OEC - Odebrecht Engineering & Construction has gone through a transformation. In 2016, the company undertook a commitment to improve its governance, starting a new era in which business actions fully meet the highest international standards of management and transparency.
The company has changed its internal processes and procedures, established new policies and evolved its Compliance Program. Tasks that are indispensable in this new transparency era that society demands and which demonstrates the entrepreneurial maturity that the OEC has gone through.
To guide the behavior and actions of all OEC team members, a Compliance Policy was approved in February 2017. It is a solid and comprehensive document with detailed rules on how members should behave in their relations with each other and with Shareholders, Clients, Suppliers, Competitors, Governments, Communities and society in general.
It is a more modern proposition that responds to society’s most current issues, with detailed guidelines on anticorruption practices, money-laundering, conflicts of interest, relationship with suppliers and shareholders, among others. These are clear and objective rules that leave no room for doubt when an employee makes a decision.
The current Compliance System is based on the most recognized international benchmarks and was conceived as an instrument that ensures that OEC and all its subsidiaries companies and employees act in an ethical, reputable and transparent manner. It consists in ten integrated measures to prevent, detect and remedy non-compliance risks.
Six of ten elements are related to prevention measures because prevention is always better and less expensive than to remediate a non- compliance matter.
However, no matter how good prevention is, it may not be enough to eliminate all risks. That’s why there are measures in place for detection and remediation. Once an exposure to risk or a non-compliance situation is detected, it must be quickly addressed in accordance with its nature and severity. The 10 elements of the system are detailed below.
Governance
- To increase the number of independent advisers, guaranteeing a minimum of 20% independent members (and no less than two participants with this characteristic).
- Creation of Ethics Committee and Compliance and Internal Audit Committees which reports to the Board of Directors.
- Hiring of a senior Chief Compliance Officer with experience and independence guaranteed by reporting to the Board of Directors of OEC.
Policies and Guidelines
- Implementation of 11 Compliance Guidelines, 11 Financial Guidelines, one for Internal Audit, one Instruction on Management of New Businesses (Pipeline), one Guideline of Supplies and six others for Planning & People, including the topic Conflicts of Interest.
Independent instruments to fight against corruption
- Ethics Line Channel: instrument aimed to receive reports and complaints of inappropriate behavior and violations of Internal Policies, Guidelines, rules and /or legislation. The channel is managed in a confidential and independent manner and the assessments are conducted in a confidential and impartial way. Ensuring confidentiality, anonymously and prohibition against retaliation.
- Third Party Due Diligence: implemented in 2017, the Due Diligence process is a prerequisite for starting any business relationship with third parties (suppliers, service providers, potential partners and customers). Analysis is conducted independently by the Compliance team with the support of a specialized international company.
Evaluation, control and monitor risks
- Internal Audit: annual Audit Plan for projects, construction works, and offices is approved by the OEC Board of Directors.
- Continuous Monitoring: a series of financial indicators - including all items transacted in the financial system databases and other corporate systems - are monitored.
- Core Compliance: evaluation and systematic follow-up of key-process of the Compliance System based on objective indicators that allows to test the operation of the implemented rules. Effective fulfillment and achievement of compliance indicators and goals is an important part of the Member's performance evaluation.
Information, training and advice at all levels to ensure commitment to ethics, integrity and transparency of members. Focus on high and middle leadership in key roles (leadership, finance, legal, compliance and business development).
To support the implementation of compliance actions, each country where the OEC operates has a Compliance Focal Point acting as an interface between the Compliance team and operational teams.
In addition to the focal point of compliance, each active work site has a multiplier, responsible for the dissemination of the theme locally.
Recognizing the need to change the environment in which OEC operates, the company understands its responsibility for this change and contributes with knowledge and know-how as a result of our transformation journey.
Therefore, it participates in public debates and business commitments to strengthen the culture of integrity, serving as an example of transformation and promoting new ethical and transparent external initiatives, such as:
- Observ Institute: supported the creation of the open access online platform to give transparency and to monitor public bidding processes for governmental construction contracts.
- Adherence to the Business Pact for Integrity and Transparency, of the Ethos Institute.
- Active participation in Anti-corruption Seminars in Brazil, United States, Angola, Peru, Panama, Ecuador and Colombia.
- WCA Engagement - World Compliance Association in Angola and Panama.
Odebrecht Commitment introduces the 10 principles undertaken by the Group to fight and not tolerate corruption in any of its forms when conducting its Business. It is aligned with the Odebrecht Entrepreneurial Technology and must be practiced in a responsible manner in all areas of work, without any exceptions.
Following are the 10 points of the Odebrecht Commitment:
The Ethics Line is an exclusive and confidential channel for safe and, if desired, anonymous communication about behavior considered unethical or that violate OEC – Odebrecht Engineering & Construction’s Policy on Compliance in Acting Ethically with Integrity and Transparency and/or any policy, guideline, internal regulation and/or current legislation.