Compliance
Program
Get inspired01.
The Program is ours02.
The role of each one03.
Get to Know
the ProgramMonitoring the Program04.
01.
Get Inspired
Compliance Programs have the purpose of
disseminating guidelines to achieve the state of
compliance and business sustainability, making it
possible to increase the prevention of illicit acts,
reduction of financial losses and damage to the
reputation of the institution.
In the financial system, clients and investors have become
concerned about issues related to the reputation and
sustainability of the companies that manage their assets.
These entities need to dedicate greater attention to compliance
with the requirements imposed by the regulatory environment
and to the development of policies to guide and demand ethical
and responsible conduct from their members.
Such Programs establish guidelines for prevention, detection
and correction of practices that are either inappropriate or in
conflict with laws, norms and external and internal regulations,
gaining relevance as an instrument of corporate governance.
ComplianceIs to comply with laws and external and internal regulations
Compliance is a responsibility of all
employees, interns, service providers and
suppliers of the Bank, regardless of their
function . After all, they are the primary
responsible for conducting their processes,
controls and risks.
Compliance
Being in compliance is the act of obeying
the laws, regulations, norms, policies and
procedures, adding to this concept
principles of integrity, ethical conduct, and
even efficiency.
A responsibility
of everyone
The Compliance
Program
The Compliance Program involves the whole
Bank in the mission of ensuring effective
compliance risk management and strengthening
the internal control system, contributing to:
risk mitigation in business
dissemination of the a culture of
internal controls and compliance
inhibition of illicit acts
reduction of financial losses
reputation damage prevention
The Program is aimed at all employees and third parties
that provide services of a permanent, temporary,
exceptional or occasional nature to the Bank.
It also applies to units located abroad, in accordance with
their local laws and international good practices.
It is aligned with the Corporate Strategy, reflecting the
purpose, values and vision shared among the people who
make Banco do Brasil.
Corporate
Strategy
Banco do Brasil
Corporate
Strategy
Banco do Brasil
Strategic Planning is a systematic process in which strategic
guidance is established, that is, the direction to be followed by
Banco do Brasil and it’s Affiliated Entities (ELBBs), seeking better
direction of efforts and allocation of organizational resources.
At Banco do Brasil, the current Corporate Strategy defines the
Strategic Objectives to be pursued by the Organization for the
2018-2022 time horizon, as well as the Macro Ambitions of the
Bank in relation to the Strategic Segments in which the ELBBs
operate. The Corporate Strategy is divided into the Master Plan, the
Market Plan, the Performance Agreements of the Units, and the
Planning of the Strategic Units, providing the alignment and
engagement of the entire Institution to achieve sustainable
results.
PurposeCaring for what people value
Values
Customer FocusInnovationEthicsEfficiencyPublic spiritedReliabilityOwner's sense
Vision
Be the company that provides thebest experiencefor the lives ofpeople and promotesthe developmentof society, in an innovative, efficient andsustainable way.
Purpose, Values and Vision are the elements that inspire and
provide consistency for the company's performance. This is how we
define ourselves, that is how we are, how we wish to be perceived.
And so are we committed to:
Respect all laws related to our business withparticular focus on the sustainability ofoperational and management processes;
Maintain responsible and ethical businessconduct, contributing to the integrity of thenational financial system;
Require of all employees and partners that they ensure compliance with regulations;
Valuing good practices, not toleratingmisconduct and non-compliance with legalobligations or internal rules.
“Banco do Brasil has a
transforming role for people,
for society and for the country”Our commitment
Remember that the Code of Ethics and the
Standards of Conduct must always be respectedin your day-to-day actions and decisions and should alsoserve as a reference for our employees, service providersand suppliers.
02.
The program
is ours
The Compliance Program gives the Bank the
credibility it needs to demonstrate its ethical
positioning and responsible and sustainable
practices in the conduct of its business.
It is composed of integrated and complementary
guiding principles that drive the Bank's
operational activities and business practices,
supported by the pillars of prevention,
detection and correction of deviations from
external and internal laws, rules and regulations
and the Code of Ethics and Standards of
Conduct.
The pillars are supported by a solid base formed
by the culture of Internal Controls and
Compliance, Ethics and Corporate Governance.
The Compliance Program belongs to all of us
Compliance Program
Banco do Brasil
I - Top Management Support – tone from the top
II - Risk assessment
III - Code of Ethics, Standards of Conduct and Compliance Policy
IV - Training and communication
V - Regulatory monitoring
VI - Due Dilligence
VII - Internal controls
VIII – Reporting Channel
IX - Internal investigations and
consequence management
Prevention Detection Correction
Culture of Internal Controls and ComplianceEthics and Corporate Governance
The Compliance Program is sponsored by the Senior
Management, which seeks always to be prepared for the
challenge of inserting the culture of internal controls and
compliance into the day to day work, and of being seen as
an integral part of and partner of the business.
The Senior Management of Banco do Brasil, composed of
the Board of Directors and Executive Board, approved the
implementation of this program, ensuring that the directors
participate actively, aiming to maintain alignment to the
organization's direction, greater operational safety and
greater confidence to investors, suppliers and customers .
Support from
The Top
Knowing the vulnerabilities, risks and
objectives of the company is fundamental to
structuring an assertive assessment,
combining the probability of occurrence and the
impacts that such events would have if they
were observed.
Banco do Brasil has a risk management
structure that aims to identify, evaluate and
measure, control, mitigate, monitor and
report risks, contributing to the maintenance of
the organization's solidity.
Risk
Assessment
The compliance area assists
managers in managing compliance
risk, which can be defined as the
possibility of financial loss or
reputation loss from non-compliance
with applicable laws, regulations,
internal standards, codes of conduct
and guidelines for the business and
activities of the organization.
Risk is the possibility that the outcome of a particular event may be different from the expected result, negatively impacting the company's intention to achieve previously established goals.
The other risks have their own and integrated
governance structure.
The Code of Ethics and the
Standards of Conduct of Banco do
Brasil establish the values and
determine the standard of behavior
that is expected of its functional staff.
They present the commitments and
the guidelines regarding their related
public, duties and behaviors
expected in the work environment.
*The Code of Ethics and the Conduct Standards and the other documents that deal with integrity in business are available in the corporate intranet and also in the internet:
https://dipes02.bb.com.br/pessoas/area.xhtml?area.id=6#!
http://www.bb.com.br/pbb/pagina-inicial/sobre-nos/etica-e-integridade/#/
*The Subsidiaries, Affiliates and Holdings may define their guidelines based on these guidelines, taking into account the specific needs and legal and regulatory aspects to which they are subject.
Code of ethics,
Standards of Conductand Compliance Policy
These instruments reflect the
company's position, are linked to
the various issues related to
conducting business, guiding its
employees along the path of
ethical and legal practices.
The Internal Controls and Compliance
Policy is part of good governance and
aims to establish principles and
guidelines to be observed to ensure the
strengthening of the internal control
system, compliance with compliance
obligations and the effectiveness of
compliance risk management.
Training programs and communication actions are critical to promoting Compliance culture. The
definition of a strategy for elaboration of training and communication plan facilitates the chain and
multiplication of knowledge.
The Bank has carried out training actions, aiming at promoting the training, updating and
specialization of its employees, in matters related to internal controls and compliance, risk
management, safety and other compliance functions.
The communication actions aim to reinforce the issues here addressed, disseminating to all
employees aspects regarding norms and procedures, general and specific policies, using all
available channels.
Training and Communication
The regulatory environment delimits the performance of
companies in conducting business by establishing
restrictions - laws, standards, regulations and rules. Such
restrictions lead to the need to create, modify or adjust
internal processes in order to adapt to the requirements
imposed by this environment, avoiding losses due to fines
and penalties and damage to reputation.
Monitoring
Regulatory
The identification of laws, regulations and standards in the
Bank is carried out in a decentralized manner by process,
product and service managers, within their scope of action,
being also in charge of internalization, publication and
periodic review. It is up to these managers to assess the
compliance status of their processes, products and
services, based on the analysis of related laws,
regulations and rules, promoting the necessary
adjustments in their internal policies and procedures.
Due
Diligence
The administrative and civil liability of legal entities for acts against national or foreign public administration,
imposed by the Anti-Corruption Law (12,846 / 2013), led companies to review their internal processes to
foresee anti-corruption measures, as well as to monitor third parties with which they have contractual
relationship, due to the concept of co-responsibility.
Thus, Due Diligence of third parties becomes an increasingly necessary and relevant practice to minimize
the risks of various kinds, inherent to business with companies and contractors.
Due Diligence – refers to the process of investigation, evaluation and analysis for accepting the risks of commercial transactions, being used in the creation of commercial partnerships and contracting suppliers.
These are processes and practices whereby organizations seek to
ensure that all planned and approved actions are carried out
properly, in order to safeguard assets, the accuracy and reliability of
management information and financial records, the promotion of
operational efficiency and adherence to organization´s policies. Its
purpose is to contribute to achieving the company’s strategic
objectives and its continuing corporate presence.
Internal
Controls
Banco do Brasil has an Internal Control System suitable to its
size and complexity, meeting regulatory requirements and in
line with best governance practices.
They allow employees (domestic and overseas), interns,
apprentices, third parties and business partners, a way to alert
the company, even anonymously, to potential violations of the
Code of Ethics and Standards of Conduct and other policies.
The Complaints channels of Banco do Brasil are easy to
access and are designed to capture and analyze information
received. They are recognized for their credibility and
commitment to protecting the identity of the source and
confidentiality of information.
Reporting
Channel
Reports about behavioral deviations and noncompliance with
internal rules should be sent to our Internal Ombudsman.
Any suspected harmful act that might be defined or described
as corruption should be referred to the “Canal de Denúncia de
Ilícitos”.
• Internal Ombudsman - (061) 3108-7488
External Ombudsman - 0800 729 5678
0800 729 0088 For the hearing or speech [email protected]
Reporting Channel - Portal BB (Atendimento > Reclamaçõese denúncias > Canal de Denúncia de Ilícitos)
Internal Investigations
and Consequences Management
The management should be carried out in an independent
and confidential manner, and the inquiry must be carried out
in a professional and impartial manner, using appropriate
investigative mechanisms.
Banco do Brasil has rules, specific procedures and
defined workflow for the investigation process and
determination of responsibility and disciplinary
control, in a segregated, autonomous and impartial
way.
Non-compliance with the guidelines of the Code of
Ethics and the Standards of Conduct may result in
sanctions, depending on the severity of the
occurrence, its circumstances and the level of
participation of each party involved.
Consequence management requires methodology and
intelligence, with an impersonal process and focus on
establishing the truth.
Banco do Brasil has established an
Integrity Program which provides
for a set of internal mechanisms
and procedures, an incentive to
report irregularities and to
implement the code of ethics and
standards of conduct, with a focus
on anti-corruption measures.
Integrity
Program
Access the Integrity Program
03.
The role of
each one
The role of the Top Management
Maintain proper conduct and ethical attitude, adhering to the Code of Ethics and the Standards of Conduct.
Ensure compliance within the governance of the organization.
Oversee reports concerning the compliance status of the organization, as well as the Compliance Program monitoring and take actions needed to maintain compliance.
Disseminate the culture of internal controls and compliance and promote this program to employees.
Top Management approves and
supports the Compliance Program
Important actions to be taken by the leadership of the Banco
do Brasil:
Ensure adherence to compliance policy
Promote environment control management in his/her team
Encourage the debate on the Compliance Program among the team so as to clarify employee doubts and reinforce the importance of knowing all the guidelines
Protect team members against retaliation due to reports of violations
Ensure that staff members are properly trained in their areas of practice, and encourage training in
internal controls and compliance.
Leadership
Role
Each manager is responsible for
ensuring that all legal obligations
governing their activities are complied
with, which may include identifying,
reporting and managing any breach of
compliance.
It should be an example of good
conduct, to encourage and value such
behavior in his team, ensuring that
everyone conducts their activities
ethically, always in compliance with laws
and regulations.
All
employees’
RoleKnow and comply with the Code of Ethics,
the Standards of Conduct and the
Integrity Program of Banco do Brasil.
Ensure compliance in the conduct of work
activities, observing the responsibilities
assigned to his/her role.
Obey the laws, regulations and internal
rules of the Bank.
Prevent, when detected, the practice of acts
not tolerated in this Program and report any
breach of compliance.
Be an example of ethical conduct
Be Compliant
To act as a compliance agent, contributing to the
dissemination of the culture of internal controls and
compliance in the organization.
04.
Program
Monitoring
The Compliance Program is periodically
monitored by Top Management with the purpose
of evaluating the compliance status of the
guidelines.
Monitoring
the Compliance Program
As of 8 May, 2019Internal Controls Board