Ethics and Compliance Policies
Constellation has developed and implemented its policies, procedures and actions in order to ensure compliance with ethical duties, which have the guidelines established in the Code of Ethics and Conduct and in the Anti-Corruption Policy as their key pillars.
Code of Ethics and Conduct
Consists of a behavioral guide intended for all Constellation’s employees aiming at establishing ethical relationships, reducing conflicts and respecting all laws and regulations applicable to the Company’s business.
Anti-Corruption Policy
Establishes guidelines for interactions with public officials and procedures to prevent acts of corruption and fraud prohibited by laws and contrary to ethics and morality. Constellation’s Anti-Corruption Policy incorporates all elements of the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, the Brazilian Anti-Corruption Law (Law No. 12,846 and current regulations) and other anti-corruption laws applicable to your business.
Download our:
Compliance Governance
The Compliance Department is responsible for Constellation’s Compliance Program. The department is exclusively dedicated to issues of ethics and integrity, acting autonomously.
Constellation believes that each employee is responsible for Ethics and Compliance in their activities. In this sense, the Compliance Department, in addition to being responsible for the Compliance Program, also acts as a “facilitator” by promoting the dissemination of Compliance throughout the Company through periodic incentive actions.
Training and Communication
Constellation is committed to disseminating the correct understanding of its Compliance Program and applicable legislation to all its employees. To further this end, the Company has developed the Compliance Training Program, which involves the adoption of teaching practices, awareness raising or case discussions, always according to the target audience, involving:
In-person meetings with selected business areas and audiences, aiming to discuss, raise awareness and teach about specific topics. Through these face-to-face meetings, it is possible to further detail specific issues that affect the selected group, thereby giving greater effectiveness in the dissemination of knowledge about the rules and standards of conduct established by Constellation.
Online training involves teaching and updating through educational material, including the administration of tests to verify the employee's understanding of the content.
Constellation believes that communication is one of the most important tools in the Compliance Program, as it disseminates the culture of Ethics and Compliance throughout the Company at all levels. In this way, Constellation developed a Communication Plan focused exclusively on Ethics and Compliance issues. Through specific and dynamic actions, the Company seeks to keep all employees up to date on internal policies, as well as news and updates regarding Ethics and Compliance, through the use of online platforms, digital media, films and animations.
Ethics and Conduct Channel
The Ethics and Conduct Channel available to employees, suppliers, service providers, regulators, and the general public through which they can submit complaints or reports regarding possible noncompliance with the Company’s policies or any attitude in disagreement with the ethical and compliance principles adopted by the Company. The receipt and any subsequent actions due to any report made in the Ethics and Conduct Channel is handled by a specialized and independent service provider. The analysis of all reported cases is conducted by the Compliance Department, following specific internal policies on the matter.
The Channel of Ethics and Conduct main pillars are:
- Guarantee of anonymity
- Prohibition of retaliation against the author of the report
- Autonomy of the body responsible for the analysis of the report
- Impartiality in the analysis of the report
Complaints and reports can be made through the following means:
Phone
Brazil: 0800 721-0765
Panama: 507-8365930
India: 000-800-919-0475
U.S.: 1-800-950-9830
Luxemburg: 800-2-7320
Netherlands: 0-800-022-4886
Internet
www.canaldeeticaeconduta.com/theconstellation
compliance@theconstellation.com
Letter
Av. Presidente Antonio Carlos, 51 – 5º andar
Rio de Janeiro-RJ - Brasil - 20020-010
At.: Departamento de Compliance
Personal Data Privacy and Protection
Constellation is aware of the importance in protecting your privacy and your personal data in control of the company. The Data Protection Officer (DPO) is responsible for guiding the employees and implementing the communication with data holders (personal data subject) and with the competent authorities, as well as for maintaining adequate processes and procedures of the company, organizing trainings and encouraging a truly truthful data protection culture.
The DPO is the company's main communication channel about anything related to data privacy and protection and can be contacted through the e-mail DPO@theconstellation.com
Personal Data Privacy and Protection Portal
Constellation has a Portal where personal data subjects (holders) are able to exercise their rights. On the Portal, it is also possible to report any incident of personal data, known or suspected, in the context of Constellation's activities. The anonymous option is available for those who opt for no personal identification during the report.
Click here to access the portal.