MARCHESAN Integrity Program
ORIGIN OF THE MARCHESAN INTEGRITY PROGRAM
The Brazilian Anti-Corruption Law (12,846/2013) made room for a more specific form of Compliance, aimed at implementing anti-corruption measures, the so-called Integrity Program. This program began with Decree 8.420/2015, which regulated the Anti-Corruption Law.
DEFINITION
The MARCHESAN Integrity Program, in conjunction with the decree, consists of the organization's scope, the set of internal mechanisms and procedures for integrity, auditing and incentives to report irregularities and the effective application of codes of ethics and conduct, policies and guidelines with the objective of detecting and remedying deviations, fraud, irregularities and illicit acts committed against the public administration, national or foreign.
PURPOSE
Clarify, prevent and combat illegal activities throughout the organization's field of activity.
THE FIVE PILLARS OF THE INTEGRITY PROGRAM
1st: COMMITMENT AND SUPPORT FROM TOP MANAGEMENT
Support from the company's top management is an indispensable and permanent condition for fostering an ethical culture and respect for the law and for the effective application of the Integrity Program.
2nd: INSTANCE RESPONSIBLE FOR THE INTEGRITY PROGRAM
The responsible body is endowed with autonomy, independence, impartiality, material, human and financial resources for full operation, with the possibility of direct access, when necessary, to the highest decision-making body of the company.
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3rd: PROFILE AND RISK ANALYSIS
The company is aware of its processes and its organizational structure, identifies its area of activity and main business partners, its level of interaction with the public sector – national or foreign – and consequently evaluates the risks for the commission of harmful acts of Law nº 12.846/2013.
4th: STRUCTURING RULES AND INSTRUMENTS
Based on knowledge of the company's profile and risks, the MARCHESAN Code of Conduct, rules, policies and procedures for preventing irregularities were established; developing mechanisms for detecting and reporting irregularities (whistleblower channel and whistleblower protection mechanisms); defining disciplinary measures for cases of violation and remedial measures. For broad and effective dissemination of the Integrity Program, MARCHESAN has a communication and training plan, covering the company's different audiences.
5th: CONTINUOUS MONITORING STRATEGIES
MARCHESAN has a monitoring methodology on the applicability of the Integrity Program to the company's way of operating and creates mechanisms so that deficiencies found in any area can continually feed back into its improvement and updating.
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1st: COMMITMENT AND SUPPORT FROM TOP MANAGEMENT
Support from the company's top management is an indispensable and permanent condition for fostering an ethical culture and respect for the law and for the effective application of the Integrity Program.
2nd: INSTANCE RESPONSIBLE FOR THE INTEGRITY PROGRAM
The responsible body is endowed with autonomy, independence, impartiality, material, human and financial resources for full operation, with the possibility of direct access, when necessary, to the highest decision-making body of the company.
p>
3rd: PROFILE AND RISK ANALYSIS
The company is aware of its processes and its organizational structure, identifies its area of activity and main business partners, its level of interaction with the public sector – national or foreign – and consequently evaluates the risks for the commission of harmful acts of Law nº 12.846/2013.
4th: STRUCTURING RULES AND INSTRUMENTS
Based on knowledge of the company's profile and risks, the MARCHESAN Code of Conduct, rules, policies and procedures for preventing irregularities were established; developing mechanisms for detecting and reporting irregularities (whistleblower channel and whistleblower protection mechanisms); defining disciplinary measures for cases of violation and remedial measures. For broad and effective dissemination of the Integrity Program, MARCHESAN has a communication and training plan, covering the company's different audiences.
5th: CONTINUOUS MONITORING STRATEGIES
MARCHESAN has a monitoring methodology on the applicability of the Integrity Program to the company's way of operating and creates mechanisms so that deficiencies found in any area can continually feed back into its improvement and updating.
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