Page 1
Global Anti-Corruption Compliance Manual
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 2
Introduction
I
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 3
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 4
Anti-CorruptionPolicy
II
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 5
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 6
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 7
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 8
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 9
Corporate IntegrityDepartment
III
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 10
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 11
oIntroduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
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Page 12
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 13
Handling anti-bribery compliance problems &corrective actions
IV
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 14
Under no circumstances must the reporting of any such potential violation or impropriety serve as a basis for retaliation and intimidation against any employee who acted – or made such report – in good faith.
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 15
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 16
Training andEducation
V
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 17
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 18
Gifts andHospitality
VI
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 19
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 20
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 21
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 22
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 23
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oIntroduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 24
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 25
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 26
oIntroduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 27
SocioenvironmentalInvestments
VII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 28
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 29
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*subject to applicable labour laws and the terms of negotiated collective bargaining
rights.
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 30
Suppliers
VIII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 31
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*Service providers, suppliers of materials or equipment, vendors, agents, distributors,
brokers, consultants, representatives, other contractors or suppliers, and other
intermediaries paid to represent Vale. Supplier does not include customers or recipients of
socioenvironmental investments. Separate rules apply for Government Authorities.
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 32
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
*Employees may use a risk classification questionnaire provided by the Corporate Integrity department (e.g., the Initial Risk Assessment Questionnaire) to establish the Supplier's level
of corruption risk, or request the Supplier to complete such questionnaire.
Page 33
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 34
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 35
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Appendices
Page 36
Appendices
Joint ventures, consortia, and other associations
IX
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 37
Appendices
o
o
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 38
Appendices
Selection and compensation of employees and managers
X
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 39
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 40
Appendices
Books, records, and financial reporting
XI
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 41
Appendices
o
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Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 42
Appendices
Internal auditing and monitoring
XII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 43
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 44
Appendices
Appendices
XIII
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 45
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 46
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 47
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 48
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 49
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 50
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
o
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Page 51
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
o
o
o
o
o
o
Page 52
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 53
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
§
Page 54
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 55
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
§
Page 56
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 57
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
§
Page 58
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 59
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 60
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 61
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 62
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 63
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring
Page 64
Appendices
Introduction
Anti-Corruption Policy
Corporate Integrity Department
Handling anti-bribery compliance
problems/ corrective actions
Training and Education
Gifts and Hospitality
Socioenvironmental investments
Suppliers
Joint ventures, consortia, and
other associations
Selection and compensation of
employees and managers
Books, records, and financial
reporting
Internal auditing and monitoring