To be on the same page when it comes to the best conduct that governs our daily professional activities, we have created a Code of Conduct. This document, available to everyone at Dexco, guides the way every administrator, employee, the company’s or third parties do business on behalf of the company. It sets the appropriate, desired behaviors to interact with Dexco or its main stakeholders.
Our Compliance department is responsible for disseminating, training, reviewing, and updating our Code of Conduct. Any and every subject connected with it is previously discussed within the Technical Group of our Ethics Commission (Compliance, HR, and Legal Management) and decided by the Ethics Commission, formed by our Managing Director and other members of our Executive Committee. Updates to the Code of Conduct are approved by our Managing Board.
Our Way to Be and Do Things and do business is only one. It is based on integrity, legality, and justice. To that end, Dexco’s Integrity Program is based on:
The Integrity Program is periodically monitored by Compliance and its actions are frequently reported to our Senior Management, through our Audit and Risk Management Committees and Ethics Commission.
Dexco’s Senior Management supports and participates continually and unequivocally in all actions adopted within the scope of the Integrity Program, being periodically updated on how it is being applied and improved across the company.
It is paramount for Dexco to comply with the current law and good corporate governance practices, putting in place practices to prevent fraud, money laundering, corruption, and other unlawful acts.
The company’s main procedures and guidelines are laid out in policies and rules. The business areas are responsible for devising and updating their own rules in order to keep the governance environment up to date. The company takes measures to ensure accurate, precise accounting records and submits its financial statements to periodical audits.
Our Compliance area gives periodical training to administrators and new employees on the Anticorruption Act and other guidelines in our Code of Conduct in order to disseminate the compliance culture and help prevent and fight acts that harm the Public Administration. Throughout the year, guidance and recommendations in compliance and integrity are also released.
Dexco monitors risks and tests controls in its main processes in order to comply with the law and good corporate governance practices.
The company adopts fair, transparent criteria to select and hire suppliers and conducts public inquiries to evaluate related financial, registration, and reputational conditions, as described in our Internal Supply Standards.
Dexco has a channel where reports can be filed including anonymously and confidentially. All reports are looked into and handled confidentially.
The goal of this guide is to formalize the internal mechanisms and procedures of Dexco’s Integrity Program, created based on the Federal Anticorruption Act (Law no. 12,846/2013) and the Federal Anticorruption Decree (Decree no. 8,420/2015), with the purpose of preventing, detecting, and addressing irregularities and unlawful acts committed against the Public Administration, helping strengthen the company’s integrity and transparency culture.
This guide applies to all of Dexco’s departments, its administrator and employees, as well as any third parties that may be hired by Dexco S.A.Integrity Program Guide
Dexco does not make political contributions, in accordance with its Anticorruption Policy, which forbids expenses and donations to candidates or political parties under the applicable law. Other types of government donations can occur exceptionally, provided that they meet the following goals and criteria: (i) fulfillment of all legal requirements and determinations; (ii) preservation of public assets/services directly affected by the company’s operational activities upon technical justification of the requesting administration; and (iii) supporting causes that resonate with the company’s activities and/or values. In any of the aforementioned exceptions, the donation shall observe the provisions under the Donation Rules, meet all mandatory formal requirements (e.g. official notice), and be subject to prior analysis and favorable opinion of the Compliance department, in addition to the approval of Dexco’s Managing Board and President.
In order to contribute to the government in the creation of public policies that promote business and the social environment, in 2020 Dexco created an Institutional and Governmental Relations area, responsible for representing the Company’s discourse in the legislative process (federal, state and municipal) . This department works mainly in conjunction with reputable sector entities to which the Company is affiliated (eg IBÁ, CIESP, ABINEE, ANFACER, among others), ensuring an impersonal and transparent political action, always guided by ethical, moral standards and in accordance with Laws and Dexco’s Anti-Corruption Policy. To learn about the actions carried out in 2022, click here.
Dexco, in line with its commitment to comply with applicable laws, including the Personal Data Protection General Law – Lei Geral de Proteção de Dados Pessoais (LGPD), has formally appointed the person who acts as Data Officer in its Privacy Governance Structure.
The Data Officer, or DPO (Data Protection Officer), is a person indicated to act as a communication channel between the Controller (Dexco), the Data Holders (natural persons to whom the processed personal data refer to) and the Data Protection National Authority – Autoridade Nacional de Proteção de Dados (ANPD – public administration body responsible for ensuring, implementing and monitoring compliance with the LGPD throughout the national territory).
According to the LGPD, Dexco must appoint a person in charge of personal data processing, who performs the following activities:
I – to accept complaints and communications from the data holders, provide explanations and take measures;
II – to receive communications from the national authority and adopt measures
III – to guide the entity’s employees and contractors regarding the practices to be taken in relation to personal data protection; and
IV – to perform other duties determined by the controller or established in complementary rules.
At Dexco, the DPO role is performed by the employee André Villamar Pinho. André currently works at Dexco as Data & Analytics Manager and also acts as DPO.
It is important to highlight that DPO has the Privacy Governance Structure and the Privacy and Data Protection and Privacy Commission support, to carry out his activities, with an independent reporting line to the Risk Management and Audit Committee – Comitê de Auditoria e Gerenciamento de Riscos (CAGR).
Follow below DPO’s identity and contact information:
Name: André Villamar Pinho
Area: Data & Analytics
Position: Data & Analytics Manager
Contact Channels: firstname.lastname@example.org | email@example.com