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The Sustainable Integrity Program (PIS) has as its mission to increasingly strengthen the ethical posture and absolute integrity that guides our attitudes and values.

PIS is one of the pillars of the Solví Entrepreneurship Model (MES). All Solví Group Programs are based on PIS and respect its premises and guidelines.

The success of PIS depends heavily on the commitment and promotion carried out by the Board of Directors and the Board of Directors.

The Board of Directors works in partnership with the Investment, Personnel and Safety, Conduct and Risk and Audit Committees of the Solví Group, especially to assist in monitoring PIS.

The success of PIS is also achieved through the exclusive dedication of the Legal and Compliance Department, supported by the Integrity Commission and Integrity Agents in each business of the Solví Group, which aim to strengthen integrity and mitigate identified risks.

INTEGRITY

Ethics and integrity
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Political contributions
PIS structure
Bribery and corruption
Whistleblower protection

pis structure

The PIS is structured around a set of elements aimed at preventing, detecting and responding to any breaches of our Code of Conduct, our Policies, Procedures and current legislation.

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Commitment of Senior Management

Risk assessment

Code of Conduct, Policies and Procedures

Communication and Training

Monitoring and Auditing

Due Diligence Activities

Complaints Channel

Bribery and Corruption

Our Anti-Corruption Policy (edited in 2015), as well as the Code of Conduct and Compliance Policies (revised in June/2020) internally reaffirm to public agents and other stakeholders the commitment of the entire Group to an ethical and integrity posture, our code and policies are approved by a management committee and can be accessed on the company's institutional website (www.solvi.com).

 

The Conduct Committee follows up and monitors the implementation of the code of conduct progress, proposing actions aimed at strengthening and developing conscience and ethical conduct. Issues that arrive via the Integrity Channel or that have been identified by internal means, involving ethical values and conduct of the Group's companies, violations committed by employees, suppliers and service providers, are dealt with based on the Consequence Management Policy of the Solví Group.

 

Broad impact issues are submitted by the Conduct Committee to the Board for deliberation. Any report that reveals evidence of corrupt practices and bribery in all its forms is treated with the sense of urgency that the case demands and with the effective positioning of the top management in its treatment.As part of the work carried out, we highlight that there were no confirmed cases of corruption in the period, nor any lawsuit related to the topic against the organization and its employees.

Political Contributions

The topic "Relationship with the Government" is addressed in the Group's Conflict of Interest Policy, an internal document, and in items 8.4 and 8.5 of our code of conduct, establishing special care and mechanisms to mitigate the risks of this issue, reinforcing the duty to act impersonally, honestly and professionally. If the employee starts to have a situation of Conflict of Interest, previously non-existent, he must immediately communicate it, using the Conflict of Interest Declaration Form, so that the company can monitor and eliminate possible risks.

 

Solví respects the right of its employees to exercise political activities, but reinforces that electoral donations and party affiliations must not put the Company at risk. It should be noted that any political donation on behalf of Solví is strictly prohibited, as is the practice of any political or electoral activity in its name and/or on its premises and facilities.

 

Managers, administrators and employees must be guided by the Donation and Sponsorship Policy, in order to prevent electoral donations or party affiliations from being interpreted as a way of obtaining undue benefits on behalf of the company. Directors, administrators and employees must follow the Conflict of Interest Policy, avoiding conflicts between the interests of the business and their personal interests.

Whistleblower protection

Grupo Solví guarantees the confidentiality of reports, and no adverse action is taken against a whistleblower in good faith, prohibiting any retaliatory measures against the whistleblower and those responsible for investigating the reports. The guidelines are provided for in the Code of Conduct - Chapter 14 and reinforced on the Whistleblower Channel website.

Do you know the role of the Data Officer – DPO General Law for the Protection of Personal Data (LGPD)?

 

The DPO (Data Protection Officer), also known as the Person in Charge of Personal Data, is primarily responsible for maintaining organizations; compliance with the LGPD, being considered the guardian of the Privacy Governance Program. At Solví Group we have a professional from the Compliance team who plays this role and the contact channel.

Contact: dpo@solvi.com

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