Ethics, Integrity and Compliance
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Minerva Connection – Internal and External Ombudsman
| 2021 | 2022 | 2023 | |
|---|---|---|---|
| Number of reports received | 186 | 241 | 308 |
| Internal Audience | 164 | 195 | 254 |
| External Audience | 22 | 46 | 54 |
Context
Minerva Connection serves as the Company’s dedicated Internal and External Ombudsman channel, tasked with receiving suggestions, commendations, critiques and inquiries, while also providing a platform for reporting any
instances of non-compliance. Through this channel, we strive to combat behavior that contravenes ethical and conduct standards and/or prevailing legislation. The channel is overseen by a third-party company, allowing
individuals to file reports anonymously through various access channels, including telephone, website or email. This ensures complete confidentiality for those who wish to report concerns.
The management of investigations and decisions regarding reports received through the channel is a collaborative effort between the Ethics Committee and its representative (ombudsman/secretary), with oversight from the Statutory Audit Committee.
Training on ethical conduct and integrity by functional category
| 2021 | 2022 | 2023 | |
|---|---|---|---|
| Total % of employees trained | 94,1% | 96.45% | 92% |
| Board | 75,8% | 60.71% | 72% |
| Managers | 100,0% | 96.05% | 90% |
| Coordination, Supervision, Leadership | 92.3% | 95.25% | 91% |
| Administrative | 96.5% | 97.85% | 93% |
| Operational | 90,2% | 96.64% | - |
| Trainees, Interns and Young Apprentices | 98,8% | 95.33% | 92% |
Context
During 2023, employees in administrative sectors and industry leaders at Minerva Foods underwent training on the Code of Ethics – Guide of Conduct, anti-corruption and anti-bribery policies, conflicts of interest prevention and money laundering prevention. To assess the effectiveness of these measures, evaluation exercises were conducted, with a minimum passing score required for approval. Additionally, all employees receive training on these topics during onboarding, along with annual refresher courses.
In alignment with our commitment to transparency and accountability, in terms of communication, we regularly conduct interactive awareness initiatives, incorporating real-life examples on our official channels. These initiatives cover topics related to integrity and compliance, as outlined in the Code of Ethics – Guide of Conduct. Furthermore, these themes are discussed with all audiences at the Company’s internal conventions throughout the year. When it comes to our business partners, we ensure that they are well-formed about our anti-corruption policies and procedures. This is achieved through clauses incorporated into our contract, as well as by communicating the Code of Conduct for Business Partners via purchase orders. In 2023, 2,349 business partners were notified. Of these, 1,423 are part of operations in Brazil and have been communicated through the Business Partner Code of Conduct, while 926 are part of operations in Colombia, including clients, cattle ranchers and other suppliers.
Identified cases of corruption
| 2021 | 2022 | 2023 | |
|---|---|---|---|
| Number of corruption cases investigated and/or in process | - | - | - |
Context
In 2023, there were no confirmed incidents of corruption.
Operations assessed for risks related to corruption
| 2021 | 2022 | 2023 | |
|---|---|---|---|
| % of operations assessed | - | 86 | 33 |
Context
Two operations (Brazil and Colombia) were evaluated for risks related to corruption, accounting for 33.3% compared to the global operation. Although a specific corruption risk matrix has not been developed for each unit, we identify the following risks as significant:
1. Payment of bribes or bribes directly or indirectly, through third parties, to obtain undue advantages;
2. Illegal practices by the Company or third parties related to the Environment, Human Rights and labor;
3. Use of PEPs to obtain undue advantage;
4. Pressure from inspection on the customs process in exchange for undue advantage.
* The indicator started to be reported in the 2022/2023 cycle.
Communication and training about integrity procedures
| 2021 | 2022 | 2023 | |
|---|---|---|---|
| Number of employees enabled for training* | 4,019 | 3,125 | 4,262 |
| Number of employees trained about integrity procedures | 3,781 | 3,014 | 3,919 |
| % of employees trained in anti-corruption policies and procedures | 94 | 96 | 92 |
| % of employees that received anti-corruption communications** | - | - | 100 |
Context
During 2023, employees in administrative sectors and industry leaders at Minerva Foods underwent training on the Code of Ethics – Guide of Conduct, anti-corruption and anti-bribery policies, conflicts of interest prevention and money laundering prevention. To assess the effectiveness of these measures, evaluation exercises were conducted, with a minimum passing score required for approval. Additionally, all employees receive training on these topics during onboarding, along with annual refresher courses.
In alignment with our commitment to transparency and accountability, in terms of communication, we regularly conduct interactive awareness initiatives, incorporating real-life examples on our official channels. These initiatives cover topics related to integrity and compliance, as outlined in the Code of Ethics – Guide of Conduct. Furthermore, these themes are discussed with all audiences at the Company’s internal conventions throughout the year. When it comes to our business partners, we ensure that they are well-formed about our anti-corruption policies and procedures. This is achieved through clauses incorporated into our contract, as well as by communicating the Code of Conduct for Business Partners via purchase orders. In 2023, 2,349 business partners were notified. Of these, 1,423 are part of operations in Brazil and have been communicated through the Business Partner Code of Conduct, while 926 are part of operations in Colombia, including clients, cattle ranchers and other suppliers.
* Corporate employees, employees working at commercial offices and those holding administrative and leadership positions hired until November 2023 are considered qualified. This training was provided online.
** Accounting for our Brazil and Latam divisions as well as our international offices. For the Australian division, data for 2023 is not available. We plan to enhance our management of this topic throughout 2024.