Sumário
Annual Report
2022 Sustainability
2022 Sustainability
- PT
- EN
Reflecting the importance of integrity, transparency and honesty that guide its operations, MRS adopts an Integrity Program to consolidate and reaffirm its beliefs, principles and guidelines, which must govern the actions of all employees at all hierarchical and managerial levels and third parties relating to the Company.
Under the responsibility of the Ethical Conduct Committee and with documents approved by the Board of Directors, the Program defines conduct policies and anti-corruption rules to be adopted by all employees in their daily practices and relationships with the Company’s stakeholders.
MRS Code of Ethical Conduct is in line with the current demands of society and the corporate environment, with guidelines related to the environment, social issues (such as human rights and diversity), governance and issues related to the General Data Protection Law (LGPD, acronym in Portuguese). The document called Ethical Conduct for Third Parties also includes ESG guidelines related to diversity, human rights and the environment. All documents that comprise MRS Integrity Program can be accessed in full at link.
For the receipt of reports related to possible unethical or illegal conduct, MRS maintains a Whistleblower Channel, which is available via phone, internet and intranet and, since 2022, has been managed externally, ensuring even more impartiality in the handling of reports and contributing to assertiveness in cases to be investigated, by forwarding reports and/or complaints not related to ethics directly to the responsible areas.
The investigations of reports received by the Channel are under the responsibility of the Compliance Management, linked to the General Internal Audit and Risk Management. On a quarterly basis, the area reports complaints and the appropriate treatment to the Board of Directors and the Ethics Committee, which is responsible for analyzing the most complex cases. Reports can be sent anonymously and confidentiality is ensured by internal policy. All reports are investigated and, if appropriate, the penalties indicated in MRS Code of Ethics and Conduct and Disciplinary Regulations are applied.
In 2022, 107 cases were addressed, 63 of which required forensic treatment. Of this total, 49 investigations were completed and 27 were deemed valid, resulting in 35 dismissals, 16 warnings, 5 suspensions and 7 disqualification of suppliers. No cases of corruption involving people belonging to the Government at any level (municipal, state or federal) were identified or reported. In addition, there are no corruption-related lawsuits filed against MRS and the Company is not aware of corruption-related lawsuits against one or more of its employees.
In 2022, an assessment of the maturity of MRS compliance structure was performed by a specialized independent consultancy, with the Internal Audit and Risk Management being in charge of implementing action plans to raise the classification to the “Managed” level, according to CMM – Capability Maturity Model classification by Carnegie Mellon.
MRS Internal Audit practice is certified with QA (Quality Assurance) by Institute of Internal Auditors (IIA), in line with the best global standards. The work of Internal Audit, Corporate Risk Management, Continuous Audit and Investigation of Reports is performed using a specific methodology. The corruption-related risk is considered and is included in the Company’s Risk Dictionary (learn more in Risk Management) as “Risk of Unethical Conduct/Fraud”.
All activities not related to traditional auditing (continuous auditing, whistleblower channel and corporate risks) undergo external inspection every five years. In 2022, 15 works were performed in different processes, chosen by risk prioritization, in addition to the investigation of cases submitted by MRS Whistleblower Channel. MRS was not notified during the period of fines for non-compliance with laws and/or regulations in the social/economic area.
For MRS, training employees in the Integrity Program is an ongoing and highly relevant activity. In addition to mandatory functional training for carrying out specific activities, MRS employees are trained in topics such as ethics, compliance, Brazilian General Data Protection Law among others, in order to ensure that the Company’s activities are supported by these principles.
In 2022, 98.6% of active employees were trained on the Code of Ethical Conduct, Conduct Policy and Integrity Program, which are mandatory for all employees, including directors.
The integration of new employees includes a lecture on the Integrity Program and there is training about this subject available at the MRS Academy (learn more here) which is a prerequisite of participation in all other courses. Annual refresher training is provided to all employees (adhesion of 93% of the active Employee base in December 2022) and awareness campaigns are carried out.
of active employees underwent training on the Code of Ethical Conduct, Conduct Policy and Integrity Program, which are mandatory for all employees, including directors.
The anti-corruption policies and procedures adopted by MRS also extend to its business partners. Before signing a contract, suppliers are registered in the database and are introduced to the MRS Integrity Program, Anti-Corruption Term and Code of Ethics.
In addition, the contracts signed by MRS require compliance with Law No. 12,846 of August 1, 2013, in which the supplier, its partners, administrators, directors, employees and agents undertake to refrain from any activity that constitutes a violation of the anti-corruption rules and obliges to conduct its commercial practices, during the execution of the contract, in an ethical way and in compliance with the applicable legal precepts.
