18
1 Global Compliance initiatives October.2019
1
Global Compliance initiativesOctober.2019
Compliance Milestones 2017
2
Named Marcelo Proença as Global Compliance Director
Establishment of direct reporting to the JBS Board of DirectorsJUN
OCTHired Deloitte to develop a software for automatization of Third Party Due Diligence process
Released the Compliance Program called “Always do it Right”JUL
AUG
Restructured the department, hiring new employees
Launched an outsourced Ethics Line 24/7DEC
Establishment of 7 Ethics Committees, in each Business Unit in Brazil to oversight the Compliance Program and the Ethics Line
Compliance Milestones 2018
3
Approval by the Board of Directors of a new Global Code of Conduct and Ethics and also a
Code of Conduct for Business Associates
MAR
Named Lance Kotschwar as Head of Ethics and Compliance at JBS USA
JBS became a signatory of the Business Pact for Integrity and Against Corruption.This agreement was developed on the initiative of the Ethos Institute.
APR
AUG In-Person Code of Conduct Training for the top management: Board Members, Presidentsand Directors
DEC End of 2018 Training cycle, with more than 115 thousand employees trained on the Code ofConduct guidelines
2018
Compliance Milestones 2019
4
MAR
MAY
AUG
OUT
2019Risk Assessment review for all Business Units in Brazil
Implemented 12 new controls for risk mitigation
Beginning of the Anti-Corruption training in Brazil for 100% of the administrative office employees, including presidents and directors
Beginning of the Code of Conduct Training in Brazil for 100% of the employees (including presidentes/directors)
Compliance Day event held at JBS headquarters in Brazil
JUNEnd of anti-corruption training in Brazil
JULCreation and launch of the JBS Compliance website
Start of third party training project
1
2
3
SET
New communication campaign for the Ethics Line
Carla
MontenegroCoordinator
Jonas
ScalengheCoordinator
Emily KnappManager
Organizational Chart
5
Trainings Due Diligence
José Marcelo M. ProençaGlobal Compliance Director
André DamasoManager
Beatriz
GentilAnalyst
Wanessa
RibeiroAnalyst
Fernanda
BrunoAnalyst
Lance KotschwarHead of Compliance
JBS USA
Board of Directors
Wesley
SouzaAnalyst
Marina
SciglianoAnalyst
Ethics LineCommunication Risk Assessment
Controls
Conflicts of Interest
Tracy EngleAnalyst
TBDAnalyst
TBDAnalyst
Gabriela
MazzettoExecutive Assistant
Valid since May, 2018
In all regions where JBS operates (South America, North America, Europe, Asia)
In two versions – For employees and for third-parties (attached to the contracts)
Documents available at www.jbs.com.br and at JBS Compliance website
New Codes
6
9
Trainings 2018/2019
9
Code of Conduct Training
Anti-corruption training – JBS
Brasil
Administrative office employees
(~17.700)
JBS Brasil
115.200Employees
98,8%
JBS USA
96.500Employees
85,5% Concluded
Pending
Corporate Friboi Seara N.N. Leather SwiftJBS
94% 91,3% 95,8% 98,3% 93,2% 94,8%92,6%
JBS Ethics Line
10
Launched in December, 2017
Available for employees and third-parties 24h/7
Issues reported by allegation type
148 151
184
139152
172
144163 164 163 168
242258
SEP OCT NOV DEC JAN FEV MAR APR MAY JUN JUL AUG SEP
Complaints per month
67%
8%
7%
5%
2%
1%
10%
Behavior (harassment)
Violation of labor laws
Conflict of interest
Fraud/Corruption
Non-compliance with internal
policies and procedures
Leakage or misuse of
confidential information
Other
2018 2019
Ethics Committees
11
Board of DirectorsJBS Ethics
Committee
Friboi Ethics Committee
Seara Ethics Committee
JBS Leather Ethics
CommitteeS
JBS New Business EthicsCommittee
Swift Ethics Committee
Corporate EthicsCommittee
Global Compliance Director
South America
Operations President
Legal Director
Finance Director
BU President (rotating seat)
HR Corporate Director
Compliance
Local HR
Labor Legal
12
Third-Party Analysis (Due Diligences)
Not Recomended by Compliance
81100
77116
46
117156
94
162 148169 166
1988
7
9
11
14
9
10
11
1621
15 16
9
SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP
Monthly analysis
Approved Not recommended
35%
14%
5%
3%
8%
7%
28%
Waste
Intemediaries
Consulting firms
Law firms
Associations
Marketing
Others
13
Communications
July August September
Communications - JBS Ethics Line
Asset misuse Moral Harassment Confidential Information Gifts
Bribe and Corruption Diversity and Inclusion Sexual Harassment Conflict of Interest
14
Controls and Monitoring
16
Preventing corruption through implementation of controls is a key focus of JBS ComplianceProgram
Companies and individuals
blocked (Watch List) Additional Moneymonitored companies and
individuals
Preventive and Detective
Controls
+780 +261 +1MM +12
Direct or indirect
mention in executive
plea-bargain process
+ than 2100 controls evaluated in 2019
Involvement in
suspected non-
compliance actions
(Yellow List)
Limitation of cash in
units. The Compliance
area also monitors any
additional money
requests
Over 12 Controls to
Mitigate Corruption Risks
16
18
Policies and Procedures
Documents that are being reviewed or created
Policies Being Created Status Scope
Due Diligence Under development
Compliance Under development
Existing Policies Status Scope
Anti-bribery and Corruption Under validation
Sponsorships Under review
Donations Published
Conflicts of Interest Signed
Gifts, Entertainment and Hospitality Published
19
01 02 03 04Enhance
Communication
worldwide
Develop a tailor
made training for
specific positions
Enhance Due
Diligence
procedures
Develop global
and local
policies based
on risk
Priorities in 2019
05 Evolution
Assessment of the
Compliance
Program
06 Application for
Compliance
certifications
Stakeholders
20
Example of stakeholders currently monitoring the JBS Compliance Program
Customers
Banking andInsurance
Government / Investors
Auditors and Rating Agencies
