Established in 2019, SOLAR’s Integrity Program is based on the best market practices and aims to systematize actions aimed at stimulating an ethical corporate culture that meets the expectations of the new social dynamics.
We have several policies and procedures, periodically revised, which evolve and become clearer and more comprehensive every day, being a success factor for the organization. As examples:
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1. Top Management Commitment and Support
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6. Due Diligence |
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2. Risks Assessment
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7. Auditing and Monitoring |
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3. Internal Controls
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8. Training and Communication |
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4. Whistleblower Channel
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9. Internal Investigations |
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5. Code of Ethics and Compliance Policies
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10. Diversity and Inclusion |
We have several policies and procedures, periodically revised, which evolve and become clearer and more comprehensive every day, being a success factor for the organization.
As examples:
- INTEGRITY
At Solar, integrity is a non-negotiable value. Our Integrity Program is the foundation of ethical, transparent, and responsible conduct, aligned with our Code of Ethics and Conduct, applicable legislation, and best market practices. Through this program, we promote an organizational culture guided by compliance, risk management, and a commitment to legality and corporate responsibility. More than ensuring compliance with rules, the Integrity Program seeks to strengthen ethical behavior at all levels of the organization, ensuring that our relationships — internal and external — are always guided by our values.
The Program aims to expand its scope beyond Compliance, creating synergies that foster a culture of ethics, integrity, risk management, and overall compliance.
The Program’s structure is composed of policies, standards, and governance tools that guide the conduct of our employees, partners, and stakeholders. Among its main instruments, we highlight:
Code of Ethics and Conduct: grounded in Solar’s values, mission, and vision, it guides expected behavior for everyone, serving as a reference for daily activities and resolution of ethical dilemmas.
Anti-Corruption Policy: regulates the company’s and its representatives’ conduct before public authorities and the private sector, in compliance with applicable legislation, such as Laws No. 12,846/2013, 8,666/1993, 8,429/1992, 9,613/1998, 13,165/2015, 12,813/2013, and other federal and state legal provisions.
Information Security Policy: establishes guidelines for protecting the company’s strategic data and information, promoting a safe environment aligned with good security practices.
Gifts, Hospitality, Entertainment, and Courtesy Policy: regulates corporate interactions, ensuring that all relationships are guided by legality, transparency, fairness, and respect for competitive principles.
Related-Party Transactions Policy: ensures that relationships with shareholders, officers, and other related parties are conducted ethically, preventing conflicts of interest and promoting fairness.
- ETHICS
Ethics management at Solar is based on a set of guidelines and standards that inform and train all employees, ensuring that the company maintains ethical and transparent conduct in all relationships with its stakeholders. Its purpose is to prevent, detect, mitigate, and report deviations, fraud, irregularities, and unlawful acts, including corruption and bribery.
We do not tolerate, and we actively combat and report, unlawful practices such as bribery, extortion, kickbacks, facilitation payments, corruption, money laundering, fraud, terrorism financing, and any other acts that violate our Code of Ethics and Conduct and applicable laws.
Access the Code of Ethics and Conduct here
- DEVELOPMENT, TRAINING, AND AWARENESS
Solar continuously invests in initiatives to prevent ethical misconduct, promoting a culture of integrity based on compliance with the Code of Ethics and Conduct and other company regulations. Among the main actions, we highlight the Solar Code of Ethics and Conduct Training, mandatory for all employees, which covers rules of conduct, anti-corruption guidelines, and the principles that guide the company’s activities.
In addition to online training, we also hold in-person sessions at our units through the Dialogue of Value program. In these sessions, we reinforce Solar’s values and Code of Ethics and Conduct, encourage open dialogue, and promote active listening between leaders and teams, strengthening collective awareness and the daily practice of integrity.
- TRANSPARENCY
Solar complies with the Anti-Corruption Law (Law No. 12,846/2013), which aims to combat acts of corruption committed by companies, establishing administrative and civil liability of legal entities for acts against public administration, whether domestic or foreign.
To fulfill legal and regulatory obligations, Solar establishes guidelines and standards that must be followed by all employees in their interactions with public authorities, as well as with business partners, benefit plan participants, suppliers, sponsors, and founders.
- ETHICS HOTLINE
The Ethics Hotline is a tool provided by Solar Coca-Cola for employees, suppliers, service providers, partners, or other stakeholders to report or provide information about potential violations of the company’s Code of Ethics and Conduct, internal regulations, applicable legislation (including the Anti-Corruption Law), or acts of corruption in the private sector.
When filing a report, the whistleblower may choose to identify themselves or remain anonymous. Regardless of the choice, all reports are handled with complete confidentiality and seriousness.
The channel is managed by an independent and specialized company, ensuring impartiality in the handling of complaints. Reports are thoroughly investigated by the Compliance area and deliberated by the Ethics Committee. When necessary, they may also be reviewed and/or deliberated by the Ethics, Audit, Risk, and Compliance Committee (CARC) and/or the Board of Directors.
Access via website: www.canaldeetica.com.br/solarcocacola
Phone: 0800 591 7187
- COMMITMENT
Solar acts rigorously in investigating any identified misconduct. When irregularities are confirmed, corrective and disciplinary measures are promptly applied, and cases are reported to the competent authorities, when applicable.
We also act proactively to correct failures in the value chain and implement actions to prevent recurrence. Our commitment is to ethics, integrity, and respect for our values in every area of operation.
Whistleblower channel:
0800 591 7187 (24 hours x 7 days a week)