Avibras Indústria Aeroespacial S.A.

Based on public information, there is evidence that the company has published a statement from the President, supporting its ethics and anti-corruption agenda. The statement is on the company website and highlights the importance of integrity, transparency and compliance. The company therefore scores 1. To score higher the company would need to have published at least two more strong statements from the CEO in the last two years, which promote its ethics and anti-corruption agenda. Alternatively, the company would need to have published one strong statement from the CEO in the last two years, which specifically supports the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the company’s President demonstrates a strong, personal, external facing commitment, to the ethics and anti-corruption agenda of the company. TI notes the statement from the President introducing the new Code of Conduct in the July/August 2014 edition of the company magazine, but is looking for an external facing commitment rather than publication of internal facing actions.

Based on public information, there is some evidence that the company’s President demonstrates a strong, personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. TI notes that the company President introduced the new Code of Conduct to employees in the July/August 2014 edition of the company magazine Nossa Gente. The company therefore scores 1. To score higher the company would need to demonstrate at least two further examples of the internal-facing commitment of the President.

Based on public information, there is some evidence that the company publishes a statement of values representing high standards of ethical business conduct, specifically integrity. This value is briefly described in other parts of the company’s website, as well as the transparency values. The company therefore scores 1. To score higher the company would need to provide evidence that this value is explained in more detail, particularly in regard to its translation into company policies, along with other such values.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives, which promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is evidence that the company has appointed a Board committee, with overall corporate responsibility for its ethics and anti-corruption agenda. TI notes that the Ethics and Conduct Committee performs this function and is supported by the Board of Directors.

Based on public information, there is no readily available evidence that the company has appointed a person at senior level within the company, to have responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is some evidence of regular Board level monitoring and review of the company’s ethics and anti-corruption agenda. The audit area is responsible for monitoring systems and processes, including regular reviews of compliance activities. The President has responsibility for the audit area and monitors the company’s procedures. The company therefore scores 1. To score higher the company would need to provide evidence of a periodic, heavyweight review of its entire ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence of a formal, clear, written plan on which the review of the ethics and anti-corruption agenda by the Board is based, or of implemented improvement plans. The audit area is responsible for monitoring systems and processes, including regular reviews of compliance activities. The President has responsibility for the audit area and monitors the company’s procedures. However, there is no evidence of the basis of this review process or the implementation of improvement plans.

Based on public information, there is no readily available evidence that the company has a formal process to review and update company policies and practices, in the event of an actual or alleged instance of corruption.

Based on public information, there is some evidence that the company has an anti-corruption risk assessment procedure implemented enterprise-wide. The company states that the audit area has responsibility for risk management, including conflicts of interest, corruption and/or unlawful acts. However, there is insufficient evidence to determine the risk management format and process. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. The company states that the audit area has responsibility for risk management that may generate conflicts of interest, corruption and/or unlawful acts. However, evidence does not suggest that this risk management process includes the assessment of proposed business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents, with respect to countering corruption.

Based on public information, there is some evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption. The company has the right to terminate a business relationship with a supplier, but it remains unclear if this includes termination due to bribery or corruption allegations. The company therefore scores 1.

Based on public information, there is insufficient evidence that the company explicitly addresses the corruption risks associated with offset contracting. The Code of Conduct states that all offset requirements are evaluated technically and economically, avoiding any form of favouritism. However, to score higher the company would need to provide evidence that offset contracting corruption risks are explicitly addressed in the company’s offset policies, procedures and contractual terms.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk, when selecting or reappointing its offset partners and offset brokers.

Based on public information, there is some evidence that the company has an anti-corruption policy that prohibits the giving and receiving of improper gifts. The company therefore scores 1. To score higher the company would need to provide evidence of the explicit prohibition of other forms of corruption, such as facilitation payments.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is evidence that the company's Code of Conduct is easily accessible to Board members, employees and third parties. The Code of Conduct is provided to all new employees and is available on the company’s website in Portuguese, Spanish and English.

Based on public information, there is evidence that the company’s Code of Conduct is easily understandable and clear to Board members, employees and third parties.

Based on public information, there is evidence that the Code of Conduct applies to all employees, including members of the Executive Board.

Based on public information, there is readily available evidence that the company has a policy on potential conflicts of interests. The policy includes a definition of conflicts of interest and examples of scenarios.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy states that employees may give and receive gifts if they are not aimed at obtaining benefits in any negotiations, and cash gifts are always prohibited. The company therefore scores 1. To score higher the company would need to provide evidence of upper limits for gift exchange, and/or the requirement for senior management authorisation if a value threshold is exceeded.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy states that events hosted by external individuals can only be accepted when there is a real business opportunity and only with the authorisation of the leadership. However, professional oriented events such as business lunches do not require senior authorisation. The company therefore scores 1. To score higher the company would need to provide evidence of upper limits for gift exchange, and/or the requirement for senior management authorisation if a value threshold is exceeded.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is evidence that the company prohibits political contributions.

Based on public information, there is no readily available evidence that the company has a clear policy on lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance, to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. The Code of Conduct is insufficient as it contains a minimal number of example scenarios.

Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is evidence that the company provides anti-corruption training to all employees.

Based on public information, there is some evidence that the company provides targeted ethics training to Board members. The company states that ‘Board members receive specific training on Ethics and Conduct’; however, the scope of the training and the frequency remains unclear. The company therefore scores 1.

Based on public information, there is some evidence that the company provides training to employees in sensitive positions. The company therefore scores 1. To score higher the company would need to provide further evidence that ethics and anti-corruption training is tailored for employees facing different levels of risk.

Based on public information, there is no readily available evidence that the company has a clear and formal process, by which employees declare conflicts of interest. Employees can contact the Ombudsman regarding non-ethical behaviour and non-compliance with the Code of Conduct. However, the company does not explicitly state that conflicts of interest should be declared to the Ombudsman.

Based on public information, there is evidence that the company has a policy to apply disciplinary procedures, to employees and Board members who have violated the Code of Ethics.

Based on public information, there is evidence that the company has an ombudsman and a helpline department, for employees to report concerns or instances of suspected corrupt activity. Employees can contact the ombudsman by phone, email or post. The company therefore scores 1. To score higher the company would need to provide evidence of an independently operated channel and allow anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to the ombudsman and the helpline department. Employees can contact the ombudsman by phone, email or post.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms, to assure itself that whistleblowing is not deterred and that whistleblowers are treated supportively. The company states on its website and in its Code of Conduct that retaliation is prohibited. However, evidence does not show any further mechanisms or efforts to encourage and support whistleblowers.

Based on public information, there is evidence that the company instructs employees, to seek help and advice on corruption-related issues from the ombudsman.

Based on public information, there is evidence that the company has a non-retaliation policy for bona fide reporting of corruption, and that disciplinary measures are applied to employees who breach this policy.