At Rede D’Or São Luiz, we are committed to keeping the highest ethics and integrity standards in our care delivery practices and in the relationship with all stakeholders, including our commercial transactions. Therefore, we have a Code of Conduct, which lays down all our principles, an Anti-Corruption Corporate Policy and an Integrity Program.
Full compliance with said documents contributes to business growth, sustainability and perpetuity. We did not record any confirmed corruption cases in 2021.
Total number and nature of confirmed corruption cases
2019
No such cases in the reporting period
2020
No such cases in the reporting period
2021
No such cases in the reporting period
Our Code of Conduct informs employees on expected behavior in the relationship with colleagues and other stakeholders (clients, suppliers, government operatives, community and the press). The Code covers several topics, including laws, standards and regulations, professional conduct, transparency in relationships and mutual responsibility. All employees must be informed and accept the Company’s Code of Conduct by signing a statement electronically. If applicable, they must also inform the company about any situation that might be considered a possible conflict of interest.
Periodic reviews have enabled us to keep our Code of Conduct up to date regarding changes in social behaviors, laws and regulations, such as the Brazilian General Data Protection Act (LGPD, in Portuguese).
Complying with the legislation in force, the Company does not make contributions to political campaigns, political parties, lobbyists or lobby organizations, trade association and other groups exempt from paying taxes.
The main purposes of Rede D’Or São Luiz’s Anti-Corruption Corporate Policy are to prevent bribes and corruption, maintain our image and reputation and enable the immediate response to any matters on conduct. The document covers specific topics, such as the receipt and offer of gifts, political contributions, recordkeeping and internal controls, training and rules enforcement. The Policy is applicable to all of Rede D’Or São Luiz’s directors, executive officers, employees, representatives and third parties.
To help our Employees with understanding attitudes that can be considered potential acts that violate our code of conduct’s ethical guidelines, we carried out communication campaigns addressing material topics to the company as well as society, such as sexual harassment and discrimination.
Our Integrity Program sets forth the implementation of mechanisms used to prevent, identify and fight corruption, bribery and frauds in bidding processes and the relationship with Public Authorities, ensuring Rede D’Or São Luiz’s full commitment to ethics and transparency. It is based on the Brazilian Anti-Corruption Law (12.846/13) and the respective decree (8.420/15) and relies on the commitment of the senior management, who safeguards its application to the Company’s daily activities.
Pillars of the Integrity Program
To spread and consolidate the compliance and anti-corruption culture at Rede D’Or São Luiz, we offer specific training on the topics to our internal stakeholders. Throughout 2020 and 2021, after the implementation of the DL (distance learning platform), 55,855 employees completed the compliance training, which have included topics related to Rede D’Or São Luiz’s code of conduct and internal rules regarding the topic, accounting for 87% of our total staff. Furthermore, we also made available a training focused on anti-corruption practices, with 2,015 managers trained and approved, accounting for 85% of our target audience.
Any kind of misconducts can and must be recorded in our Whistleblowing Channel, which is available 24x7, on the phone or the internet (via e-mail or on the website). To provide more safety and peace of mind, claims can be anonymous, as set forth in the Code of Conduct and the Whistleblowing Channel’s internal rules and ensured by a specialized and independent company.
The Compliance department is responsible for the Channel and manages received claims, submitting them to the respective departments. The department considers the type and complexity of each claim and commits to address 100% of them. Highly critical complaints can also be evaluated eventually by Rede D’Or São Luiz’s senior management.
In 2021, we received a total of 1,963 claims, most of them related to misconducts (652), followed by non-compliance with rules and internal policies (434) and moral harassment or aggression (368). The aforementioned claim types account for 74% of the total claims received. Up to year-end, 396 complaints were under analysis, 592 were found unsubstantiated and 541 substantiated. Other complaints (26%) are nor related to the whistleblowing channel, but to other communication channels, such as the Ombudsman Office and Contact Us. In the latter case, the proper disciplinary measures have been applied, in accordance with the internal rules.
Received claims
Telephone
0800 377 8031
Website
www.canalconfidencial.com.br/canalconfidencial/
Mailing address
Av. Voluntários da Pátria, 138 – Botafogo –
Rio de Janeiro/ RJ. CEP: 22270-010.
(Attn. Compliance Department).
Telephone
0800 4504510
Website
www.canalconfidencial.com.br/dorconsultoria
