Seeking continuous improvement in compliance practices, in April 2017, the Businesses of the Odebrecht Group implemented a number of improvements in their management of the Ethics Line channel, which is an important tool for maintaining a business environment and workplace guided by integrity, ethics and transparency.

The main new development was hiring ICTS, a company specializing in management with extensive market experience, to receive and forward the reports. This ensures a higher quality process, given the use of a specialized and multidisciplinary team to receive and qualify the reports received, as well as a methodology for capturing as much information as possible at the time of the report.

“The new process has reinforced people’s confidence in using the Ethics Line channel and resulted in it receiving reports with higher quality information, which has supported more productive investigations and more timely results,” said Olga Pontes, Chief Compliance Officer at Odebrecht S.A.

SEE BELOW SOME INDICATORS FOR THE ETHICS LINE AT THE ODEBRECHT GROUP*:
71% of reports are sent unanimously
56% of reports are sent through web channels (odebrecht.com/linhadeetica)
71% of reports resulted in investigations since they contained sufficient information for assessing the facts

The main topics reported are: misconduct**, violation of internal standards and policies, and moral harassment.

ABOUT THE CHANNEL
The Ethics Line can be accessed by Odebrecht’s team members as well as by clients, third parties and the general public. The new Ethics Hotline also allows whistleblowers to accompany progress on their reports anonymously using the case number generated. This functionality also allows Odebrecht to communicate anonymously with the whistleblower to request additional information or clarifications.

Odebrecht S.A. and each Business have their own websites and telephone numbers (toll-free, 0800) for making reports, which can be found at www.odebrecht.com/linhadeetica. The system functions 24 hours a day, seven days a week. The websites and toll-free telephone service of the Ethics Hotline are available in Portuguese, English and Spanish.

*Consolidated information of all Businesses of the Odebrecht Group from April 2017 to October 2018.

**Misconduct: any inappropriate behavior that violates the commitment to ethical conduct, with integrity and transparency. Moral harassment: practice of abusive conduct committed against a team member to coerce, humiliate, disrespect or embarrass them.