This is the OCRIM Group’s Code of Ethics and Conduct. It defines the principles that should guide the conduct of the company and all its employees towards customers, consumers, suppliers and other stakeholders.
Legality, transparency and professionalism are affirmatives that guide the conduct of the OCRIM Group’s activities, essential for carrying out work proficiently. This Code of Ethics and Conduct constitutes the basis for actions that formalize the ethical conduct required in internal and external relations.
1. POLICIES AND PRACTICES
1.1 To preserve the environment is to take care of the future
For OCRIM, the commitment to environmental preservation is renewed every day starting with practices committed to waste reduction, conservation and the preservation of water resources and green areas.
Such attitudes also reinforce the company’s commitment to the new generations, demonstrating the pursuit of sustainable development that constitutes an innovative business management.
All this, with a common goal: to help build an even better future for Brazilians and for the world.
Responsibility of our employees to the environment
The OCRIM Group works continuously to make all its employees aware of sustainable attitudes inside and outside the company. All employees are guided by and must be committed to the following practices:
A. Rationalization of the use of production inputs, reducing the volume of waste generated, as well as the consumption of water and energy;
B. Correct destination of discarded materials;
C. Selective recycling of waste, used oil, batteries and electronic equipment, with an appropriate place for disposal of these residues, both by the company and the local community.
1.2 Supporting the community is making a better society today
Concern for people is part of the mission and commitments of the OCRIM Group, involving itself in issues related to social, cultural, environmental responsibility and enhancing the value of human beings.
Such attitudes reinforce each of OCRIM Group’s commitments as a fundamental part of a traditionally innovative business management.
The employees of the OCRIM Group are also made conscious of taking part in voluntary activities and must also be aware of their responsibilities towards the community.
Responsibility of employees towards social actions
Every employee, when representing the OCRIM Group before the members of a community, must act in accordance with the principles specified in this Code, without prejudice of any kind.
1.3 To care for the institutional image is to protect our history
The institutional image of the OCRIM Group and what it represents for customers, suppliers and the community is a very important asset for the company. Therefore, we are all responsible for the preservation and continuous improvement of the image and credibility constructed throughout the company’s history.
Our relationship with the press must be guided strictly by the reliability of the information transmitted and have as its goal the disclosure of relevant facts and the promotion of the Ocrim Group in a truthful, clear and direct manner.
Marketing and publicity actions are fundamental for public awareness and for the preservation of the OCRIM Group’s image of respectability and trust with different audiences. They must express their principles and the integrity of their policies and practices, which are essential to earn and preserve the loyalty of our employees, customers, consumers and other stakeholders.
The need for transparency and veracity in all communications of the Ocrim Group is essential. In addition to our products, ideas, strategies and other types of commercial and industrial information are produced, which are valuable but are not public, which the company owns and protects under the law, as it does with other types of assets. Therefore, all employees, suppliers and customers must care for this information.
Responsibilities of Employees with the Institutional Image:
A. Care for the image of the OCRIM Group, inside and outside the work environment, being aligned with the company’s values, acting ethically and free of prejudice;
B. Not to make statements or give interviews on behalf of the OCRIM Group if not expressly authorized and prepared to do so;
C. Ensure that the records and documentation that support the activities of the OCRIM Group always contain correct, safe, accurate and up-to-date information;
D. Ensure the safekeeping and secrecy of confidential information related to the company.
E. Not to discuss confidential information in public areas, public transport or transfers, as well as on social networks, personal and/or corporate blogs, or other means of communication that may create the risk of unwanted exposure of information.
F. Care for the image of the OCRIM Group on social networks. Posts of a biased, discriminatory and offensive nature are not in line with the company’s values.
2. RELATIONSHIP
Ethics, respect and credibility.
Three words that represent our relationship with everyone: employees, customers, consumers, suppliers and competitors.
2.1 Employees: To value is to grow together
The OCRIM Group values its employees through participatory management, creating opportunities for personal and professional development (as is the case with internal recruitment, based on criteria of dedication and individual merit), training, recognition of good performance, remuneration and benefits.
The company permanently invests in safe, ergonomic and healthy work environments for a respectful internal relationship, whose preservation is up to the conduct of all employees.
Relations between employees and the company are guided by ethics, respect and credibility. The OCRIM Group values diversity among employees in the work environment and condemns any practice of discrimination or harassment of any nature. In addition, it considers everyone equal, with the same responsibilities and rights. The company also constantly emphasizes common sense and good judgment in decision making.
The OCRIM Group respects labor legislation, not making use of illegal, informal, child or slave work. The OCRIM Group recognizes the legitimacy of unions, respecting their initiatives and practices, being always willing to dialogue in any situation, seeking solutions that will serve all those involved, as well as respecting the freedom of its employees to opt for union association.
Employees’ responsibility:
A. To be alert to situations that constitute a conflict of interest, real or potential, and that may interfere with the ability to remain unconstrained and make impartial decisions in relation to the OCRIM Group;
B. Not to use their position, access to privileged information or the company’s name, inside and outside the work environment, to obtain personal benefits or advantages of any nature for themselves or for third parties;
C. Not to carry out activities in parallel, paid or not, that are in competition with or incompatible with the OCRIM Group’s business or that cause physical or emotional exhaustion that impairs their conduct or professional performance;
D. To respect other employees, avoiding any prejudiced, aggressive behavior or that could make any employee feel attacked, humiliated, intimidated, discriminated against, harassed or excluded;
E. Not to adopt behaviors that may jeopardize their own health and safety and that of other employees, such as smoking in inappropriate places (observing signposted places) or consuming alcoholic beverages or drugs or carrying weapons in the work environment, or presenting oneself to work intoxicated or under the influence of drugs;
F. To ensure the proper use and conservation of the company’s assets placed under their custody so that there are no losses, damages and/or waste and not to use the facilities, assets (such as equipment) of the OCRIM Group, for private, illicit and unethical ends;
G. Use available electronic communication resources solely and exclusively for professional purposes, within legal requirements, and according to the ethical principles of this Code, not transmitting defamatory comments, messages or documents containing language, images or files that are offensive or induce any kind of discrimination – as well as not installing any type of program or file that violates the company’s or third parties’ intellectual property on OCRIM Group’s equipment;
H. To keep up to date with legal and regulatory standards and instructions regarding the performance and safety of their activities and with regard to the important rules set out in the manuals made available to Employees;
I. To ensure the safekeeping of the confidential information of the OCRIM Group internally and externally;
J. The OCRIM Group repudiates any form of corruption. Be aware of situations that characterize this kind of behavior. The practice of these acts is subject to disciplinary measures and sanctions in accordance with current legislation;
K. To denounce, via available channels (which maintain the confidentiality of the information and of the employee’s identity), any practices contrary to those contained in this Code of Ethics.
2.2 Customers and consumers: to offer quality is to demonstrate attention
Customers and consumers motivate the OCRIM Group to be in constant development, a true inspiration, translated into innovative processes through high technology to produce safe, quality and sustainable food. It is for these people that the company works daily. Therefore, they are our most important business partners.
The company wants to constantly increase its credibility with customers and consumers, offering products with safety and quality, demonstrating its responsibility to the environment and people, the basis of its practices for the sustainable development of its business.
Responsibility of employees towards Customers and Consumers:
A. To treat customers and consumers with respect, cordiality, attention, effectiveness, proactivity and agility in meeting their needs and, above all, with ethics;
B. To serve customers and consumers impartially and free from prejudice of any nature, strictly obeying the laws, as well as the regulations established by the Consumer Defense Code and the Brazilian Commercial Code;
C. To look out for the interests of customers and consumers, helping to solve problems and forwarding their requests and complaints to the responsible areas in the company, efficiently and quickly, responding to them whenever necessary;
D. Fulfill what we promise within the agreed time frame;
E. Protect the confidentiality of secret information forwarded to them by customers and consumers;
F. Disclose information about our products and services and socio-environmental actions in a clear and truthful manner;
G. Maintain the established and desired standard for the products, for it is our guarantee certificate of quality, sustainability and innovation;
H. Be open to criticism and contributions in the permanent search for the improvement in quality and efficiency of our products and services;
I. Disseminate the practices of the OCRIM Group, serving as a reference and engagement.
2.3 Suppliers: aligning principles is the best way to work
The OCRIM Group values ethical practices in the selection, negotiation and administration of all commercial activities, treating all suppliers with respect, without privileges or discrimination of any nature, regardless of the volume of business that each one maintains with the company.
Suppliers to the OCRIM Group must be aboveboard in the production, delivery and practice of signed contracts, maintaining the confidentiality of information in an ethical manner and complying with the commercial conditions established by law.
Awareness of good practices, valuing sustainability issues, must be constantly sought and will be especially observed.
The choice and contracting of suppliers must always be based on technical, professional and ethical criteria, in line with the guidelines of this Code, and conducted through a pre-determined objective process, such as competition or price quotation, which assures the best cost benefit ratio.
The choice and contracting of suppliers must always be based on technical, professional and ethical criteria, in line with the guidelines of this Code, and conducted through a pre-determined objective process, such as competition or price quotation, which assures the best cost benefit ratio.
Responsibility of employees towards suppliers:
All OCRIM Group employees must follow the following practices in hiring and in the relationship with our suppliers.
A. Ensure that all suppliers respect labor legislation, do not use child or slave labor and care for the health and safety of their workers;
B. Make sure that all suppliers respect environmental legislation and adopt compatible attitudes with respect to the environment and its preservation;
C. Ensure that all suppliers act in accordance with the principles expressed in this document, in the Purchasing Policy and in accordance with the rules applicable to their activities;
D. Establish relationships free of favoritism;
E. Maintain the confidentiality of the supplier’s data and ensure that the supplier maintains confidentiality regarding OCRIM Group’s information;
F. Not request and/or accept any kind of gifts, benefits or advantages of any type and nature from suppliers, such as, for example, gifts of any value, financial compensation, merchandise, leisure trips, tickets or any other services offered. If it is not possible to refuse, the same must be informed in accordance with the OCRIM Policy on Gifts, Favors, Hospitality and Courtesies, registered and forwarded to the Ethics and Conduct Committee, which will be responsible for the treatment on a case-by-case basis, always in accordance with this Code;
G. Represent the company, signing contracts and other documents only when such attribution is granted and/or has legal powers to represent the company.
2.4 Competitors: to respect is to work ethically
The competitiveness of the OCRIM Group will be exercised based on our capacity and the ethical management of our company, always guided by the company’s values of conduct and respect.
All market and competitor information, legitimate and necessary for the business, must be obtained through transparent and reputable practices, and its obtainment by illegal means will not be tolerated.
2.5 Respecting public authority means working seriously
The OCRIM Group respects the laws and is interested in contributing to the country’s social and economic development, respecting good governance practices.
All operations and business carried out by the OCRIM Group are, and must remain, supported by the respective documentation, being the object of immediate accounting entry in the company’s official books and records, in strict compliance with norms and accounting principles.
Representatives of public agencies, duly identified by credentials, receive professional treatment, making pertinent information, data and records required by law available to them, whenever requested.
The OCRIM Group does not offer or promise, directly or through third parties, payments, gifts or benefits to public agents, political parties or their members and candidates for political office, as well as their relatives or the equivalent, in order to obtain benefits for the company.
Responsibility of employees vis-à-vis Public Authorities:
A. Keep up to date with legal and regulatory norms and other instructions relevant to the performance of its activities;
B. Maintain a good relationship with the government agencies with which it relates in terms of activities, being cooperative under the terms of current and transparent legislation, in order to combat corruption, favoring and obtaining illegal advantages and against the principles of this code and always defending the company’s legitimate interests;
C. Represent the company before the Public Authority only when such attribution is granted, always respecting the documents of incorporation and representation of the company.
D. Refrain from practices that violate the laws, rules or regulations in effect in the country, as well as those that go against the principles of conduct expressed in this Code.
3. ADMINISTRATION AND APPLICATION OF THE CODE OF CONDUCT AND ETHICS
3.1 Compliance with the Code’s principles
All OCRIM Group employees must respect and comply with the terms contained in this Code of Ethics and Conduct, as well as be responsible for its application in all their professional relationships and those with any other public groups or entities.
3.2 Violation of the Code
Any person who is aware of any conduct or activities contrary to the principles established herein must report the fact to their immediate superior or submit a complaint to the Ethics and Conduct Committee. All information and/or complaints received by the Committee will be treated as confidential, and the identity of the informant will be preserved.
Violation of any conduct or practice contained in this Code will be penalized upon evaluation by the Ethics and Conduct Committee, as well as being subject to the application of the current laws in Brazil.
3.3 Ethics and Conduct Committee
The OCRIM Group will permanently maintain a Conduct and Ethics Committee, composed of the Directors, the HR Manager and the Legal Manager and will have the responsibility to:
A. Periodically review, every two years, this Code;
B. Receive reports of violations of this Code;
C. Guarantee the confidentiality of the information received;
D. Analyze and evaluate Code violations, ascertaining the facts and supporting decision-making;
E. Refer to the Presidency the most serious cases of violations of the Code of Ethics and Conduct;
F. Be responsible for disclosing this Code, which will be delivered to all employees during their integration and making it available to interested parties on the company’s website;
G. Clear up doubts and provide other information to employees in relation to this Code, through the available channels.
4.4 Ombudsman – Ethics and Conduct Channel
For clarification of doubts, contact your immediate leadership. Complaints can be made to the Ethics and Conduct Committee through the email canaldaetica.ocrim@contatoseguro.com.br; by calling 0800 700 7067 or by using the form available on the website www.ocrim.com.br/canal-de-etica, which may be anonymous. Remembering that, being anonymous, the Committee will not be able to give feedback to the whistleblower.
If the complaint contains identification, the Committee will guarantee the confidentiality of the informant. If necessary, it will be up to the Ethics and Conduct Committee to take the statements of the parties involved, examine the documentation and whatever else is necessary and, based on the facts collected, determine whether or not there has been a violation of this Code. If so, determine the sanctions to be applied.
Decisions on whether or not to accept the complaint, the Committee’s conclusions and recommendations will be periodically reported to the President, who may forward them to the Board of Directors.
Together, we bolster the values and ethical principles that guide the professional relationships of the OCRIM Group.