Ethics and Compliance
(GRI 205-2, 2-27)
Ethical conduct is fundamental to maintaining the trust of our consumers, customers, investors, suppliers, team members, and other stakeholders, such as government agencies. We operate our business within a framework of compliance, high ethical standards, and integrity. We adhere to relevant laws, policies, and regulations, and support open and anonymous communication throughout our organization and value chain.
Our Global Compliance Program
We believe that an effective compliance program requires on-going monitoring, oversight, review, and revision. With an experienced team in place and demonstrated support from leadership, JBS aims to continually evaluate, improve, and implement its compliance program in line with recognized standards, such as the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs.
In 2022, we appointed Mike Koenig as JBS Global Chief Ethics and Compliance Officer to harmonize and reinforce the company’s strategy across global operations and build upon existing regional frameworks and expertise. Mr. Koenig reports directly to the Board of Directors and is supported by six dedicated senior managers, one in each region of operation. Under Mr. Koenig’s leadership, the Global Compliance team creates and disseminates the global policies and programs that promote ethical conduct in all company transactions and relationships.
JBS senior compliance managers also implement additional procedures, programs, and strategies unique to their regions but consistent with the overarching global compliance program.
To learn more about our regional compliance program, please visit our websites:
Our Nine Compliance Program Pillars
The structure of our compliance program is based upon nine well-established pillars, beginning with support from senior management. In enhancing our compliance program, JBS has relied on guidance from, among other things, the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs, two international law firms, two expert forensic firms, well-accepted industry literature, and our internal compliance team’s experience.
1) Leading Behavior
JBS promotes a culture of compliance, starting with its leadership teams setting an example. Visible support, involvement, and commitment from leadership are crucial to encouraging...
1) Leading Behavior
JBS promotes a culture of compliance, starting with its leadership teams setting an example. Visible support, involvement, and commitment from leadership are crucial to encouraging team member ethics and compliance.
2) Assessing Risk
The periodic identification, classification, and management of risks allow JBS to identify, understand, minimize, and remedy issues and improve policies and procedures.
3) Developing Policies and Procedures
Clear and consistent policies and procedures based on risk assessments guide team members in their daily activities. Key policy topics include...
3) Developing Policies and Procedures
Clear and consistent policies and procedures based on risk assessments guide team members in their daily activities. Key policy topics include anti-bribery/anti-corruption (ABAC), antitrust/anti-competition, conflicts of interest, and hospitalities (gifts, business meals, and entertainment).
4) Conducting Trainings
JBS delivers frequent, engaging, and targeted training to all team members in the most appropriate format (in person, online, or via video). All team members also receive mandatory Code of Conduct training.
5) Promoting Reporting and Conduct Investigations
The JBS Ethics Line is available 24/7 to all team members in multiple formats and languages and guarantees anonymity (for those who choose) and non-retaliation. We encourage usage through...
5) Promoting Reporting and Conduct Investigations
The JBS Ethics Line is available 24/7 to all team members in multiple formats and languages and guarantees anonymity (for those who choose) and non-retaliation. We encourage usage through our “Speak Up” campaign and regular communications. Appropriate personnel conduct investigations, and we take administrative or disciplinary action when warranted.
6) Communicating Regularly
JBS distributes general and targeted communication campaigns to increase transparency within the business and reinforce ethics and compliance practices.
7) Implementing Controls
JBS continues to manage and improve advanced control systems for faster and more effective detection and prevention of risk transactions.
8) Monitoring Effectiveness
We consistently monitor our compliance program via internal personnel and third parties to ensure its vitality and achieve meaningful improvements in our systems and practices.
9) Extending to Third Parties
We require third-party vendors to follow our same high ethical business standards and comply with all applicable laws, regulations, and rules. In addition, we have implemented external technology to further improve third-party due diligence and monitoring.
Leading Behavior
Global Governance
In 2022, we formed a Global Executive Ethics and Compliance Committee (“Global Committee”) to increase the uniformity and consistency of our compliance program across all company entities. Comprised of JBS executive leadership and advised by senior legal counsel as needed, the Global Committee recommends and oversees improvements and enhancements to our global compliance program and promotes best practices among all stakeholders.
In 2023, the JBS and Pilgrim’s Boards of Directors passed resolutions to maintain an effective ethics and compliance program and required mandatory periodic reporting by JBS Ethics and Compliance leaders to the respective boards.
Regional Oversight
In addition to the Global Committee, Ethics and Compliance Committees have been established in all regions. Meeting quarterly, the committees are composed of the respective CEOs, Chief Financial Officers (CFOs), Heads of Human Resources, regional heads of compliance, Chief Legal Officers (CLO) or General Counsels, and a business unit representative.
Business Management
While the committees have specific roles, functions, and goals, all JBS leadership and management are crucial in implementing the JBS compliance program companywide. Each month, the Global Chief Ethics and Compliance Officer conducts meetings with the full global compliance leadership team and also has one-on-one calls with each regional head of compliance. Senior management actively participates in training and communications and involves the compliance team in day-to-day business activities.
Throughout our operations in 2023, JBS compliance leaders attended regular meetings, frequently communicated information about ethics and compliance issues to team members, engaged with senior leaders, participated in various events and forums, and conducted culture surveys to evaluate and help improve each business unit’s compliance culture.
Assessing Risk
JBS conducts external and internal audits, testing, and surveys to identify high-risk areas and monitor the effectiveness of compliance messaging and training. Topic-specific assessments are conducted annually in each region, with appropriate remedial measures put in place as needed. A comprehensive global risk assessment was performed in 2022, and another is planned in 2025.
Developing Policies and Procedures
We provide the JBS Code of Conduct and Ethics (“Code”) in five languages (English, French, Italian, Portuguese, and Spanish). Our Code sets clear behavioral guidelines and standards for our employees to ensure appropriate workplace conduct and safe operations for the well-being of our team members. The Code covers a wide range of topics, including animal welfare, compliance, corporate ethics, environmental compliance, food safety, taxation and finance, team member safety, and workplace conduct.
All team members participate in annual, mandatory Code of Conduct and Ethics training, and new team members also receive an employee handbook during orientation that includes information on ethics and compliance. All team members must abide by our policies regardless of their position in the company. Corrective actions for violating the Code or company policies include coaching, written warnings, final written warnings and, if necessary, termination of employment. Serious violations can result in immediate termination.
Some of the key policies and procedures we have implemented include:
- Gifts, Meals and Entertainment
- Charitable Donations and Sponsorships
- Investigations
- Third-Party Due Dilligence
Conducting Trainings
We conduct general and tailored trainings across our global workforce. All salaried employees are required to complete trainings in the areas of ABAC, antitrust, conflicts of interest, gifts/meals/entertainment, and Code of Conduct. Additional ABAC training is provided to our international logistics, international sales, global procurement, financial, and accounting teams. Our JBS and Pilgrim’s Boards of Directors also receive ABAC training annually.
Team member training is provided in various formats, including in person, as pre-recorded videos, and via interactive online modules. Training completion is monitored through the learning management system (LMS), One Trust.
2023 training topics included:
- Foreign Corrupt Practices Act overview
- ABAC risk areas and financial transaction red flags
- Third-party gifts, meals, and entertainment
- Third-party onboarding
- Non-retaliation
- Convercent EL usage
- Investigative procedures, steps, and documentation
- Antitrust, competitor interactions, and completely sensitive information
- Conflicts of interest
- Export controls ans sanctions
- Purpose and importance of compliance
- Compliance policies overview
Promoting Reporting and Conducting Investigations
(GRI 2-25, 2-26, 205-3, 406-1)
To support the ongoing effectiveness of our compliance program, we provide anonymous and non-anonymous channels for team members and third parties to report potential misconduct or concerns without retaliation or fear of retaliation.
Most notable is the JBS Ethics Line, which is available free-of-charge, 24/7, in 18 languages. Every team member and third-party partner in every country where we operate can access this service. An independent, external third party receives reports, whether anonymously or with the reporter’s name, on potential violations of any JBS policy, procedure, law, or regulatory requirement. The Global Compliance team reviews the reports and assigns investigations as appropriate.
Behavioral-type cases related to workplace practices are typically transferred to JBS Human Resources personnel to investigate. Cases related to ABAC, antitrust, embezzlement, falsification of corporate documents, financial wrongdoing, theft over US$ 2000, and conflicts of interest remain with the Global Compliance team. In addition, the Compliance team handles any allegation involving executive or senior leaders. In 2023, people submitted 6,524 grievances to the Ethics Line, of which 100% were investigated and closed by appropriate personnel. We took corrective and administrative action where warranted. Approximately 6% of complaints were considered priority matters, which we consider critical cases*. We dedicate considerable time to raising awareness of the JBS Ethics Line and the importance of reporting all suspicions of unethical conduct. The company also implemented a Global Non-Retaliation Policy and an Investigative Procedure Manual in 2023 to standardize internal processes. Once assigned to an internal investigator, cases undergo two levels of review. All investigators complete mandatory training on the Investigative Procedure Manual prior to serving in their role.
JBS Ethics Line Cases¹ by Region |
|||||||
| JBS Region | 2022 | 2023 | |||||
| JBS Global | 5,743 | 7,925 | |||||
| Australia | 12 | 17 | |||||
| Brazil | 3,444 | 5,501 | |||||
| Europe | 42 | 54 | |||||
| Mexico | 26 | 91 | |||||
| U.S. and Canada | 2,219 | 2,262 | |||||
Communicating Regularly
The Global Compliance Team has launched multiple communication campaigns, such as “Speak Up”, “Person Of Value”, and others. The campaigns raise awareness of the importance of reporting potentially unethical and unlawful conduct, ensuring reporting is not met with retaliation, and building team members’ ability to recognize improper behavior.
Executive leadership amplified this messaging by participating in compliance workshop and training presentations, in-person discussions with regional teams, and email communications. This past year also marked the continuation of an internal Ethics and Compliance Newsletter, which we publish regularly. The newsletter covers such topics as:
- Leadership and governance
- Policies
- Training
- Trending compliance topics
- Compliance conferences and events throughout the company
Implementing Controls
In addition to reviewing and enhancing existing financial controls related to ABAC practices, JBS has implemented preventative and detective controls throughout the company’s operations. We have started implementing Lextegrity, an independent, third-party platform, to automate the approval, reporting, and initial and ongoing management of JBS vendors. The platform has been rolled out in the U.S. and is currently being implemented in Australia, Europe, and Mexico.
Once live, integration into Lextegrity is required for all new and repeating JBS vendors during onboarding and contract renewal, respectively.Existing vendors with long-term JBS contracts are being gradually transitioned onto the platform in batches. We have also undertaken several measures to identify and, when necessary, update due diligence evaluations of vendors who interact with governments or government agents on our behalf.
Monitoring Effectiveness
Using data from our Ethics Line, we monitor team member perceptions and trends in reporting. In 2023, we began inserting all complaints received via other channels into the Ethics Line platform to create a more holistic understanding of allegations to investigate and address. We also developed a Global Non-Retaliation Policy and Investigative Procedure Manual to standardize investigation procedures across global operations.
Extending to Third Parties
In addition to our JBS Code of Conduct and Ethics, we make our Code of Conduct for Business Associates available in four languages (English, Italian, Portuguese, and Spanish) to help ensure that our value chain partners adhere to our ethical business practices and expectations.