We are committed to a culture of integrity, where honesty, respect and dignity are critical conditions in interpersonal and professional relationships.

We believe that following robust standards of corporate governance, ethics and integrity is the key to continuing our history of more than 70 years of operations.

Based on these values and on the support and commitment of Carioca Engenharia’s senior management, we created our Compliance Program, which includes the rules, standards and ethics procedures to be complied with by all shareholders, directors, employees, vendors, business partners, clients and third parties that have any connections with Carioca.

In 2020, to further our Compliance Program, Carioca implemented a Compliance, Antitrust and Anti-Bribery Management System (acronym in Portuguese: SGACC) based on the requirements of current regulations, where compliance, anti-corruption, anti-bribery and antitrust actions were taken according to specific procedures and controls, for the purposes of meeting the needs of the construction industry and stakeholders, and complying with the laws.

To encourage ethical conduct in our business, we have prepared a Code of Conduct which outlines the values, mission and principles that should guide the conduct expected of all employees.

Our Ethics Committee monitors and evaluates all cases that may potentially violate the provisions of these instruments. The following violation reporting channels are always available:

Tel.: 0800-3891220

Carioca website: www.canaldedenuncia.com.br

Violation reporting boxes available at our administrative offices and construction sites.

Aware of our role in society and our commitment to building a fairer and more ethical industry, Carioca is part of some anti-corruption programs:

• Since 2020, we have been signatories to Business Pact for Integrity and Against Corruption, by Instituto Ethos.
• Carioca Engenharia is a founder of MISEC (Movement for the Integrity of Engineering and Construction). Created in 2019 from a joint effort of multiple construction companies, Misec is supported by the Global Compact Network Brazil, the United Nations, and Instituto Ethos.
• On November 17, 2022, Carioca, maintaining its leading role in promoting ethics, became a member of IBRIC (Brazilian Institute for Self-Regulation in the Infrastructure Sector). It is committed to promoting the self-regulation of member companies in matters that include ethics, transparency, integrity, sustainability and corporate governance, helping to strengthen the industry.

Compliance

1. What is compliance?

Compliance consists of a set of practices and behaviors that aim to help a company to comply with the laws and with its own rules and procedures by establishing ethical conduct in all its activities, in order to strengthen its governance, integrity, competence, efficiency and competitiveness, and to preserve its sustainability and perpetuity.

2. What is the SGACC?

The Compliance, Antitrust and Anti-Bribery Management System (SGACC) outlines integrated rules, specific and didactic procedures for greater prevention, monitoring and identification of risks.

The SGACC ensures that Carioca may take compliance, anti-bribery, anti-corruption and antitrust actions with a view to:

1. meeting the needs of the civil construction industry and stakeholders;
2. complying with applicable laws;
3. mitigating risks of violation of anti-bribery, anti-corruption, compliance and antitrust rules and processes and;
4. guaranteeing the continuous improvement of its overall performance.

3. What is the Code of Conduct and who does it apply to?

The Code of Conduct is a document that contains Carioca’s values, beliefs and ethics. It applies to our employees, suppliers and business partners. It is extremely important to ensure that our employees, suppliers and business partners know, practice and defend our principles of ethics. The document is available below.

4. Which conduct should be followed by Carioca employees and business partners who liaise with government officials?

As stated in PR SGACC 02 (Government Relations), our employees and partners must respect the current legislation and follow Carioca’s procedures, guidelines, and rules of ethics. It is expressly forbidden for any employee and business partner to offer, promise or authorize, either directly or through third parties, any undue advantage, whether in money, goods or services, to government officials or to anyone related to them, to political parties and their members, or to any candidates for public office, for the purposes of obtaining any advantage for themselves or for Carioca.

5. What is a conflict of interests?

A conflict of interests occurs when an employee uses their job, role or business position to obtain any undue advantage, either direct or indirect, for themselves or for third parties with whom they have a connection.

6. What are the duties of the Ethics Committee?

The Committee is responsible for sharing our ethical culture, reviewing our policies and standards, conducting investigations, analyzing cases of non-compliance and recommending sanctions.

7. Does Carioca’s violation reporting channel guarantee anonymity?

Yes, it does. This is a confidential violation reporting channel managed by a third-party company, and anyone using this channel to report any violations can do so anonymously and is protected from any retaliation.