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Compliance

At Melnick, we act ethically, seriously and transparently, where respect is valued in all our relationships, actions and decisions. Our Compliance approach is integrated, and the Compliance area works closely with the Legal Department and Risk Management to ensure compliance with the Company's internal integrity procedures. This dedication is formalized in the Code of Conduct and the Risk Management Policy, reinforcing a culture of excellence in management, control and governance.

Under the direct leadership of the CEO, Leandro Melnick, the Compliance area reports periodically to the Company's Audit Committee, which is responsible for supervising the independence of the area's work and may, at its sole discretion, seek independent opinions on compliance issues. The Compliance area conducts investigations into possible breaches of integrity, ensuring that the Company's Code of Conduct is applied and adhered to In cases of suspected fraud, bribery or corruption, the area is responsible for conducting investigations in a confidential and impartial manner, regularly reporting progress to the Audit Committee. A summary of these activities is presented by the Audit Committee to the Council of Administrations at its quarterly meetings.

In addition, the Company has a Conduct Committee, a collegiate advisory body to the Council of Administrations, to whom it reports directly, and is composed of three members, (i) Manager of the Human Resources area; (ii) Manager of the Legal area; and (iii) Manager of the Company's Risk Management and Compliance area. The Conduct Committee has subsidiary powers to supervise investigative activities in the Risk Management and Compliance area that do not fall within the remit of the Audit Committee, as well as to draw up a communication and training plan related to the Integrity Program and ensure compliance.

Ethics Channel

The Ethics Channel was created to register doubts, suggestions about the Code of Conduct or behaviors that are not in line with Melnick's culture or values. Contact is made through Contato Seguro, an outsourced company that guarantees the confidentiality of information and does not identify the sender under any circumstances.

To get in touch, call 0800 800 2929, available 24/7, or visit www.contatoseguro.com.br/melnick. If you identify or suspect any misconduct, please contact us by phone or via the website to report, suggest or clarify questions about our Code of Conduct.

All incidents are forwarded to our compliance team for investigation. Once confirmed, they are evaluated by the conduct committee, which will take the necessary measures. We guarantee a response to all records, available on the Channel.

At the same time, we have an Ethics Channel Policy, which establishes guidelines and procedures related to the Company's Ethics Channel and for investigating reports sent to this Channel.

Code of Conduct

In our Code of Conduct we consolidate the principles, guidelines, rules of behavior and conduct expected of all employees, for the continuous and sustainable growth of our business, maintaining the quality of our products and the satisfaction of our customers.

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Third Party Code of Conduct

In the Third Party Code of Conduct, we present the behaviors and rules that our suppliers must follow, in line with Melnick's values and commitment to acting ethically and transparently.

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Check out the policies related to the Compliance area:

Privacy Policy

Melnick is concerned with keeping the data and privacy of the parties with whom it has dealings safe. To this end, we have created a Data Privacy Policy which, in compliance with the Brazilian General Data Protection Law, aims to guide and establish guidelines on the processing of all data.

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Anti-Corruption Policy

Establishes guidelines and procedures related to combating corruption, money laundering and terrorist financing and ensuring that all members of the Company and those acting on its behalf understand and act in compliance with applicable legislation.

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Gifts Policy

Establishes guidelines and procedures related to gifts, presents, hospitality and entertainment for the Company and its subsidiaries.

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Donations Policy

Establishes procedures and rules that must be followed when making political and/or philanthropic donations and/or contributions, as well as sponsorships, guaranteeing transparency, integrity and compliance with the law.

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Relationship Policy

It establishes guidelines for maintaining a relationship of integrity, transparency and compliance with the law.

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Due Diligence Policy

Establishes the criteria for classifying risks and evaluating suppliers, service providers and business partners who interact with Melnick so that they adhere to the precepts of the Code of Conduct and current laws. The main objective is to assess and measure the risks of non-compliance related to reputation and integrity in Melnick's relationship with suppliers, service providers and any other business partners of any kind.

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