Ethics and Compliance

Constellation maintains its relationships based on transparency, ethics, integrity and full compliance with the laws and regulations established in the countries where it operates. Constellation’s principles follow the highest international standards and are a fundamental part of running its business. The Company understands that it is necessary to maintain ethical standards at all levels of its activities, and it is the duty of each employee to perform his duties in a transparent and honest manner.

Ethics and Compliance Policies

Constellation has developed and implemented its policies, procedures and actions in order to ensure compliance with ethical and compliance duties, which have as fundamental pillars the guidelines established in the Code of Ethics and Conduct and in the Anti-Corruption Policy.

Code of Ethics and Conduct – Consists of a behavioral guide intended for all Constellation’s employees aiming at establishing ethical relationships, reducing conflicts and respecting all laws and regulations applicable to the Company’s business.

Anti-Corruption Policy – Establishes guidelines for interactions with public officials and procedures to prevent acts of corruption and fraud prohibited by laws and contrary to ethics and morality. Constellation’s Anti-Corruption Policy incorporates all elements of the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, the Brazilian Anti-Corruption Law (Law No. 12,846 and current regulations) and other anti-corruption laws applicable to your business.

Download our Code of Ethics and Conduct and Anti-Corruption Policy.

Compliance Governance

The Compliance Department is responsible for the Constellation Compliance Program. It is a department exclusively dedicated to issues of ethics and integrity, acting autonomously from the management.

Constellation believes that each employee is responsible for Ethics and Compliance in their activities. In this sense, the Compliance Department, in addition to being responsible for the Compliance Program, also acts as a “facilitator” by promoting the dissemination of Compliance throughout the Company through periodic incentive actions.

Training and Communication

Constellation is committed to disseminating the correct understanding of its Compliance Program and applicable legislation to all its employees. To further this end, the Company has developed the Compliance Training Program, which involves the adoption of teaching practices, awareness raising or case discussions, always according to the target audience, involving:

In-person meetings with selected business areas and audiences, aiming to discuss, raise awareness and teach about specific topics. Through these face-to-face meetings, it is possible to further detail specific issues that affect the selected group, thereby giving greater effectiveness in the dissemination of knowledge about the rules and standards of conduct established by Constellation.

On-line training involves teaching and updating through educational material, including the administration of tests to verify the collaborator's understanding of the material.

Constellation believes that communication is one of the most important tools in the Compliance Program, as it disseminates the culture of Ethics and Compliance throughout the Company at all levels. In this way, Constellation developed a Communication Plan focused exclusively on Ethics and Compliance issues. Through specific and dynamic actions, the Company seeks to keep all employees up to date on internal policies, as well as news and updates regarding Ethics and Compliance, through the use of online platforms, digital media, films and animations.

Ethics and Conduct Channel

The Ethics and Conduct Channel is a channel available to employees, suppliers, service providers, regulators, and the public in general through which they can submit, complaints or reports regarding possible noncompliance with the Company’s policies or any attitude in disagreement with the ethical and compliance principles adopted by the Company. The receipt and any subsequent actions due to any report made in the Ethics and Conduct Channel is handled by a specialized and independent service provider. The analysis of all reported cases is conducted by the Compliance Department, following specific internal policies on the matter.

The Channel of Ethics and Conduct has as its main pillars:

  • Guarantee of anonymity
  • Prohibition of retaliation against the author of the report
  • Autonomy of the body responsible for the analysis of the report
  • Impartiality in the analysis of the report

Complaints and reports could be made through the following means:

  • Phone: 
  • Brazil: 0800 721-0765
  • Panama: 507-8365930
  • India: 000-800-919-0475
  • U.S.: 1-800-950-9830
  • U.K: 44-3308085490
  • Internet: www.canaldeeticaeconduta.com/theconstellation/
  • E-mail: compliance@theconstellation.com
  • Letter: Av. Presidente Antonio Carlos, 51 – 5º andar
    Rio de Janeiro-RJ - Brasil - 20020-010
    At.: Departament of Compliance

 FAQ (Frequently Asked Questions)

What is Constellation’s Compliance Program?

Constellation’s Compliance Program consists of a set of ethics and compliance policies and procedures, including the Code of Ethics and Conduct, Anti-Corruption Policy, Gifts and Entertainment Policy, among other procedures and forms, which are in full alignment with the highest international market standards with respect to ethics and compliance.

Who is responsible for the Compliance Program?

The Compliance Program is administred by the Compliance Department, an independent team dedicated exclusively to ethics and compliance issues.

How can I obtain a copy of the Code of Ethics and Conduct and Anti-Corruption Policy?

The Code of Ethics and Conduct and the Anti-Corruption Policy are available for download to the general public on the website www.theconstellation.com/en/ethicsandcompliance/, under the “Ethics Code” and “Compliance Policies” tabs on the Ethics and Conduct Channel (www.theconstellation.com/en/ethicsandcompliance/), and, for Constellation employees, on the company’s Intranet.

To whom do the Code of Ethics and Conduct and the Anti-Corruption Policy apply?

The Code of Ethics and Conduct and the Anti-Corruption Policy apply to all members of the Board of Directors, officers, managers, employees and all who work directly or indirectly for Constellation. Violation of any rule of the Code of Ethics and Conduct or Anti-Corruption Policy will result in a disciplinary measure provided for in the Company’s internal regulations, which includes dismissal or termination of legal relationship with the company.

What is Constellation’s Ethics and Conduct Channel?

The Ethics and Conduct Channel is a channel made available to Constellation employees, suppliers, service providers, regulators, society and third parties in general to report any violation of the Code of Ethics and Conduct, Anti-Corruption Policy and applicable legislation, with regard to Constellation’s businesses.

How can I make a report on Constellation’s Ethics and Conduct Channel?

Anyone can make a report in the Channel of Ethics and Conduct through the following means:

Phones:

  • Brasil: 0800 721-0765
  • Panama: 507-8365930
  • India: 000-800-919-0475
  • U.S.: 1-800-950-9830
  • U.K: 44-3308085490

Internet: www.canaldeeticaeconduta.com/theconstellation/
E-mail: compliance@theconstellation.com
Letter: Av. Presidente Antonio Carlos, 51 – 5º andar. Rio de Janeiro-RJ. Brasil. 20020-010

Can I make an anonymous report on Constellation’s Ethics and Conduct Channel?

Yes, any report can be made anonymously, if so desired by the rapporteur through the available channels. Bona fide reports will not subject the rapporteur to any type of retaliation. Reports made in bad faith, with the willfully provision of false information or fraud may result in penalties.

Is it possible to follow a report made on Constellation’s Channel of Ethics and Conduct?

The progress of the report made through the Ethics and Conduct Channel can be followed by the rapporteur himself, even anonymously. All you have to do is access the Channel link (www.theconstellation.com/en/ethicsandcompliance/) and enter the protocol generated when the report is made on the “REPORT FOLLOW-UP” button or by calling 0800 721-0765 , from Monday to Friday from 9AM to 5PM, and providing the protocol number. In addition, it is through this action that new information and evidence may be requested to the author of the report, speeding up the investigation of the report.

How is a report in the Constellation Channel of Ethics and Conduct analyzed?

The report is analyzed by the Compliance Department following the procedures established in the Company’s internal policies, specially developed for this purpose. If necessary, a specialized consulting or audit firm may be hired to carry out a specific investigation.

Does Constellation have any guidelines regarding the granting and receiving of gifts, entertainment or hospitality?

 Yes, general guidelines regarding the granting and receipt of gifts, entertainment or hospitality are described in the Anti-Corruption Policy. Specific guidelines regarding this theme are established to all employees through the Gifts and Entertainment Policy.

Who should I contact if I have any questions regarding ethics and compliance at Constellation?

You should contact the Compliance Department at compliance@theconstellation.com or send a letter to:

Av. Presidente Antonio Carlos, 51 – 5º andar
Rio de Janeiro-RJ
Brasil
20020-010
At.: Department of Compliance

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