Last week I participated in a seminar about compliance promoted by the Brazilian American Chamber of Commerce (Amcham) in Belo Horizonte. As a manager in this area at Samarco, I have always sought to share our experience and knowledge about the subject, which is becoming more and more intrinsic to the present day. Furthermore, I understand that promoting integrity beyond the company’s environments is fundamental, showing that it has always guided our conduct.
What might be new for many companies, has always been part of the Samarco’s history, becoming something officially structured within the organization in 2002 when the company created its code of conduct. That was the moment when the compliance program was created. Our involvement with this subject has been continuous and constant. In 2011, we already had a policy to prevent fraud and corruption before the enactment of Law 12.846 / 13, better known as the Brazilian anti-corruption law or clean company law,
Recently, our bonds of trust were put to the test with the Fundão Dam break. It made us reflect and improve many aspects of our management, as well as seek studies and debates that show us ways to make our compliance program more efficient. In this way, we improve our initiatives, controls and practices related to the subject daily.
I believe we are on the right track. Recently, Samarco, even in the midst of a major crisis that has challenged its values, ranked 31st in transparency among the 100 largest Brazilian companies in a study conducted by Transparency International Brazil. The study, conducted in 2017 and published this year, sought to identify how the largest corporations in the country are evolving in their standards of transparency and prevention of corruption. Samarco received a score of 8.5 in the anti-corruption program, with the average score being 6.5 for this item.
The constant and disciplined practice of integrity is no easy task. Getting to know suppliers and partners well, managing ethical relations with the public and private sector, avoiding any potential hypothesis of favoring bids, carefully obtaining licenses or entering into contracts and exposing potential conflicts of interest, demands a sense of ethics and a firmness of purpose that are hard to achieve in all company actions.
In the case of Samarco, in particular, I am convinced that this path is fundamental for regaining the bonds of trust with the many types of public that we interact with. We have sought to adopt the best practices of compliance, bringing the subject to our employees’ daily life.
We provide periodic and mandatory training on the topic for our employees. An example of this is the course about interfacing with public power that we are applying to all employees who have some kind of interaction with these “actors,” which range from analysts to members of the company’s board of directors. I understand that implementing good compliance practices depends heavily on the awareness of all employees, partners and leaders.
I often say that compliance is not a department that companies have, but rather a value that influences people’s behavior for the sake of integrity, and that is exactly what Samarco will continue to pursue.
Compliance and Risk Manager and Ombudsma