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FCC S.A.
Our Company › Code of Conduct

The main objective of the Code of Conduct of FCC S.A. is to guide the behavior or professionals of the company, ensuring a transparent relationship with the workforce, shareholders, customers, suppliers, the government and the whole of society.

Introduction

A company has to be seen as an active element in the social context (cultural, political, economic, etc.) and this fact leads to commitments and responsibilities that the organization should have regarding society.

Corporate Ethics is about with this entry process in the world we live in. The company must be present in a transparent manner, in order to contribute, always, to improve the internal and external relations and to the community development, practicing citizenship and social responsibility.

Today's organizations incessantly seek the answers to their permanence and survival in the market and the ethical and moral conflicts pervade this context. As a result, their organizational concepts and their Ethics and / or Codes of Conduct are continuously reformulated in order to promote improvements in the interaction between the internal and external environments.

The main goal of the FCC S.A. Code of Conduct is to guide the behavior of business professionals, ensuring a transparent relationship with the workforce, shareholders, customers, suppliers, government and society.

In this document, conduct and responsibilities have been established and it is the duty of all who comprise the workforce, as well as those who represent and act on behalf of the company, maintain commitment and adherence to its principles, promoting their application in actions involving organization's interests.

The behaviors herein set forth should reflect, above all, the values consolidated by the FCC S.A. Way of Being, entirely built by the people who comprise our workforce. The collection of these values gathers the ethical principles, which guide the practice of our ideals. In all, nine core values summarize the FCC S.A. Way of Being:

  1. Our Way of Being Responsible for the Common Wealth
  2. Our Way of Being Responsible for All
  3. Our Way of Being Committed
  4. Our Way of Being Disciplined
  5. Our Way of Being to Generate Trust
  6. Our Way of Being to Work in Team
  7. Our Way of Being to Make It Happen
  8. Our Way of Being to Innovate
  9. Our Way of Being to Achieve Excellence

1.  Relationship with Customers

FCC SA is guided by the following principles: transparency in the dissemination of information and characteristics of products and services; product suitability or service to customer demand to better meet their needs; compliance with laws where it operates and respect for the commitments.

It is not allowed to offer award for brand loyalty, rebates, gifts (except advertising gifts, worth up to $ 100 - one hundred dollars), special discounts or other benefits.

This sponsorship costs with customers related to meals, transport and accommodation is permitted within the commercial relationship, as provided for by FCC S.A. Commercial Policy.

It is forbidden to the employee: accepting gifts, payments, loans, or any other advantage on its behalf and / or the people in the family, except promotional gifts containing the identification of the company, to a maximum of $ 100 (one hundred U.S. dollars). All gifts which are not considered promotional gifts - or not containing the company logo that is offering the gift - must be subject to the approval of the Ethics Committee, regardless of the value. This committee may approve the acceptance of the gift by the recipient employee or forward to draw for all or a specific group of employees.

It is allowed to FCC S.A. receiving, accepting and sponsoring socio-cultural activities, and / or other ethical nature, promoted by its customers and prospects or FCC SA (itself) as long as evaluated by the Social Responsibility Committee and approved by the Ethics Committee.

FCC S.A. submits to the Brazilian and international anti-corruption legislation and knows its administrative and civil liability against cases of bribery or any undue advantage to start or maintain a business, including facilitation payments (bribes) and money laundering, not Consistent, or being tolerant, under any circumstances, with these illegal practices.

2. Relationship with Shareholders

 Observing the legal provisions, all shareholders have comprehensive information about what can affect investments and debt payments.

Tort cases, where there is obligation to transmit to the Presidency of the Board of Directors of FCC SA, in compliance with the requirements of Brazilian Corporate Law (Law 6404) and /or in the  FCC S.A. Anti-corruption Policy, must be reported.

The Ethics Committee shall be responsible for sending to the chairman of the Board of Directors the cases provided by law (corruption, fraud and tax accounting books, bidding fraud, bribery etc.) and cases of direct complaints against the Board of FCC SA, as mentioned in the FCC S.A. Anti-corruption Policy.

3. Relationship with Credit Financial Institutions
 
The relationship with financial institutions must occur within legal requirements, ensuring both parties access to relevant information to the conducted business.

FCC S.A. shall only provide the data necessary to implementation of financial transactions and information required by the Government.

4. Relationship with government agencies, State enterprises or controlled by the government

FCC S.A. submits to the Brazilian and international anti-corruption legislation and, to ensure its ethical and transparent relationship with public agencies, public corporations or controlled by the government, maintains its accounting documents in order to provide reasonable assurance that its transactions are accurately registered.

In its relationship with national and international public agents, the company does not accept corruption in whatsoever form, respecting the legal liability (civil and administrative), made by responsible control agencies in Brazil and abroad, in proven cases of bribery or undue advantage characterizing tort, committing to repair the damage caused. It also recognizes the administrative and civil liability of employees involved in these acts, punishing these people with the measures described in the internal policies of the organization.

In the relationship with national and international public agents, all employees and contractors at the service of the organization must comply with the legal regulations and guidelines of FCC SA for cases involving the possibility of fraud or illicit transactions with "things of value", namely: trips offer, gifts, presents, entertainment, awards, facilitation payments (bribes), contributions to charitable causes, contributions to political parties, sponsorships, acquisitions and / or fraudulent records.

 5. Relationship with the Workforce (employees, apprentices, trainees, assigned, temporary and outsourced)

 FCC S.A. gives to the entire workforce a treatment based on justice and respect, not allowing the adoption of any discriminatory practice by reason of gender, origin, ethnicity, sexual orientation, generation, religious creed, ideology or cultural differences.

The company does not use any form of discrimination in hiring, compensation, access to training or recognition / internal awards, promotion, termination or retirement.

Considering target of prejudice, disrespect, such as sexual harassment, psychological harassment, or mistreatment, the member of the workforce must seek with the immediate manager or the Ethics Committee, the solution to the problem.

The professional development of each employee is evaluated individually and periodically, leaving the manager to guide and provide information that affects, directly or indirectly, their performance and motivation.

The respect for privacy and confidential information of the effective under the responsibility of FCC SA is strictly maintained. Access to these information is restricted to authorized personnel, so that they have an obligation to ensure that they are not disclosed or improperly used.

FCC SA encourages participatory management, involving employees in strategic planning and developments, providing the company's results through specific meetings and corporate communication channels, thus allowing a systemic view of the organization.

FCC S.A. employees assigned to other companies should be subject to the Conduct / Ethics Code organization in which they are allocated, provided they are stricter than the FCC S.A. Code of Conduct. In case of conflicting information, the organization's employees shall always follow the provided by FCC S.A. Code of Conduct.
The professionals assigned to Fábrica Carioca de Catalisadores S.A. undertake to observe the guidelines set forth in the FCC S.A. Code of Conduct.

At FCC S.A., the workforce is always stimulated and encouraged to create new solutions, take initiative and act proactively, preventing accommodation and conformism.

Critics and workforce suggestions are encouraged and welcomed by the company, without constraints or the author punishment, since made with accountability and transparency through the channels provided by the organization.

As defined in the Way of Being FCC SA, involuntary errors in well-meaning attempts function to produce improvements or solve problems are not punished, since they help to grow and form the basis for a permanent search for excellence. In turn, volunteers’ errors are not tolerated because they are the result of the omission, the slouch, the neglect and the laziness to do it well, deserving special attention and rigorous correction.

The trade union association, and the strike are recognized by FCC SA as workers' rights. However, the FCC SA does not allow excesses that endanger the physical and moral integrity of its workforce and its assets.

The legal rights and responsible treatment are provided for pregnant women employed, employees and contractors victims of work accident and people with disabilities.

The workforce must maintain the confidentiality of confidential acts or facts to which it has access and not use it to obtain advantages for oneself or for others, with the capital market, companies, institutions or individuals.

Relatives of people within the workforce may be admitted and / or hired by the company, if assessed and competing on equal terms with other candidates and not occupying conflicting positions hierarchically to each other.

It is not allowed to FCC SA workforce, use machinery, equipment, tools, facilities or other property of the company for their own benefit or third parties.

FCC S.A. employee shall not offer or accept entertainment or gifts - except promotional gifts containing the identification of the company, a maximum limit of $ 100 (one hundred dollars) - or performing any sort of unanticipated favors in the efficient conduct of its function.

FCC S.A. workforce acknowledges that the company submits itself to the Brazilian and International Anti-corruption Legislation and must act aligned with these regulations, as well as the guidelines and internal integrity policies, not involving, under any circumstances, in cases of bribery and undue advantages, such as facilitation payments (bribes), money laundering or other forms of corruption within the organization, or shall suffer legal penalties and internal punishments.

6. Relationship with Suppliers

Suppliers must be treated on an equal basis in all stages of the competition process and should be assessed according to pre-established criteria by the company (Third Parties Hiring Policy and Contracts Audits).

The purchase of materials or services may not involve companies in which employee's relatives participate, directly or indirectly, unless otherwise approved by the Ethics Committee.

It is strictly forbidden for all employees and temporary employees receiving commissions, benefits or gifts / free gifts that represent their commitment to the supplier, except promotional gifts containing the identification of the company, to a maximum of $ 100 (one hundred dollars).

FCC SA does not establish any form of contract / partnership with suppliers of materials and / or services that use child labor and / or forced, as set forth by the International Labour Organization (ILO). It also does not establish contract / partnership with companies that have harmful environmental practices.

7. Health, Safety and Environment

It is the FCC SA’s responsibility, the constant search for life quality and improvement of the people’s working environment, for the safety, health and welfare.

The safety and health of the workforce are FCC SA core values, as well as the environmental preservation, and they have priority over the manufacturing in case of conflict. The security ambience is a company duty (as other trainings on Environment, Health and Safety that are necessary) and an obligation of the workforce.

Performance of the tasks and the operation of any equipment may only be achieved if the procedures and security conditions are absolutely guaranteed.

Environmental conditions should be strictly and permanently monitored in order to a healthy environment and considering the current environmental legislation. They must also be continuously directed to sustainable development.

It is forbidden to enter and remain in the workplace, as well as the external representation working on behalf of FCC SA; anywhere in the influence of alcohol or under the influence of illicit drugs. The breach of this item may place both the workforce and the assets of FCC SA at risk and, therefore, shall be liable to punishment if identified.

8. Communication

FCC SA maintains the workforce permanently informed about the relevant facts that occur in the company, always maintaining the transparency and its commitment to truth.

Those who participate in the dissemination of rumors compromise their own image and the corporate image. Information derived from rumors should not be outsourced to other colleagues and neither the external public. The authenticity of any matter not yet formalized by the company should be checked with the managers or Human Relations Management.

Information for the external public can only be disclosed by persons designated to speak on behalf of FCC SA No member of the workforce must make statements on any subject without being authorized by the Board.

In interpersonal relationships, face-to-face communication, the search for understanding, freedom of expression and continuous dialogue should prevail.

The workforce is the responsible for the use of specific vehicles of corporate communication, such as e-mail, intranet, relationship system between customer and internal supplier etc.

It is forbidden the dissemination of any messages other than those absolutely linked to the performance of the function and subject to punishment those possessing pornographic, racist, religious or political nature, and the spread of gambling prohibited by law.

9. Social Responsibility (internal people and community)

 Being a socially responsible company is one of the strategic goals of FCC SA for achieving its Vision. To this end, the organization actively participates in the development of the region where it operates (internally and externally), implementing social responsibility actions through incentive programs for the Education, Health, Environmental Awareness and Income Generation.

Its social programs shall cherish the identification of real needs of the domestic population and the environment (being safeguarded their culture and vocations), the partnership with public bodies and by strengthening its institutional image.

All social and environmental responsibility actions of FCC SA are supported by the Social Responsibility Policy and Donations and Sponsorship of the Company.

The participation of the workforce in projects and causes involving volunteer work is supported and encouraged by FCC SA

FCC SA does not adopt or support in own or third party processes, any kind of child labor, forced labor or predatory exploitation of fauna and flora.

FCC SA rejects any form of sexual exploitation of children and teenagers and all kinds of action or promotional material that encourages this advertising model. In addition, it states that children and teenagers must grow free of all forms of negligence, discrimination, exploitation, violence, cruelty and oppression.

FCC SA also fosters respect to children and education for citizenship through internal and external practices of mobilization and awareness of the workforce.

Ethics Committee

The Ethics Committee is comprised by directors and two members of the management group chosem by FCC S.A. Board.

The Ethics Committee is responsible for ensuring the fairness in business relationships, monitoring, investigating and treating the cases of violation thereof. The penalties applicable to the identified violations follow the sanctions provided for in the relevant legislation and the organization's guidelines.

If any member of the Ethics Committee is involved in any complaint, this may not participate in the investigation process and the definition of penalties.

The Ethics Committee shall be responsible for sending the cases provided by law (corruption, fraud and tax accounting books, fraud in procurement, bribery, etc.) and cases of direct complaints against the Board of FCC SA to the Chairman of the Board of Directors. In this case, the Directors shall not participate of the complaint investigation process.

 Code of Conduct Management

As from the publication of this Code, its management will be up to the Human Relations Management supported by the Ethics Committee. It is up to the Ethics Committee ensure the constant updating and adjustment of this Code of Conduct.

It is the Ethics Committee’s responsibility to analyze the Code of Conduct violation cases, applicable law or internal policies of the organization, in the most serious occurrences and deliberate on questions of doubts on the interpretation of the texts contained in these guidelines.

It is the FCC SA’s responsibility to empower the workforce in its Ethics and Conduct guidelines, policies, standards and procedures relevant to each process and related legislation to its activities.

It is commitment of the employee, third party or people working on behalf of Fábrica Carioca de Catalisadores S.A. apply all these guidelines and laws, under penalty of tort and / or unethical, and thus suffer legal sanctions arising and / or internal punishment.

It is also commitment of the workforce and all individuals acting on behalf of the company to protect the integrity of FCC SA, reporting violation cases or suspected conduct violation that comes to their attention through the Reporting Channel or, directly to the Ethics Committee.

  

FCC S.A. Reporting Channel
Complaints of violation or suspected violation of conduct and / or tort which comes to your knowledge may be made through the Reporting Channel.

Mail to Fábrica Carioca de Catalisadores S.A. –Nelson da Silva Street, 663, Distrito Industrial de Santa Cruz, Rio de Janeiro – RJ – ZIP CODE 23565-160, in attention to FCC S.A. Ethics Committee

E-mail canaldedenuncias@fccsa.com.br

site www.fccsa.com.br, link Reporting Channel

Dial 0800-9400158. Toll free from anywhere in Brazil, Monday through Friday, from 8am to 6pm.

Schedule a meeting with the Ethics Committee or the Board of FCC SA at (21) 2195-9009.

Related Documents

Anti-Corruption Policy
Commercial Policy
Conflict of Interest Policy
Business Travel Policy
Social Responsibility Policy
Donations and Sponsorship Policy
Third Party Procurement Policy (PCT)

Fábrica Carioca de Catalisadores S.A. is an international technology company that produces and provides solutions in catalysts and additives for the oil refinning industry.

As a joint venture, FCC S.A. joins the tradition and know-how of two world giants of the oil and petrochemical areas – Petrobras and Albemarle Corporation.

@2016 Fábrica Carioca de Catalisadores - Todos os direitos reservados