InterCement strives for transparency and ethics in its relations with all its stakeholders. It also values compliance in its processes and operations, and has developed, over the past few years, its Integrity and Compliance Program, applicable to all InterCement companies. In this sense, the Program is based on the main national and international references, focusing on the themes of Anti-Corruptiona and Anti-Bribery.

The Integrity and Compliance Program aims to inform and instruct professionals so that they are always guided by best practices and thus avoid damaging the company´s image and reputation.

This program is divided in two parts:

The hard part (robust and laborious) which is the elaboration and/or revision of policies and standards, updating of the Code of Conduct, education, internal controls, monitoring, among others.

The soft part (more subtle and intangible) which is to try to root in the Organizational Culture the habit of using ethical guidelines to integrate the decision-making processes of the organization.

Listed below are the components of the Integrity and Compliance Program. For more details, just click on each one.

1. Communication

It consists of a continuous communication process of Integrity and Compliance topics, through e-mail marketing (including messages of support from Senior Management to the Integrity and Compliance Program), banners, wallpaper on the desktop or in SAP, stickers, lectures, videos, Compliance website, etc.

E-mails marketing related to the Integrity and Compliance Program are sent through the domain: Compliance Comunica.

2. Education

It consists of an active and permanent teaching and learning process on topics involving integrity and compliance, such as, but not limited to:

Code of Conduct
Ethical Line
Integrity and Compliance Program

It is necessary to monitor and demand the participation of professionals in training, as well as apply mechanisms to verify the retention of content covered in training.

The Audit, Risk and Compliance Department participates in the planning, preparation, application and/or contracting of training on integrity and compliance issues.

3. Audit, Risk and Compliance Governance

5. Compliance Process

It is a monitoring process that aims to ensure compliance with local Laws and Regulations, as well as InterCement`s internal Policies, Rules and Procedures.

For topics identified as critical, InterCement created a governance structure that has the roles of Compliance Agents

Compliance Agent

Key professionals in each Business Unit, responsible for being the Facilitator (contributing to spreading the compliance culture and implementing the process at the BU) and the Guardian (ensuring that the execution of activities is in accordance with local Laws and Regulations, as well as InterCement´s internal policies, standards, manuals and procedures).

6. Terms and Declarations

In a process of continuous improvement, the Audit, Risk and Compliance Department created the Compliance Module online avaivable on intranet (Portal SER+) to automate the filling process and perform centralized management of Terms and Declarations related to some of the Standards of the Integrity and Compliance Program, such as:

1.Declaration of Commitment to the Code of Conduct
2.Term of Commitment to the Integrity and Compliance Program
3.Conflict of Interests Declaration
4.Term of Utilization of working tools
5.Declaration of Interaction with Public Agent
6.Declaration of Competitor Meeting Participation
9.Declaration of Acceptance of donation of goods and or materials
10.Declaration of Acceptance of donation of sponsorship
11.Declaration of offer of gifts above USD100
12.Declaration of receipt of gifts above USD100
13.Sworn Statement of Politically Exposed Person – PEP (Loma Negra)