareholders to follow the Code of Conduct guidelines and to comply with all laws, regulations and policies in the regions and countries where we operate. We are constantly searching for best practices, encouraging the fight against corruption and emphasizing the damages caused by corruption in political, economic and social domains.

At Votorantim Cimentos, we have a Global Anticorruption Policy that reinforces our position of zero tolerance towards corruption, bribery and facilitation payments. We prohibit the offer or receipt of any kind of advantages meant to secure an unfair business or personal gain, especially with regard to public officials or government authorities. This includes receiving and offering gifts, providing entertainment and hospitality, extending corporate invitations or any other act that is in conflict with local laws and regulations or is contrary to our own policies. Effective in 2017, Votorantim Cimentos also has in place a Global Donations and Sponsorship Policy that restricts and governs political donations. In all instances, employees of Votorantim are expected to respect and abide by the guidelines outlined in our Code of Conduct and all other policies mentioned.

Since 2013, we have maintained a Compliance Program, with communication and training campaigns aimed at all employees at all levels within the Company. We monitor the effectiveness of the program regularly, and take the necessary measures in the event of infractions, intentional or unintentional.

Ethics Line

We encourage the reporting of any suspected wrongdoing through our Ethics Line and we do not tolerate any form of retaliation against those who raise these concerns. Our Ethics Line – public and open to all, inside and outside of the organization — provides a way to report misconduct (real or perceived) in a confidential and anonymous manner. All reports are investigated and addressed in accordance with internal policies and current laws and regulations.

Our programs and policies are constantly evolving as we consolidate best practices and adapt to changes in our society, while preserving our enduring legacy of integrity, ethics and transparency.

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Compliance Program

• Strong commitment to the principles of ethics and transparency
• Highly committed to the best practices defined by the SEC and CVM (Brazilian equivalent to SEC)
• Structured compliance program, updated annually, and committed to initiatives that lead to transparent and responsible corporate behavior
• SOX compliant since 2010
• Compliance monitoring and evaluation, always focused on prevention
• Ethics and compliance training available to employees in all units on the company‘s global portal
• Ombudsman channel available to all employees and stakeholders