Compliance and Ethics

Whistleblowing channel, investigation, and disciplinary mechanisms

As part of our commitment to transparency and non-retaliation, Cowade maintains a whistleblowing channel known as the “Open Channel,” through which employees and the public can anonymously report incidents or concerns.

This channel is managed by an independent third-party company with a support structure that includes psychologists and lawyers, ensuring professionalism, confidentiality, and appropriate guidance throughout the process.

All reports are documented within a third-party system that provides inviolability and full traceability. In addition, meetings of the Executive Ethics and Compliance Committee are formally recorded in minutes, reinforcing accountability, governance, and trust in the reporting process.

Supervision and Compliance Resources

The Compliance structure evolves alongside the growth of Cowade and the expansion of its operations. Currently, the area operates independently and is linked to the Executive Management of Internal Audit, Compliance, and Corporate Security, to which the Compliance Officer also reports.

The department has dedicated resources to manage the Integrity Program, ensure compliance with Anti-Corruption Laws, and support adherence to the LGPD (General Data Protection Law). It also maintains the resources necessary for the outsourced whistleblowing channel, analytical tools, internal training, and awareness programs.

This structure strengthens governance, risk management, data protection, and ethical conduct across the organization.

Code of Conduct and Policies

Compliance is responsible for ensuring clear, concise, and accessible rules for all employees of Cowade. To this end, the company maintains a modern and regularly updated Code of Conduct, aligned with key internal policies such as the Anti-Corruption Policy.

Together, these documents guide employees on expected ethical behavior and the proper conduct of their activities, while also clarifying procedures for preventing and addressing corruption and bribery. In addition to the Code of Conduct and Anti-Corruption Policy, Cowade also maintains other internal policies and standards that support and strengthen its Integrity Program.

Compliance Risk Assessment

The Integrity Program of Cowade was structured based on a detailed diagnosis and analysis of the compliance risks involved in its operations. This process included the development of a vulnerability matrix and risk map, a matrix of relationships with the public sector, and an assessment of compliance maturity across the organization.

Based on these evaluations, a structured action plan was created with a phased implementation approach. Since 2020, this work has been further strengthened with the establishment of the Corporate Risk Management area, reinforcing risk governance, monitoring, and continuous improvement of the Integrity Program.

Training, Communication, and Incentives

Since 2019, compliance topics and tools have been integrated into onboarding training at Cowade, with the Code of Conduct presented to all new employees from the beginning of their journey.

Periodically, the company reinforces its culture of ethics and integrity by clarifying the Code of Conduct and promoting best practices for ethical behavior. This communication is delivered through internal lectures, annual anti-harassment training, corporate TV broadcasts, posters, videos, and podcasts.

In addition, the results of reports received through the whistleblowing channel are published annually, strengthening transparency, accountability, and trust across the organization.

Internal controls, monitoring, culture audit, and continuous improvement.

Supplier evaluation and individual compliance

In 2020, Cowade began strengthening a key pillar of its Integrity Program by implementing a Due Diligence process for suppliers, partners, and service providers, including Background Checks.

This implementation involved defining standardized methods and processes, adopting technological tools, and expanding internal resources to support execution. The approach includes the application and analysis of risk-based criteria, focusing on the identification and selection of suppliers, partners, and service providers that may present higher compliance risks to the operation.

Whistleblowing channel, investigation, and disciplinary mechanisms

To ensure transparency and protect against retaliation, Cowade provides a whistleblowing channel known as the “Open Channel,” allowing employees and the public to anonymously report incidents.

This channel is managed by an independent third-party company and supported by a professional structure that includes psychologists and lawyers, ensuring confidential handling and appropriate support for all reports.

All cases are recorded in a third-party system that guarantees data inviolability and traceability. In addition, meetings of the Executive Ethics and Compliance Committee are formally documented in minutes, reinforcing governance, accountability, and transparency throughout the process.