FAQ
Frequently Asked Questions (FAQ)
What is Constellation's Compliance Program?
Constellation’s Compliance Program consists of a set of ethics and compliance policies and procedures, including the Code of Ethics and Conduct, Anti-Corruption Policy, Gifts, Entertainment, and Hospitality Policy, among other procedures and forms. These are fully aligned with the highest international market standards regarding ethics and compliance.
Which instance is responsible for the Compliance Program?
The instance responsible for the Compliance Program is the Compliance Department, an independent area dedicated exclusively to ethics and compliance issues.
To whom do the Code of Ethics and Conduct and the Anti-Corruption Policy apply?
The Code of Ethics and Conduct and the Anti-Corruption Policy apply to all members of the Board of Directors, Executive Board, executives, employees and everyone who works directly or indirectly for Constellation. The violation of any rule of the Code of Ethics and Conduct or the Anti-Corruption Policy will result in disciplinary measures provided for in the Company’s internal rules, which include dismissal or termination of the legal relationship with the company.
How can I obtain a copy of the Code of Ethics and Conduct and the Anti-Corruption Policy?
The Code of Ethics and Conduct and the Anti-Corruption Policy are available for download to the general public in the “Ethics and Compliance Policies” section, and also on the Ethics and Conduct Channel page, and for Constellation employees, on the company’s Intranet.
What is Constellation's Ethics and Conduct Channel?
The Ethics and Conduct Channel is a channel made available to Constellation employees, suppliers, service providers, regulatory bodies, society and third parties in general to report any violation of the Code of Ethics and Conduct, the Anti-Corruption Policy and applicable legislation, regarding Constellation’s business.
How can I make a report on Constellation's Ethics and Conduct Channel?
Anyone can make a report on the Ethics and Conduct Channel through the following means:
Telephone
Brazil: 0800 721-0765
Panama: 507-8365930
India: 000-800-919-0475
U.S.: 1-800-950-9830
Luxembourg: 800-2-7320
Netherlands: 0-800-022-4886
Internet
Av. Presidente Antonio Carlos, 51 – 5th floor
Rio de Janeiro-RJ – Brazil – 20020-010
Attn.: Compliance Department
Can I make an anonymous report on Constellation's Ethics and Conduct Channel?
Yes, any report can be made anonymously, if so desired by the reporter through the available channels. Reports made in good faith and with responsibility will not subject the whistleblower to any type of retaliation. Reports made in bad faith, with the intentional provision of false information or through fraud are not permitted and may result in sanctions.
Is it possible to follow up on a report filed through Constellation's Ethics and Conduct Channel?
The progress of the report made through the Ethics and Conduct Channel can be followed by the whistleblower themselves, even anonymously. To do so, access the Channel link and enter the protocol generated when the report was made in the “FOLLOW UP REPORT” button or via telephone 0800 721-0765, from Monday to Sunday, 24 hours, simply by providing the protocol number. Furthermore, it is through this follow-up by the whistleblower that new information and evidence may be requested, speeding up the investigation of the report.
Who should I contact if I have any questions regarding ethics and compliance at Constellation?
You should contact the Compliance Department via email compliance@theconstellation.com or by sending a letter to:
Av. Presidente Antonio Carlos, 51 – 5th floor
Rio de Janeiro-RJ – Brazil – 20020-010
Attn.: Compliance Department