Annual and Sustainability Report | 2019
Ana Cláudia Fernandes
HR Manager in Amparo (SP)

With each training cycle,

training makes them curious and, more than anything, confident. They understand that this closer relationship is a plus and that they can speak their minds, ask questions and even complain. They are confident that all issues will be taken seriously and, above all, the entire team is available and transparent."

A global food company

Ethics and compliance

Since 2017, the Company has had an independent global department at the forefront of the compliance topic, reporting directly to the Board of Directors. The Company monitors the maturity of processes and assesses the efficiency of actions adopted year after year, in every region where it operates. In this sense, 2019 was an important year for upper management to reiterate a commitment to continual improvement processes implemented.

All practices and policies related to compliance are available in the Code of Conduct and Ethics.. This document provides guidelines for team members to work in compliance with the Company in every situation, outlining the behavior and conduct acceptable and required by JBS. The Code, available in Portuguese, English, Italian and Spanish, was created to consolidate and unify the global guidelines in place at the different JBS operations around the world. The Company also has a Business Associate Code of Conduct. Third parties carrying out any kind of transaction with JBS, such as customers and suppliers, must follow this Code.

EIn 2019, the Company continued to spread its “Always Do the Right Thing” program in every sphere of the business. This initiative was built to foster an environment of ethics and integrity in all Company processes, following local and international guidelines on the following pillars:

  • Risk assessment
  • Leadership and governance
  • Policies and procedures
  • Ethics hotline
  • Controls
  • Training and communications
  • Third-party due diligence
  • Assessment, oversight and discipline
Amparo (SP)

JBS held their first compliance meeting, in partnership with J&F, at the Company’s headquarters in São Paulo. The event was attended by around 150 participants, including team members from JBS and from other group companies, in addition to market professionals, who gathered to debate challenges and trends of compliance in Brazil. The Global CEO of JBS, Gilberto Tomazoni, and the Chairman of the Company’s Board of Directors, Jeremiah O’Callaghan, were also in attendance. Some of the Brazil’s top compliance professionals exchanged ideas and experiences over eight hours, in an effort to enhance their knowledge of compliance programs and good corporate governance practices. Another topic discussed was the role of compliance in fighting corruption.

The Company also focused its activities on training and education for team members, aimed at reinforcing guidelines and ratifying a culture of compliance. A series of training sessions on the Code of Conduct and Ethics were held, with 116,645people participating, which accounts for 98.4% of JBS team in Brazil and 37,432 training hours.

Anti-corruption training was held in Brazil for administrative staff, with 16,075 people, or 94% staff participation, taking part in 8,084 training hours. Single-topic training for specific teams was also developed, such as competition compliance for those working directly with public sales.

To build on existing policies, JBS revised the Promotional Items, Gifts, Travel and Entertainment Policy and a new policy, the Third Party Due Diligence Policy, was launched.

Throughout the year, over 9,000 reputational analyses were done on suppliers, including not only a historical assessment of partners, but also of their respective associates, making contracts more reliable. This was done using a tool developed by JBS in partnership with an international consulting firm, allowing for a comprehensive analysis of partners’ reputations.

The Company also invests in the Supplier Training Program. The 10 largest carriers with whom the Company holds contracts for transportation went through a pilot program in 2019. With this training, they understand and are committed to the rules and policies of JBS in Brazil, as well as what is expected of them as suppliers. The goal of the initiative, which is still under development, is to continue in 2020 with the entire value chain to encourage transparency and integrity as strategic elements of the business.

The Company has also adopted internal policies, which must be adopted at every Company unit. The Global Policy on Conflicts of Interest was approved and implemented worldwide. The Anti- Corruption Policy is in the approval phase and should be implemented in 2020. The Company also carried out a review of existing controls and created new controls to verify compliance with internal rules and scenarios for any breach of rules.

Other initiatives developed in 2019:

  • Launch of a global compliance website (, dedicated to Company activities in this area;
  • Internal communications campaign;
  • Risk assessment for controls and rules for each business.

Team member Tayna Santos, from Heardquarters (SP), reading the Code of Conduct and Ethics

Policy for Offering and Receiving Promotional Items, Gifts, Travel and Entertainment

Updated in August 2019, the Policy for Offering and Receiving Promotional Items, Gifts, Travel and Entertainment provides rules on exchanging gifts and entertainment between the Company’s team members and partner companies. The new guidelines provide more security, control and transparency in relations for the Company’s business partners in Brazil and for the purpose of the gift offered and/ or received.


Ethics Committees

JBS Brasil has five business Ethics Committees (Friboi, Seara, Swift, JBS Couros and JBS Novos Negócios) and one Institutional Committee. Process improvements were implemented across these committees.

The business committees meet on a quarterly basis to discuss the most relevant grievances received via the Ethics Hotline, jointly establishing solutions in addition to resolving other matters related to compliance. Members of the Institutional Ethics Committee, which meets on a quarterly basis, include the CEO of JBS in Brasil, Administrative Director, Legal Director, HR Corporate Director, one of the Company’s BU Presidents (rotating seat) and the Global Compliance Director. This committee carries out a variety of activities which are defined and pre-established in the internal policy, such as discussing and resolving highly relevant grievances received and considering progress made in the compliance program.


JBS Ethics Hotline

The JBS Ethics Hotline guarantees transparency in internal and external relations. The hotline is consolidated, well-structured and fully outsourced – which protects and guarantees user anonymity. It is available everywhere in the world where the Company is located, in 4 languages, 24 hours a day, 7 days a week, and it is a fundamental part of the Company’s compliance program. This channel is the chief vehicle for grievances related to irregularities and violations of the Company’s Code of Conduct and Ethics, both for its team members and JBS’s external public.


Business Pact for Integrity and Against Corruption (Ethos)

GRI 102-12, 102-13

JBS has been a signatory to the Instituto Ethos Business Pact for Integrity and Against Corruption since 2018. This initiative aims to join companies with the goal of promoting a market of greater integrity and ethics and to eradicate bribery and corruption. In the last year, the Company also signed the Business Movement for Integrity and Transparency. The movement encompasses creation by business sectors of conditions to deepen and consolidate integrity programs, risk management and anti-corruption activities, while also demanding enhancement of laws.


Compliance Highlights 2019

  • 37,000 hours of training in the Code of Conduct and Ethics, with more than 115,000 team members in Brazil.
  • Over 8,000 anti-corruption training hours for more than 16,000 team members, through an online platform.
  • Due diligence: In 2019, 9,486 analyses were done by JBS software. When any nonconformance is found in a supplier assessment, the supplier is automatically barred and undergoes a second verification procedure by the compliance area.
  • In 2020, there will be training on topics such as conflicts of interest and a review of anti-corruption content.


the report