Integrity Program and Whistleblower Hotline

Integrity Program

To comply with Federal Law 12,846/2013 (Lei da Empresa Limpa) or Anticorruption Law, Localiza formed a multidisciplinary work group with representatives from the Internal Audit, Corporate Communication, Internal Controls, Legal and Human Resources departments, and the work done by this group gave rise to the Localiza Integrity Program implemented in 2015.

The Integrity Program is a set of procedures and guidelines essential for constantly maintaining ethical and transparent conduct in all professional relations involving the Company in order to prevent and combat acts of corruption and acts against public administration.

The Integrity Program covers the entire Localiza Team, including franchisees in Brazil and abroad, and certain suppliers and service providers that represent the Company at government agencies and entities, referred to as Third-Party Intermediaries.

The Company’s Integrity Program applies even before employees are hired. Candidates for leadership positions and/or positions exposed to risks of corruption must mandatorily take eliminatory tests of conduct and ethical compliance during the selection phase. In addition, all new employees or new franchisees must sign the Statement of Commitment to the Integrity Program, declaring their understanding and compliance with the Program’s rules. To train and guide employees and franchisees, the Company provides on-site or online training on the Integrity Program and the Anticorruption Law to eligible people. During exit interviews, employees answer questions about the ethical conduct of leaders and other employees and are encouraged to use the Company’s Hotline (Confidential Channel).

The Integrity Program also provides for the inclusion of Anticorruption clauses in agreements signed with Third-Party Intermediaries contracted by the Company and the signing of the Statement of Commitment to the Integrity Program, declaring full understanding and compliance with its rules. The Company also applies monitoring and due diligence procedures and provides training to Third-Party Intermediaries.

The Localiza Integrity Program is supported by the following pillars:

– Permanent support from Localiza’s Board of Directors, CEO and Board of Executive Officers to maintain and apply the Integrity Program
– Periodical supervision and monitoring of the Integrity Program by the Audit, Risk Management and Integrity Committee
– Enforcement of policies and punishments, regardless of position or function

– Identification of the most exposed areas and types of risks involved
– Risk evaluation and classification
– Treatment of risks identified, in partnership with the areas concerned
– Adoption of preventive measures to enhance controls

– Adoption of clear policies and tough measures against corruption and acts against public administration
– Compliance Manual
– Implementation of internal controls

– Periodical communication and training on the Integrity Program for the entire Localiza Team (employees and franchisees)
– Participation of Third-Party Intermediaries in periodical training sessions on Localiza’s Integrity Program

– Investigations on existence of irregular/illegal processes in the Company
– Periodical investigations and monitoring of Third-Party Intermediaries that may configure situations of risk to the Company

– Constant monitoring of the Integrity Program and the effectiveness of measures recommended and adopted
– Execution of audit procedures to evaluate the effectiveness of the Integrity Program

– Hotline broadly disseminated to internal and external stakeholders, operated by independent company to ensure anonymity.
– Defined flow of investigation and analysis of complaints.
– Internal policy of non-retaliation to whistleblowers in good faith and witnesses involved in an internal investigation
– Establishment of punishments for irregular or illegal conduct

– Review of laws, rules and regulations for updating internal procedures and rules
– Periodical revaluation of risks of corruption and acts against public administration
Localiza is a company committed to building relationships based on integrity with clients, employees, franchisees, shareholders, suppliers, government agencies and the society in general. Hence, it does not tolerate unethical conduct, especially that involving corruption or any acts that may cause harm to public administration.

Business Pact for Integrity and against Corruption

In April 2016, Localiza signed the Business Pact on Integrity and Anticorruption (Pact), an initiative of Ethos Institute in partnership with the United Nations Development Program (UNDP), the World Economic Forum, the Global Compact Network Brazil and Patri Public Affairs.
The Pact’s principles, which aim to stimulate a fairer and more ethical market, are based on the Charter of Social Responsibility Principles, the UN Convention against Corruption, the 10th Principle of Global Compact and the Guidelines of the Organization for Economic Cooperation and Development (OECD) for Multinational Companies.

Based on the premises of the Pact, Localiza publicly affirms its commitment to:
– adopt, or reinforce, all the actions and procedures necessary for people who are part of its structures to learn the laws they are bound by, while acting on behalf or in benefit of the Company, so that they can comply with them fully, especially in relations with government bodies and agents;

– prohibit, or reinforce the prohibition of any person or organization acting on behalf or in benefit of the Company to give, undertake to give or offer bribery, which includes any direct or indirect pecuniary or nonpecuniary benefit to any government body or agent, not even to obtain a decision favoring its business;

– prohibit, or reinforce prohibition of any person or organization acting on behalf or in benefit of the Company to make contributions to political campaigns in order to obtain advantage of any kind or avoid retaliations or illegal omissions;

– prohibit, or reinforce prohibition of any person or organization acting on behalf of the Company, either as representative, agent, attorney-in-fact or under any other relation, to use any immoral or unethical means in relations with government bodies and agents;

– disclose the principles expressed herein to other economic agents, entities and associations that maintain relations with the Company;

– support and cooperate with the governments in any investigation of suspected irregularity or breach of law or of ethical principles expressed herein, giving them access to its registers, records and files, regardless of any court order, always in strict compliance with the law in force; and

– consult the National Register of Disreputable and Suspended Companies (CEIS) of the Office of the Federal Controller General to verify if natural persons or legal entities acting as suppliers in its production chain were declared disreputable by public authorities, avoiding business relations with such persons whenever possible. This procedure must also be conducted by any person or organization acting on behalf or in benefit of the Company.

Click here to access the compliance manual (Portuguese only).

Whistleblower Hotline

In line with the best corporate governance and risk management practices, Localiza offers a whistleblower hotline (Confidential Channel) to register information about unethical or illegal situations occurred in the Company. Localiza´s Confidential Channel is operated by an independent company and is available 24 hours a day, 365 days a year and can be accessed by any of the following means:

Understand how Localiza´s Confidential Channel works

Canal Confidencial

What is and what situations should be communicated through the Confidential Channel?

The Confidential Channel is the tool provided by Localiza to register complaints related to situations involving violations of Localiza’s Ethics Code and Compliance Manual or the existing laws.

Who can use the Confidential Channel?

The Confidential Channel can be used by Localiza´s employees and others public, with whom it relates, such as suppliers and service providers, customers, investors, etc.

Is it necessary to identify yourself when registering a complaint?

No. The complaints can be made anonymously or on an identified form.

Can complaints be tracked?

Yes. After the registration of a complaint, a protocol number will be available. With this protocol it is possible to track the progress of the investigation and check for any doubts or questions by those responsible for investigating. The monitoring can be done through:

  • Telefone
    0800 979 2055 (Brazil – toll free)
    55 11 3232-0786 (abroad – collect call)
    From Monday to Saturday from 8AM to 8PM (Brasília time), with the option to talk to an analyst .
  • Internet
    www.canalconfidencial.com.br/localiza (through the link “Track Reporting”)
Who is responsible and how long does it take for a complaint to be investigated?

The Internal Audit and Personnel Management departments are responsible for the management of the Whistleblower Hotline and for the determination and investigation of complaints process. The referral of complaints for each of these departments will depend on the nature and type of situation complained.

There is no fixed deadline or limit stipulated for the complaint to be investigated. The complexity and content of each complaint registered in the Confidential Channel may vary and consequently, the investigation and treatment time will also vary.

Is there any punishment for those who make a complaint?

No. Complaints do not need to be identified and Localiza will not allow retaliation against the complainant of good faith or even against any person who provides information, documents or collaborate on an internal investigation process, according to its Whistleblower Policy and Non Retaliation.

What happens to an employee terminated?

Punitive measures against any person reported will be applied when there is enough evidence about his/her involvement in a situation or illegal or unethical conduct, after all internal investigation procedures of a complaint are performed. The application of punitive measures is Localiza’s Management sole decision and can range from a simple orientation, formal warning, temporary suspension or even lead to the dismissal of those involved.