JSL COMPLIANCE

In line with the best governance practices and with the guidelines of the General Controllership of the Union, the Program is structured based on pillars that aim to guarantee proper mechanisms and procedures to the Company’s structure.

The Company’s Compliance Program, which applies to all companies controlled by it, aims to prevent, detect and remedy the occurrence of deviations, fraud, irregularities and illegal acts, especially in the public environment, as well as strengthening ethical principles and transparency standards.

JSL’s Code of Conduct applies to everyone who has any connection and relationship with the company. It is composed of a set of guidelines that portray our values and that should guide performance. The topics addressed in the Code of Conduct include, among others: (i) compliance with laws and regulations; (ii) human rights; (iii) employment relationships; (iv) employee conduct; (v) combating corruption; (vi) conflict of interest; (vii) donations and sponsorships; (viii) gifts, presents, entertainment and hospitality; (ix) relations with the external environment; (x) non-compliance and disciplinary measures; and (xi) whistleblowing channel.

The Whistleblower Channel operates 24 (twenty-four) hours a day and 7 (seven) days a week, and the whistleblower is given the possibility to formalize his complaint through the following communication channels: telephone, website and e-mail, all managed exclusively by a third-party company. Anonymity is guaranteed to the whistleblower in good faith, as well as the possibility of monitoring the handling of the claim, independently, by means of a protocol number.

Telephone: 0800 726 7111
Website: contatoseguro.com.br/jsl

It is a free channel designed to answer questions and seek guidance on topics related to the Compliance Program, Code of Conduct, Anti-Corruption Policies and other internal JSL rules. It is accessible to the internal and external public, from Monday to Friday, from 8 am to 5:48 pm.

Telephone: 0800 726 7250
E-mail: [email protected]

JSL’s Anti-Corruption Policy encompasses a set of Policies that we understand as essential for the effective fight against corruption, they are:

–  Policy of Interaction with the Public Power;
– Bidding Participation Policy;
– Donation and Sponsorship Polic;
– Gifts, Entertainment and Hospitality Policy.

The Risk Management Policy describes the steps of the management process for (i) identification of risk events, (ii) instruments used for risk management, (iii) organizational structure for risk management and (iv) the responsibilities of each of those involved, establishing limits for responsibilities according to the levels of risk identified.

The risk management practices adopted by the Company are reviewed annually and/or whenever necessary by the Internal Controls, Risks and Compliance Area.

In respect of your privacy and the security of your information, we have updated our Privacy Notice, in order to provide even more clarity and transparency on how the companies of the JSL Group process your personal data.

What does the JSL Group Privacy Notice say?

• How do we access your information?
• What personal data is processed and why we need it;
• In which situations we may share your information;
• How we protect your personal data;
• What are your rights and how to exercise them.
• This Privacy Notice meets the requirements set out in the General Data Protection Law and reflects the position of the Vamos Group to always comply with the regulations to which we are subject.

To make requests for the exercise of rights or to answer any questions, feel free to contact directly our Person in Charge of the Processing of Personal Data through the channel
[email protected]