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Compliance

OTHER POLICIES

POLICIES AND PROCEDURES

JBS also has guidelines and documents addressing specific day-to-day issues, in line with the organization’s Compliance rules.

You can access the company’s policies for staff and third-party relations clicking on the links below.

Gifts, Promotional Items, Travel and Entertainment Policy

1. OBJECTIVE
This procedure sets out the rules, criteria and responsibilities that apply when offering or receiving gifts, promotional items, travel or entertainment.
2. COMPLIANCE
All JBS team members are required to comply with this Policy.
3. MISCELLANEOUS PROVISIONS
3.1 The guidelines for offering/receiving gifts, promotional items, travel or entertainment are mandatory, as many cultures offer these items as part of their business cultures and to build closer business relationships;
3.2 Any gifts, promotional items, travel or entertainment offered or received must be carefully assess to avoid any possibility of obtaining undue personal advantage and/or influencing business decisions.
3.3 Suppliers, government officials, consultants, competitors and clients generally exchange courtesies. However, both side’s internal rules on gifts, promotional items, travel or entertainment must be taken into account, applying the most stringent set of rules;
3.4 JBS team members should not use personal funds to pay for gifts, promotional items, travel or entertainment offered to third parties as part of business-related activities;
3.5 Any team members involved in third-party business relationships must act ethically and transparently; All team members are required to report any suspected infringement of this policy as per INPRESI-CPL-0146 - the Ethics Line Reporting Policy;
3.6 Anyone failing to comply with this policy will face appropriate disciplinary measures;
3.7 Any exception must be approved in writing and in advance by the JBS Compliance Director.
4. PROCEDURES
4.1 Promotional items
4.1.1 Promotional items, generally classified as institutional items with a unit value of no more than R$ 100.00, are permitted provided they are only offered or received on a sporadic basis and are not intended to influence decisions or as a reward or benefit for past or future business;
4.1.2 Items worth more than R$ 100.00 (one hundred reals) are classified as gifts and should not be offered or received. This includes any goods or products donated by suppliers, which could create an expectation that the supplier’s ongoing contracts with JBS will be maintained. If a JBS team member does not have an opportunity to refuse gifts in advance, they should immediately notify their immediate manager and arrange to return the item, explaining the company’s internal policies. If the item cannot be returned, or if returning it would offend the giver, the manager of the employee receiving the gift will send the item to a charitable institution or distribute it fairly within their area, if possible.


4.2 Travel and Entertainment
4.2.1 Invitations that involve travel, entertainment or related expenses should only be offered when they are directly associated with JBS’s business and are not intended to obtain undue advantages or have the appearance of a personal advantage;
4.2.2 These activities should not be expensive or extravagant, avoiding items such as Carnival or motorsport VIP boxes, tickets, rounds of golf or visits to resorts, casinos or cruises. Adult entertainment or excessive alcohol consumption are always prohibited;
4.2.3 All travel and entertainment invitations received from or offered to third parties must be approved by the relevant department, which will assess whether the event is directly related with the business and whether the employee who has been invited is the most appropriate person to attend the event;
4.2.4 JBS team members are prohibited from taking companions on trips or to entertainment venues or to include additional tourist activities, per diems, shuttles or other activities not directly related to the invitation.

Public Official and Government Agency Relationship Policy

1. OBJECTIVE
This policy describes the rules governing relationships between JBS Group companies (referred to herein simply as JBS) and government agencies and/or officials at meetings, when delivering and receiving documents or in other situations that may arise when requesting permits and licenses, submitting requests, filing bids or discussing JBS issues that require government involvement.
2. COMPLIANCE
2.1 This policy applies to all JBS business units in Brazil and to all JBS team members and outside consultants who interact with government agencies or officials.
2.2 The expression “outside consultants” includes any individual or company directly or indirectly hired to provide administrative services for or on behalf of JBS, including customs clearance, licensing, visas or work permits, scheduling meetings with government officials, obtaining regulatory approvals, calculating or paying taxes or contributions, handling inspections or any other government-related administrative service.
3. MISCELLANEOUS PROVISIONS
3.1 A Public sector interactions are very different from private sector relationships. Unlike private sector rules, the laws governing government agencies and officials are quite different and very complex and set out a number of issues for which JBS is responsible. This means various types of behavior that would be considered normal, or might even be expected in the private sector, may not be permitted in dealings with government agencies or officials;
3.2 Local and international legislation bars individuals and legal entities from directly or indirectly offering, promising, authorizing or paying any thing of value to any government official in an attempt to influence them in order to obtain or retain business or guarantee any other type of undue advantage;
3.3 JBS or team members who pursue inappropriate relationships with government officials face heavy sanctions for non-compliance with applicable laws and regulations; JBS is committed to the highest standards of integrity, ethics and transparency in all its interactions with government agencies and officials; JBS team members and outside consultants interacting with government officials must comply with all applicable legislation, the JBS Ethical Conduct Manual and the procedures described in this policy.
4. PROCEDURES
JBS’s relationships with government agencies and officials must comply with the following rules and procedures:
4.1 Requests from government agencies or officials;
4.1.1 As part of its day-to-day business, JBS is frequently asked to provide government agencies with information;
4.1.2 Team members who are approached by a government agency official must forward any request or inquiry to the relevant area within their division, such as the unit's regulatory, administrative or legal department or the JBS Institutional Relations area. Any written or verbal information provided to a government official or agency must be clear and accurate;
4.1.3 Any contact with officers of the court, such as process servers or notaries serving process on JBS or its representatives, must be accompanied by a member of the JBS legal department. At JBS distribution centers and units that do not have a legal department, receipt must be validated in advance by the unit’s legal, regulatory or administrative area by calling, emailing or otherwise contacting the unit manager or Human Resources manager, who are required to immediately forward a copy of any documents received to the legal area responsible;
4.1.4 When receiving any service of process or other document, check that JBS and/or its legal representatives are the actual addressees; if not, the document must be refused;
4.1.5 Any responses to questions or inquiries from government agencies or officials must be provided by staff or outside consultants who are fully aware of the issues involved and who have been properly authorized and prepared for this function. Any such responses must be provided in writing, where possible.


4.2 Private meetings with government officials
may be required to address matters related to JBS operations. Meeting participants must comply with the following:
4.2.1 Requests for private meetings must be formally directed to the management or secretariat of the public institution involved, clearly setting out any issues and related matters that will be addressed during the meeting, as well as the names of any staff or outside consultants designated to act on JBS’s behalf;
4.2.2 Meetings must take place at an appropriate location, preferably at the offices of the Public Institution or at a JBS unit meeting room, and must be attended by at least two JBS representatives, who will be nominated in accordance with the matters being discussed;
4.2.3 Depending on the Public Institution’s internal procedures, minutes of the meeting may be drawn up to document the issues that were addressed and any recommendations or actions decided at the meeting;
4.2.4 The meeting’s audio will only be recorded by the Public Institution, if that is part of its procedures and has been formally documented in internal administrative regulations.


4.3 Doing business with government agencies
4.3.1 Whenever it sells products to government agencies, JBS is required to comply with the Government Procurement Act; this is intended to guarantee equal treatment for everyone involved and ensure the government selects the most advantageous proposal, guaranteeing equal opportunities for all interested parties and involvement of the largest possible number of competitors;
4.3.2 Any agreements with government agencies must necessarily be preceded by a Public Bid (competitive bid, price taking, auction, invitation or electronic or in-person bidding), except when exempted or waived by law.
4.3.3 When taking part in public procurement procedures, JBS must comply with the following:
• any bid documents or information must be complete and accurate and comply with the bidding rules;
• employees or outside consultants acting on behalf of JBS shall not request or accept any confidential information, such as prices or terms offered by other participants, before bids have been unsealed and made public;
• contract terms and conditions must be complied with and the items involved in the procurement process can only be amended with the express consent of the procuring agency;
• any documents from procurement procedures JBS has been involved in must be archived for five years for future consultation;
• employees or third-party representatives of JBS taking part in public procurement procedures must be trained on sales procedures involving government customers.


4.4 Gifts, Promotional Items and Entertainment for Government Agencies and Officials
4.4.1 Gifts: offering gifts to Government Institutions or their officials is prohibited;
4.4.2 Promotional items: Promotional items may be offered, provided they cannot be viewed or interpreted as any type of bribery, payment or improper attempt to exercise influence and they do not affect or otherwise undermine JBS’s reputation or the reputation of the public official involved. In this case, the following rules apply:
• Permission: promotional items must be permitted by the rules of the Public Institution receiving them;
• Format: items must be classified as courtesies or “souvenirs” and should be institutional items generally distributed by the company on appropriate occasions, such as at Christmas or on special commemorative occasions;
• Frequency: occasionally, once a year;
• Price: modest, no more than R$ 100.00 (one hundred reals) per unit;
• Recipient: any promotional items offered as part of JBS’s institutional relationship with a particular government agency must be addressed to that agency, which will then distribute the items internally; promotional items must not be sent to specific individuals. Promotional items offered in cash or equivalent formats, such as gift cards, and promotional items intended for relatives of government officials are prohibited.
4.4.3 Entertainment: Entertainment can only be offered to government officials if allowed under the relevant government agency’s Code of Conduct or other regulations and provided the activity is part of an agenda of technical/educational or regulatory activities associated with JBS businesses. The following rules will apply:
• Any entertainment must be infrequent, modestly priced and take place at a location appropriate for business discussions and a JBS team member must be present at all times;
• These activities should not be expensive or extravagant, such as Carnival or motorsport VIP boxes, tickets, rounds of golf or visits to resorts, casinos or cruises;
• JBS team members and outside consultants must avoid inappropriate social interactions that could negatively impact on JBS’s reputation or the reputation of the persons involved; adult entertainment and/or excessive alcohol consumption are expressly prohibited;
• Only government officials with which JBS is discussing business-related matters are allowed to participate in entertainment activities. Wives, relatives or other persons should not be invited to or attend such events.


4.5 Payment for Travel and Accommodation Expenses
4.5.1 In the situations described in this policy and when permitted by the relevant government agency’s rules or regulations, JBS may pay reasonable, modest and appropriate travel expenses for officials traveling on government business for legitimate reasons, such as visiting JBS units to carry out inspections or provide regulatory certification;
4.5.2 In general, a modest amount is the price JBS would pay for an employee’s trip, including transportation, accommodation and meals, based on the types of flight and other criteria defined in the JBS Travel Policy.
4.5.3 Airline tickets and hotel bookings will be arranged and provided directly by JBS. Airline tickets will be issued for direct flights or flights with the fewest number of stopovers possible, depending on airline availability, avoiding any unnecessary stops or legs between the origin and destination;
4.5.4 Trips will be limited to the length of time needed for a particular business event or visit and payment or reimbursement for additional per diems is prohibited;
4.5.5 Government officials are prohibited from using JBS aircraft, except when no commercial flights are available to a particular destination or when use of JBS aircraft is requested and duly authorized by the relevant agency in order to carry out inspections or regulatory certification at JBS units;
4.5.6 Travel (taxi, bus) and meal expenses will be reimbursed, subject to filing original receipts, in accordance with the JBS Travel Expense Policy criteria and limits.


4.6 Hiring former public officials
Former public officials who held positions giving them access to privileged information that could offer JBS an economic or financial advantage shall only be directly or indirectly hired six months after their departure, dismissal, removal or retirement from public office, except when specifically authorized by the relevant Government Agency’s senior management.
5. USE OF PERSONAL FUNDS
JBS employees and third parties shall not use personal funds to pay the expenses of any government official during company-related activities. This policy still applies even if personal funds are used.
6. INTERPRETATION, EXCEPTIONS AND INFRINGEMENTS
6.1.1 In the event a Government Agency has regulations, policies or a Code of Conduct that are more or less restrictive than the rules in this policy, the more restrictive rules shall apply;
6.1.2 Any questions about this policy should be directed to the Compliance or Legal Department;
6.1.3 Any exception to this policy must be approved in writing and in advance by the JBS Legal Director.

6.2 Policy violations
6.2.1 Any failure to comply with this policy could have serious consequences for JBS, including fines, lawsuits or even being barred from government contracts. Policy violations could also harm JBS’s reputation.
6.2.2 Any policy violation must be immediately corrected and JBS employees must immediately report any policy violation they are aware of. Anyone who fails to comply with this policy is subject to disciplinary measures, up to and including termination of employment, with or without cause, in addition to appropriate legal measures for any harm caused to JBS.

JBS Ethics Line Policy

1. OBJECTIVE
This policy describes how to report ethical issues, misconduct or wrongdoing that could have financial and/or reputational repercussions for JBS.
2. COMPLIANCE
All areas involved in this process and referred to in this document are required to comply with this procedure.
3. MISCELLANEOUS PROVISIONS
3.1 The company reiterates its commitment to doing business legally and ethically and in accordance with its Code of Conduct and Ethics (the “Code”) and other internal policies;
3.2 This policy applies to JBS employees, third parties, service providers, suppliers, administrators, shareholders, customers, government and private sector institutions and officials or any individual or legal entity representing the company, including its direct or indirect subsidiaries, who are jointly referred to in this document as “Whistleblowers”;
3.3Questions about how to interpret the Code guidelines or JBS corporate policies or any other ethical issues creating uncertainty about violations of the Code of Conduct and Ethics should be addressed to members of the Compliance team, who will be able to respond to any inquiries or forward them to the appropriate sector.
4. PROCEDURES
4.1 JBS Ethics Line
4.1.1 Employee whistleblowers can notify their managers or the Human Resources, Legal or Compliance areas of any issues. The information these areas receive will be forwarded to the Compliance area and all information will remain entirely confidential. External whistleblowers, or company employees who do not feel comfortable reporting to their manager or representatives from the aforementioned areas, can report issues through the JBS Ethics Line;
4.1.2 The JBS Ethics Line is a channel available to report Code of Conduct and Ethics violations as well as misconduct or wrongdoing that could have financial or reputational repercussions for JBS. Below are some examples of the type of conduct that should be reported immediately via the JBS Ethics Line:
- Sexual harassment;
- Moral harassment;
- Significant fraud or other incidents involving company financial statements;
- Corruption, money laundering or financing for terrorism;
- Trafficking prohibited substances;
- Leaking or misusing information;
- Violating competition laws;
- Discrimination;
- Use of forced, child or slave labor; and
- Violation of environmental laws with long-term and widespread effects.
4.1.3 The JBS Ethics Line is managed by an external company and is available 24 hours a day, seven days a week in Portuguese, English and Spanish. The JBS Ethics Line can be contacted by:
- Telephone: 0800-377-8055
- Website: www.linhaeticaJBS.com.br
4.1.4 After making a report through one of these channels, whistleblowers will receive a filing number. This number should be used to check progress on any reported behavior, receive responses, submit other issues or provide additional information. Filing numbers are personal and nontransferable and are particularly important if a report is filed anonymously, because the person filing the report can only be contacted through the website;
4.1.5 All reports received via the JBS Ethics Line are forwarded to the Compliance area, which is responsible for processing them internally, responding to whistleblowers and concluding the resulting investigations;
4.1.6 This channel should not be used to file complaints, suggestions or compliments benefits, canteens, products, unit facilities or other day-to-day issues involving the company. These issues should be forwarded to the JBS Ombudsman or the Customer Service channel for the respective brand.


4.2 Whistleblower Commitment
4.2.1 Whistleblowers’ reports should be clear, responsible and honest and whistleblowers should never delegate responsibility for reporting misconduct and/or wrongdoing and should never assume that another person will report it. Always provide as much information as possible when reporting an issue, for example: 
-What type of misconduct/wrongdoing has occurred? 
-Who is involved? 
-Who is being affected by the situation? 
-How, when and where did the misconduct/wrongdoing take place? 
-What supporting information or documents are available?
4.2.2 By providing detailed information, whistleblowers will be showing that they are committed to using the JBS Ethics Line correctly and responsibly;
4.2.3 JBS encourages self-reporting in cases of misconduct involving an employee. This will be taken into account when applying any disciplinary and/or employment measures in each particular case, when applicable;
4.2.4 JBS will protect whistleblowers who file reports in good faith, even if the information is later found to be incorrect;
4.2.5 Knowingly making false accusations, failing to report the truth and interfering with or refusing to cooperate in internal investigations will all be considered a violation of this policy and the Code.


4.3 Confidentiality and Anonymity
4.3.1 All reports are handled confidentially. This means any information provided will only be shared among a limited number of people on a need to know basis. The information will only be disclosed outside this group if JBS is required to disclose it by law or as a matter of public interest. To ensure the matter remains confidential, whistleblowers should not comment with other employees or third parties on any issues they have reported or any investigation;
4.3.2 Whistleblowers can report issues anonymously (when permitted by local laws), however, identifying yourself is important because anonymity could mean additional issues, which often need investigation, go unaddressed.


4.4 No retaliation/interference
4.4.1 JBS will not tolerate any retaliation against whistleblowers who have reported misconduct and/or wrongdoing, provided their reports were filed in good faith and are supported by accurate information that assists in the relevant investigation;
4.4.2 Employee whistleblowers will not face any disciplinary measures, retaliation or demotion, loss of benefits, threats, abuse or discrimination for raising concerns honestly and in good faith, for taking part in an investigation or refusing to do something that violates the JBS Code of Conduct and Ethics, JBS policies or applicable legislation, even if their refusal results in JBS losing business;
4.4.3 If any employee believes he or she is suffering retaliation for whistleblowing, they should contact the Compliance area or file a report via the JBS Ethics Line;
4.4.4 Whistleblowers do not need JBS’s prior authorization to report possible misconduct and/or wrongdoing to government agencies and are not required to notify JBS they have filed such a report;
4.4.5 The preceding item also applies to reports or disclosures that may involve violations of US law and are filed with any US government organization or agency, including, but not limited to, the Department of Justice (DOJ), the Securities and Exchange Commission (the SEC), Congress or any police agency or any disclosures that are protected by US whistleblowing laws or regulations1.


4.5 How Reports are Handled
4.5.1 Any reports of misconduct will be investigated in accordance with JBS guidelines.
4.5.2 Importantly, once a report has been filed, whistleblowers should not carry out their own investigation; JBS’s own investigators are responsible for investigating each specific case in the best possible manner.