Compliance Program

Following the enforcement of the Anti-Corruption Law (Law No. 12,846, of 2013), Magna Engenharia carried out a variety of compliance training actions as of April 2014 and complied with a strict timetable for updating its ethical and business conduct standards. These standards form the basis of the Company’s Anti-Corruption Compliance Program, representing the set of values and principles cultivated by Magna’s Board of Directors, since its fundation in 1969.

With the advent of the Anti-Corruption Law, Magna carried out the adaptation of its probity mechanisms and internal control procedures, aiming at the implementation of the new Compliance Program, contracted in 2014 with a specialized external consultancy, to give sustainability to the functioning of the system prevention and anti-corruption initiatives developed in a customized way for the Company.

Following the strategy of thinking about the compliance model to be adopted, and considering the specific characteristics of the activities developed by Magna, our specialized consultants developed a totally new approach for the Company, resulting in the creation of the Compliance Committee, which is the managing body of the functioning of the Integrity Program and that it acts with autonomy and independence in relation to the formal structures of Magna, that is, without hierarchical subordination, as foreseen in the legislation of business integrity and according to the most updated models of management of the compliance function .

Using the compliance model, which it considers the most advanced, Magna has a permanent monitoring of the performance of its employees, and it also applies diligence mechanisms and procedures to verify the regularity of the performance of its subcontractors. The Company has adopted an Instrument of Adherence to the Code of Business Ethics and Conduct, in which employees undertake to follow the Company’s ethical standards and also the provisions of the Internal Regulation established by the Compliance Committee.

Compliance with the values and principles contained in the Code of Business Ethics and Conduct are extended to the Company’s business partners and subcontractors, through contractual clauses and the drafting of a Subcontractor’s Code of Conduct. As such, all subcontractors are informed of Magna’s business conduct standards and must adhere to the applicable Compliance Program rules.

The Compliance Committee is composed of senior Magna professionals and is responsible for judging the internal assessment processes and, if necessary, recommending to the Company’s Board of Executive Officers the application of applicable disciplinary sanctions to violators of the Integrity Program standards, which is made based on the results obtained by the Committee in the investigative stage of the investigation processes.

Thus, Magna intends to act as one of the pioneer companies in Brazil to adopt a compliance system that is supervised by an external legal Compliance Officer and to have rules of business probity established in its own constitutive acts, giving effect to “erga omnes “(Validity for all) to the standards of compliance that the Company follows and forcing them to comply with them in their relationships with business partners, consortia of companies, customers, suppliers and service providers.

The results obtained through the system of prevention and combat against corruption described above have been fundamental to reinforce the reliability of Magna, thus stimulating the formation of a culture of business probity in its business environment, as defended by Board of Directors since the foundation.

In addition to approving the Code of Ethics and Business Conduct and implementing the Compliance Committee, Magna has publicized its Compliance Policy and created complaint channels to receive formal suggestions or complaints on its website and at the Company’s headquarters, as well as defining a Training Policy for the integration of new employees and the recycling of all employees in the various topics related to the ethical standards defended by the Board of Directors.

In addition, Magna has produced an institutional video and a compliance sheet for distribution to employees in all branches and offices of the Company, including explanations on the regulations complementary to the Code of Ethics and Business Conduct, especially regarding the rules that must be observed for subcontracting services, participation in bids through consortia of companies, rental of vehicles and equipment, training and orientation of its staff, including all employees involved in the administrative tasks and execution of Company works.

For all this, Magna is fully able to work with public and private contractors, contributing to the development of a business environment based on ethics, high technical quality and fair remuneration for the services provided.