COMPLIANCE
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INTEGRITY
The concept of integrity is directly linked to the set of actions and decisions focused on honesty, and opposed to corruption, demonstrating values and ethical conduct that can be used as an example.
COMPANY PRESENTATION
DH Transportes, logísticas, Comércio, Locações e Empreendimentos Ltda. has been operating in the transport market since 2015, seeking to offer a range of services and facilities in all existing transport modes.
In its service scopes, the following stand out: Mooring and Unmooring Support Services, Opening and Closing of Containment Barriers and Support for Emergency Response Centers and Maritime and Port Support Services. Safety Inspection Services and Operational Monitoring of Bunker Vessels.
DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda. has a serious and defined mission, committed to modernity and business evolution, seeking the satisfaction of its customers and for this it holds Certification in the three main management standards (ISO 9001:2015, ISO 14001:2015 and ISO 45001:2018).
COMPLIANCE
Mission and Vision
Conduct sustainable and economically viable businesses;
Maintain customer focus;
Respect society;
Take ecologically correct actions.
COMPLIANCE
Principles and values
Respect for life;
Responsible Entrepreneurship;
Ethics;
Valuing people;
Transparency in all its operations.
ANTI-CORRUPTION LEGISLATION
FEDERAL LAW NO. 12,846, OF 08.01.2013 (ANTI-CORRUPTION LAW),
FEDERAL DECREE NO. 8,420, OF 03.18.2015, WHICH REGULATES THE ANTI-CORRUPTION LAW AND PROVIDES FOR THE INTEGRITY PROGRAM;
FEDERAL LAW NO. 9,613, OF 03.03.1998, WHICH PROVIDES FOR THE CRIMES OF "WASHING" OR CONCEALMENT OF ASSETS, RIGHTS AND VALUES;
FEDERAL LAW NO. 12,683, OF 07.09.2012, WHICH AMENDED LAW NO. 9,613, OF 03.03.1998, TO MAKE CRIMINAL PROSECUTION OF "MONEY LAUNDERING" CRIMES MORE EFFICIENT;
FEDERAL DECREE-LAW NO. 2,848, OF 12.07.1940 (BRAZILIAN PENAL CODE),
FEDERAL LAW NO. 8,429, OF 06.02.1992 (ADMINISTRATIVE MISCONDUCT LAW), PUBLIC OR FOUNDATIONAL;
INTEGRITY PROGRAM
With this concern, DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda., aims to incessantly seek the promotion of a productive work environment, focusing on the sustainability of its processes, establishing through its senior management an integrity program to conduct its business ethically, adopting measures against corruption and fraud, as well as standardizing control and corrective actions against potential acts against its integrity.
Thus, and in compliance with the Anti-Corruption Law, DH Transportes defines that its integrity program is intended for all its employees, including senior management, administrative and operational staff, contractors, clients, suppliers, public authorities, society, and other stakeholders.
Based on its basic principles, the integrity program also functions to fully meet its faithful definition, according to Decree No. 8,420/2015, which defined in its Art. 41 what an Integrity Program is:
"An integrity program consists, within a legal entity, of a set of internal mechanisms and procedures for integrity, auditing, and encouraging the reporting of irregularities, and the effective application of codes of ethics and conduct, policies, and guidelines aimed at detecting and remedying deviations, fraud, irregularities, and illicit acts committed against public administration, domestic or foreign."
According to the 'Manual for the Implementation of Integrity Programs - guidelines for the public sector', published by the Ministry of Transparency and the Office of the Comptroller General, the integrity program must:
"An integrity program is a specific 'Compliance' program for the prevention, detection, and remediation of harmful acts provided for in Law 12,846/2013, which focuses not only on the occurrence of bribery but also on fraud in bidding processes and the execution of contracts with the public sector."
PILLARS OF THE INTEGRITY PROGRAM
The integrity program advocates for the adoption of five basic pillars to compose its structure, these pillars are:
Senior management commitment and support;
Entity responsible for the integrity plan;
Profile and risk analysis;
Structuring of rules and instruments;
Continuous monitoring strategies.
SENIOR MANAGEMENT COMMITMENT AND SUPPORT
DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda. understands that for the full compliance of its integrity program, senior management must be aligned with the objectives. Therefore, it defines that its board of directors is committed to acting in an ethical and transparent manner throughout all stages of contract management. In all interactions with employees, management incorporates the premises of this program into its speeches and meetings, in addition to encouraging training and maintaining active participation. To guarantee implementation, the company's senior management allocates personal, material, and financial infrastructure resources during the program's implementation and monitoring stages.
CODE OF CONDUCT AND ETHICS
DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda. defines essential guidelines for the proper conduct of activities through a code of conduct and ethics. It is important to highlight that the code of conduct and ethics is provided to all employees upon hiring and is disseminated throughout the company's premises. Thus, it defines:
- Comply with and enforce labor legislation;
- Comply with occupational health and safety standards, adopting the motto: do it safely or don't do it;
- Respect and preserve the environment by complying with local, state, and national environmental legislation, applying methods with controlled socio-environmental impacts, and through the personal attitude of each company member;
- Promote business and employee performance based solely on competence and effort, not accepting privileges through illegal payments or receipts;
- Remunerate employees so that they receive their earnings based only on professional criteria, thus enabling equality for positions, functions, and experiences, regardless of gender, orientations, and personal preferences;
- Do not tolerate the practice of any type of discrimination, whether based on race, culture, religious orientation, gender, social origin, or others that may be defined;
- Do not tolerate, under any circumstances, any type of harassment;
- Require partner companies to follow the same conduct expressed in this code, through contractual instruments and compliance with legislation.
- Define that in case of violation of this code of conduct and ethics, all employees are subject to disciplinary penalties in accordance with this company's disciplinary penalty procedure.
ENTITY RESPONSIBLE FOR THE INTEGRITY PLAN
DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda., through its senior management, has decided to define the Administrative Management, together with the HSE (Health, Safety, and Environment) department, as the internal entity responsible for developing, applying, and monitoring the integrity program. The HSE area is responsible for conducting the trainings defined in the annual schedule to seek the development and improvement of the integrity plan, and defines the administrative management as the entity responsible for the evaluation, provided with the necessary resources for its complete fulfillment.
The internal responsible entity has the duty to ensure that signs of irregularities are effectively investigated, even when involving members of senior management.
In view of the above, DH Transportes defines that the protection of this entity will be ensured, as well as that of other employees against arbitrary punishments resulting from their actions.
FRAUD AND CORRUPTION RISK MANAGEMENT
Risk management is a control tool adopted in various organizational spheres, used to implement preventive and corrective measures to ensure operational, commercial, and administrative excellence. Potential impacts are evaluated from financial, operational, and brand image perspectives.
The administrative management is responsible for mapping risks and establishing the necessary measures for their full addressment, including assessment, identification, prioritization, and actions to be taken.
The business risks of DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda. can be defined as:
Strategic risks
Market risks
Operational risks
Compliance risks
CONTROL AND MONITORING
To ensure compliance with the Integrity Program, DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda. maintains performance indicators (KPIs), which are periodically evaluated and analyzed annually during critical analysis meetings in conjunction with the company's other departments.
Following the critical evaluation of these indicators, the company decides whether to maintain or adopt new goals or indicators, aiming for the best performance of company processes based on the established principles and values.
CONTROLS AND RESTRICTIONS
Conflict of Interest: In cases of conflict of interest or violation of ethical conduct, the employee must bring the fact to the attention of their immediate management and recuse themselves from further decisions.
It is important to emphasize that the use and disclosure of internal information to guarantee personal benefit or that of third parties is strictly prohibited. All employees are forbidden from acting as a consultant or facilitator on behalf of DH Transportes.
As restrictive measures, the following are defined:
- Restrict the offering of gifts to clients and commercial partners, allowing only gifts considered to have no commercial value, such as planners, notebooks, pens, mugs, and other items in this category.
- Make donations to charitable institutions or social projects only with express authorization and legal compliance.
PROHIBITIONS
In compliance with this integrity program, DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda. establishes and defines the following prohibitions:
Payment or benefit to any government authority, domestic or foreign, to obtain or retain business, or any commercial advantage;
Prohibition on offering gifts, presents, and hospitality to public agents.
Donations and/or contributions to charitable institutions, social projects, and political parties;
RELATIONSHIP WITH THIRD PARTIES
Supplier Management is a critical factor for the success of the procurement process for goods, services, and products.
With features that assist in the technical and commercial qualification of suppliers, this solution facilitates decision-making in choosing suppliers that can provide the lowest total cost of acquisition, taking into account financial issues as well as environmental aspects, occupational health and safety, and quality.
Following the definition and evaluation of suppliers, DH Transportes requires its suppliers to acknowledge and sign the company's code of ethics and conduct, thus formalizing the hiring and qualification of its suppliers.
COMMUNICATION CHANNELS
DH Transportes, Logísticas, Comércio, Locações e Empreendimentos Ltda. defines its communication channels established on its website:
The Reporting Channels are:
E-mail: paulo@grupodh.net.br
Telephone: 55 (21) 2137-2268 /
21 97104-1718
