Compliance & Governance

Compliance Program

We, at Votorantim Cimentos, prohibit the making of payments, as a bonus, facilitation or offering any advantage to public officials or government authorities for any purpose, including contribution in value, goods or services to campaigns, or political causes, as well as such as receiving and offering gifts, entertainment, hospitality and institutional invitations. Everyone must always respect the guidelines set out in the Code of Conduct.

Since 2013, we have maintained the Compliance Program with communication campaigns and training for all employees and directors, monitoring the effectiveness of the program and taking the necessary measures in case of violations or carelessness. In addition, we encourage the reporting of any suspected illegal acts through the Ethics Line and we do not accept reprisals of any kind. This channel, public and open to everyone, inside and outside the organization, ensures a way to make reports confidentially and anonymously. All reports are verified and directed in accordance with internal policies and current legislation.

Our programs and policies are constantly evolving, consolidating good practices and adapting to changes in our society.

Our Compliance Commitments

• Strong commitment to Nosso Jeito VC de Ser, Fazer e Ir Além;
• Highly committed to the best practices defined by the Comissão de Valores Mobiliários (CVM) and
• Securities and Exchange Commission from the United States of America (SEC);
• Highly committed to the best practices defined by the CVM e SEC;
• Structured compliance program, updated annually and committed to actions that lead to transparent and responsible business behavior;
• SOX monitoring since 2010;
• Monitoring and evaluation of compliance, always seeking prevention;
• Ethics and compliance training for employees available on the global portal for all units;
• Ombudsman channel available to all employees and stakeholders;

Code of Conduct

We at Votorantim Cimentos believe that being compliance is doing the right thing even when no one is looking. It is choosing the right path, even if it is the longest and most difficult. For us, this is the only acceptable path.

That’s why in Nosso Jeito VC and in our Code of Conduct we reinforce our commitment to compliance. We expect our employees at all levels, from operations to management, shareholders and partners, to follow the guidelines of our Code of Conduct and comply with all laws, regulations and policies in all regions and countries in which we operate. Thus, we conduct business with integrity, ethics and sustainability, through a balance between culture and objective processes.

We are in constant search for best practices, encouraging the fight against corruption and presenting the damage it causes in the political, economic and social spheres. In this way, we disseminate among customers, employees, directors, shareholders, suppliers, partners, public authorities, the media and the community, the breadth and relevance of the topic, resulting in protection and preservation of value for society and, consequently, for our company. .

Ethics line

The Ethics Line is a public channel open to everyone, inside and outside the organization. Its purpose is to capture, listen, analyze and resolve any issue related to our Code of Conduct. Administration of the ethics line guarantees privacy and confidentiality. No information obtained through the channel is made public, nor the identities of the people involved. The ethics line ensures that complaints, suggestions and criticisms are dealt with at the appropriate levels of the organization.

The Ethics Line is an exclusive communication channel between you and Votorantim Cimentos. Its purpose is to address issues related to the Code of Conduct, which contains the principles and guidelines that guide Votorantim’s relations with all its stakeholders and ensures that complaints, suggestions and criticisms will be sent to the appropriate sectors within the organization.

Corporate governance model

The new governance structure provides an equitable view of the business challenges and mechanisms that influence the market in our four Business Units – VCBR (Brazil), VCLatam (South America), VCNA (North America) and VCEAA (Europe, Asia and Africa) –, favoring the exchange of good practices and investment decisions.

Each of these units is represented in the GET – Global Executive Team. In addition to the vice presidents responsible for these regions, the GET is made up of the global president of Votorantim Cimentos and executive directors from five global areas that are strategic for the Company: Finance; People, Communication, IT and Management; Legal; GRC & Internal Audit; and Sustainability, Institutional Relations, Product Development and Engineering. The GET meets monthly to propose, decide and monitor the actions that lead to Nosso Jeito VC.