Ethics and Compliance
(GRI 205-2, 2-27)
Ethical conduct is fundamental to our approach to business and critical to maintaining the trust of our customers, consumers, team members, suppliers, investors, governments, and other stakeholders. At JBS, our work environment is based on high standards of ethics, compliance, and integrity; guided by adherence to the applicable laws, regulations, and policies that govern our business conduct; and supported by open and anonymous communication channels for voicing concerns. We are committed to maintaining the trust of our stakeholders, earning the trust of skeptics, and ensuring ethical and compliant business conduct across our worldwide operations.
Within the ever-changing world of business dynamism, growth, and risk management in which we operate, JBS considers “always doing the right thing” a non-negotiable expectation. All team members are required to conduct themselves ethically, transparently, honestly, and legally under the guidelines set forth by the JBS Global Compliance team.
Our Global Compliance Program
In 2022, JBS appointed Mike Koenig as Global Chief Ethics and Compliance Officer to reinforce the company’s strategy across global operations and build upon existing regional frameworks and expertise. Mike reports directly to the Chairman of the Board of Directors and is supported by six dedicated senior managers, one in each country where we operate. Under Mike's leadership, the Global Compliance team is responsible for creating and disseminating the processes, policies, channels, and programs that encourage ethical conduct in all of the company’s transactions and relationships.
To make ethics and compliance a part of our DNA, part of the fabric of our company, and part of who we are on a daily basis. We are dedicated to partnering with our business and operational units across the world to ensure our practices meet the highest legal and ethical standards and promote the core values that define our company.
How we will meet our mission:
- We will have clear and understandable policies.
- We will periodically review and update those policies as needed.
- We will regularly provide education and training to all personnel, at every level of the company, on those policies.
- We will regularly monitor our compliance program and make improvements when necessary.
- We will be available and accessible to discuss issues – big and small, whenever and wherever they arise – with all our personnel.
- We will pro-actively communicate and collaborate regularly, through a variety of channels, with all our personnel to hear their concerns, issues and questions, and offer guidance and support to ensure that they comply with the law, regulations and policies.
- We will have a robust, confidential Ethics Line where anyone can report potential violations of law, regulations and policy without any fear, whatsoever, of retribution.
- We will investigate and resolve all allegations of misconduct through a documented process.
- We will have an Ethics and Compliance Department Policy that clearly delineates roles and responsibilities within the Department.
- We will ensure that the Ethics and Compliance Department is staffed with qualified people performing tasks consistent with their experience.
- Across our regional operations, supplementary compliance teams, strategies, and programs are led by each region’s senior compliance manager. To learn more about the JBS Brasil compliance program, please visit our website.
Across our regional operations, supplementary compliance teams, strategies, and programs are led by each region’s senior compliance manager. To learn more about the JBS Brasil compliance program, please visit our website.
Our Nine Compliance Program Pillars
1) Lead Behavior
JBS leadership is responsible for promoting a culture of compliance and setting an example for good practices. Their visible support and commitment are crucial to encouraging...
1) Lead Behavior
JBS leadership is responsible for promoting a culture of compliance and setting an example for good practices. Their visible support and commitment are crucial to encouraging team member adoption at every level of the company.
2) Assess Risk
Periodic identification, classification, and management of risks allows us to proactively prevent and mitigate issues most critical to our business and continuously improve our policies and procedures.
3) Develop Policies and Procedures
Clear, direct, and consistent policies and procedures based on risk assessment results guide our team members in their daily activities. Policy topics include employee...
3) Develop Policies and Procedures
Clear, direct, and consistent policies and procedures based on risk assessment results guide our team members in their daily activities. Policy topics include employee conduct and behavior, anti-bribery/anti-corruption, anti-trust/competition, international trade and sanctions, conflicts of interest, and hospitalities (gifts, business meals, and entertainment).
4) Conduct Trainings
Frequent, engaging, and targeted training, consistent with the activities performed, is provided to all team members in the most appropriate format (in person, online, or by video) to ensure the highest effectiveness.
5) Promote Reporting and Conduct Investigations
The JBS Ethics Line is made available 24/7 to all team members in multiple formats and languages and guarantees anonymity and non-retaliation. Adoption is encouraged through the...
5) Promote Reporting and Conduct Investigations
The JBS Ethics Line is made available 24/7 to all team members in multiple formats and languages and guarantees anonymity and non-retaliation. Adoption is encouraged through the “Speak Up Campaign” and investigations are conducted and closed by appropriate personnel, and administrative or disciplinary action is taken when warranted.
6) Communicate Regularly
General and targeted communication campaigns are distributed to reinforce good practices among all team members and increase transparency around the evolution of our compliance program.
7) Implement Controls
Ongoing management and improvement of advanced control systems allow for faster and more effective detection and prevention of risk transactions.
8) Monitor Effectiveness
The continuous monitoring of our compliance program itself through both internal and third-party evaluations provide meaningful improvements over time.
9) Extend to Third Parties
Third-party vendors are required to follow our same high standards for ethical business conduct and integrity, and comply with all applicable laws, regulations and rules.
In 2022, we formed a Global Executive Compliance Committee with the primary purpose of helping create a more uniform and consistent compliance program across all company entities. Made up of JBS executive leadership and advised by senior legal counsel as needed, the Committee is tasked with overseeing continued improvements and enhancements to our global compliance program and promoting a company-wide culture of compliance for our team members, stakeholders, business associates, and customers.
After a period of sequential acquisitions, the appointment of both our Global Compliance Team and Global Executive Compliance Committee proved vital achievements for strengthening alignment throughout the company.
Beyond this Committee, all JBS leadership and management play a key role in fostering and spreading our global compliance strategy across the company with support from our Mission, Values, policies, and reporting mechanisms.
We have partnered with two leading third-party firms to conduct comprehensive risk assessments of our current compliance program and structure, as well as other potential priority risks. In addition, a third group was retained to assess the maturity and effectiveness of our program.
We are currently in the process of reviewing recommendations and implementing enhancements based on these assessments.
Developing Policies and Procedures
The JBS Code of Conduct and Ethics is available in five languages (Portuguese, English, Spanish, Italian, and French) and sets clear behavioral guidelines and standards to ensure appropriate workplace conduct, efficient and safe operations, and the well-being of our team members. The Code has policies for each of the company’s major risk areas, including team member safety, food safety, environmental compliance, animal welfare, corporate ethics, workplace conduct, and taxation and finance.
In addition to mandatory early Code of Conduct and Ethics training, new team members also receive an ethics handbook during orientation and are expected to 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.
Additional policies and procedures focused on specific topics have also been created to help employees and service providers carry out their work at JBS, for example:
- Global Anti-Bribery and Anti-Corruption Policy
- Global Conflict of Interest Policy
- Global Non-Retaliation Policy
- Antitrust Policy
- Related Party Transactions Policy
- Policy for Engaging with Governmental Entities and Officials
- Third-party Due Diligence Policy
- Policy for Offering/Receiving Gifts, Presents and Entertainment
- Documenting Competitive Sensitive Intel Policy
- Ethics Hotline Procedure
- Procedure for Investigating Grievances
During this past year, we increased trainings and adopted training key performance indicators (KPIs) across our global operations. Highlights include:
- Conducted a three-hour, in-person senior leadership compliance workshop with 50 of the company’s top executives.
- Conducted a two-hour, in-person director and manager workshop with more than 200 leaders.
- Conducted a 1-hour, in-person middle and senior manager workshop with more than 1600 leaders.
- Provided anti-bribery/anti-corruption e-training modules to all JBS USA and Pilgrim’s salaried employees as well as all JBS Brasil employees with computer access. We also conducted more enhanced and targeted anti-bribery/anti-corruption training in person to certain employee groups, such as international sales and international logistics.
- Conducted a 3-hour, in-person Ethics Line and investigation workshop for Human Resources leaders.
- Created leadership KPIs to ensure completion of required trainings.
- Prepared a Compliance Calendar to set forth a regular and consistent cadence of future trainings.
Promoting Reporting and Conducting Investigations
To support the ongoing effectiveness of our compliance program, we provide both anonymous and non-anonymous ways for our team members and third parties to report grievances without retaliation or fear of retaliation.
Most notable is the JBS Ethics Line, which is available 24/7, free-of-charge, in 18 languages to every team member and third-party partner in every country where we operate to accommodate our diverse global workforce. Through this service, an independent, external third party receives reports, whether anonymously or by name, on irregularities or violations of the JBS Code of Conduct and Ethics, JBS Code of Conduct for Business Associates, other JBS policies or procedures, or regulatory requirements. The reports are then sent to the Global Compliance team for review and appropriate investigation. In 2022, approximately 5,743 grievances were submitted to the Ethics Line, of which 100% were investigated and 97% were closed by appropriate personnel, and administrative action was taken where warranted. The remaining 3% of cases were closed in 2023.
Number of JBS Ethics Line Cases
In 2022, we launched our “Speak Up Campaign” in North America, Europe, and Oceania to encourage reporting misconduct and/or policy violations through the JBS Ethics Line or other reporting avenues. The slogan behind this campaign is “If you report it, we can resolve it.”
Executive leadership was also engaged to amplify messaging through compliance workshop and training presentations, in-person discussions with regional teams, and email communications.
This past year also marked the publishing of an internal Ethics and Compliance Newsletter and Compliance News, which continue to be published on a regular basis and cover the following topics:
- Leadership and governance
- Policies published
- Trainings launched
- Trending compliance topics
- Compliance conferences and events throughout the company
In addition to reviewing and enhancing existing financial controls related to anti-bribery/anti-corruption in partnership with our Internal Audit team, preventative and detective controls are continuing to be developed in our JBS USA and Pilgrim’s operations to mitigate risks based on our recent risk assessment, and a thorough review of system set ups and rules is being performed in JBS Brasil based on the recent risk assessment and internal and external audits.
Using data from our Ethics Line reports, we monitor overall team member perceptions. Looking ahead, we plan to expand our monitoring capabilities by such actions as developing standardized investigation procedures across our global operations and inserting complaints received outside of the Ethics Line into the Ethics Line platform.
Extending to Third Parties
Complementary to our JBS Code of Conduct and Ethics, we simultaneously have a Code of Conduct for Business Associates available in four languages (Portuguese, English, Spanish, and Italian) to help ensure that our value chain partners apply the same ethical business practices to their operations that we do.
Currently, we are implementing third-party due diligence systems to help improve and standardize our vendor intake, tracking, and evaluation.
We of course recognize that no compliance program, policy, or mission statement can account for every topic, issue, or risk area that may arise during the daily course of running a large scale, diverse and international business. Inevitably, situations will arise that do not neatly fall within any particular policy. When such situations arise, we will address them on a real-time basis using our best judgement and discretion, consistent with the highest ethical principles.