Ethics and integrity

GRI 102-16, 103-1, 103-2, 103-3, 205-1, 205-2, 205-3

As a federal concession, with operations in three federal states and interference in 107 municipalities, MRS has a relevant concern regarding the implementation and compliance with anti-corruption practices. To this end, it has maintained the Integrity Program since 2017, which includes policies of conduct and anti-corruption standards to be adhered to by all employees in their daily practices and in relationships with stakeholders, both internal and external.

The Program includes the following codes, policies and Guidebook:

  • Code of Ethical Conduct: Last updated in 2017, it deals with the principles that should guide the conduct of employees and third parties, in addition to the consequences for any violations.
  • Ethical Conduct for Third Parties: It highlights the values that third parties (including suppliers) should follow to maintain an ethical culture.
  • Governmental Relations and Anti-Corruption Policy: It establishes general guidelines and policies of conduct for the relationship of MRS and its employees with government agencies and entities.
  • Gift and Ammenities Policy: It establishes general guidelines for MRS employees in relation to gifts, ammenities or any kind of return made by/for suppliers, customers or any third parties.
  • Sponsorship and Donation Policy: It establishes guidelines and policies on sponsorships and donations to guide MRS employees, as well as suppliers, customers, and other third parties.
  • Conflict of Interest Policy: It establishes guidelines for MRS employees in relation to potential situations that constitute conflict of interest.
  • Health, Safety and Environment Policy: It establishes guidelines on MRS standards in relation to Occupational Health, Safety and Environment (HSE).
  • MRS Ethics and Integrity Program Guidebook: Objective guide for MRS Logística employees to understand and apply the best practices in the relationship with third parties, especially public officials, with points of special attention from the Code of Ethical Conduct and the Policies of Conduct that make up the Company’s Ethics and Integrity Program.

In the Internal Audit work on the risk-based Annual Plan, no significant probability of corruption risks was identified. In 2019, the General Legal Management applied a questionnaire about corruption-related risks for the areas with the highest exposure to contact with government agencies. The result indicated that although substantial impacts are possible if corruption cases involving MRS and public agencies occur, the probability that they will actually occur is low.

The Company understands that issues related to Ethics and Security are extremely relevant. In a continuous search for the best market practices, MRS frequently performs benchmarking actions. One of the main ones is a discussion group on Audit and Compliance topics led by Vale, with its main investees (MRS, MRN, Samarco and VLi). Communication campaigns are planned for employees in 2021 with a focus on Ethics and attitudes desirable by the Company.

Training to fight corruption

At MRS, 100% of the members of the Statutory Board were trained in the fight against corruption under the Ethics and Integrity Program. At the Program launching, in 2017, on-site training for managers was carried out, with the attendance of 78% of the target audience. In 2018, training was also focused on managers, including Executive Officers. In 2019, the MRS Leadership Program training was carried out, aimed to train future managers, with 100% attendance. 

All new hires are trained on the Ethics and Integrity Program on the onboarding day. In addition, MRS provides through the MRS Academy an online training course on the theme, which is a prerequisite for participation in all other courses. Of the 5,851 Company’s employees, 86% have already undergone this training. Learn more on MRS Academy and the training available in Employees.

Internal audit

MRS follows its own methodology in the work of Internal Audit, Corporate Risk Management, Continuous Audit and Reporting of Complaints. The corruption-related risk is considered and is included in the Company’s Risk Dictionary as “Risk of Unethical Conduct/Fraud”.

MRS Internal Auditing practice is certified with QA (Quality Assurance) by IIA (Institute of Internal Auditors).  All activities not related to traditional auditing (continuous auditing, reporting channel and corporate risks) undergo external inspection every two years. For 2021, the budget for the external assessment has already been approved.  As a means of measurement, the status of the assessments is submitted on a qurterly basis to the Sustainability Committee and the Board of Directors.

In 2020, 14 works were carried out in distinct MRS processes, selected by priority of risks, in addition to two recurring works of Continuous Audit and analysis of 146 complaints regarding ethical deviations, complaints and non-compliance, raising no points in relation to this specific risk.

MRS was not notified of fines for non-compliance with laws and/or regulations in the social and economic area during 2020.

GRI 419-1

Reporting Channel works as a risk control mechanism

The Audit Hot Line is a communication channel of MRS, through which questions and complaints are received, working as a control mechanism for risks to which the Company is exposed, and for addressing unethical or illegal conduct that may occur.

Complaints can be submitted anonymously, through telephone, internet and intranet, and confidentiality is guaranteed by internal policy as a way of protecting and trusting the channel. The channel is managed by the General Board of Internal Audit for Risk Management.

All complaints are investigated and, if applicable, the measures contained in the Code of Ethics and Conduct and in the MRS Disciplinary Regulation are taken. In cases where the General Board of Internal Audit and Risk Management understands the need to report to the Ethics Committee, an extraordinary call is made and the case is analyzed.

On a quarterly basis, the General Board of Internal Audit of Risk Management reports on all complaints received to the Ethics Committee and to MRS Board of Directors.  In 2020, 170 complaints related to the channel were received, which, together with 44 opened in 2019 and addressed in 2020, amounted to 214 complaints for solution in 2020. Of this total, 73 were related to ethical deviations and 141 to complaints or non-compliance. Of the complaints related to ethical deviations, 28 were considered valid, generating 22 dismissals, 5 suspensions, 11 warnings and 1 feedback/coaching. Among the complaints and non-compliances, 42 were considered valid, resulting in 42 corrections of processes.

Audit Hot Line
E-mail: linhadireta@mrs.com.br
Website: www.mrs.com.br/linhadiretacomauditoria
Phone: 0800-725-399925

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