2010 - Embraco

Interview Profile ManagementdifferentialsSustainaBIlityEnergyEffICIencySupply valuechain ChaINSoCIalinvestmentInternalPublICMATERIalItyGRIContent56CompleteParcialSO2Percentage and total number of business units submitted to risks assessments related to corruption.All our units undergo periodic operational audits. They are determined by the corporate audit committee at the end of each year from risk assessment interviews carried out withthe president and vice presidents.Additionally, our units in Brazil, Slovakia, United States and Italy are within the scope of the Sarbanes-Oxley Law (SOx). This means that they have strict internal control regardingfinancial reports. Employees involved in this process receive specific training, presential or online, through Whirlpool’s Virtual University. The performance and effectiveness ofcontrol systems related to the adequacy of SOx are tested by the Internal Auditors of the company and undergo independent external verification. In 2010, we monitored a total of31 cases (see table).Brazil Slovakia United States ItalyCases evaluated (absolute number) 10 8 5 8Cases evaluated (% of total number of cases existing in the unit) 32 26 16 26SO3SO4Percentage of employees trained on anti-corruption policies and procedures of the organization.Embraco`s positioning against corruption can be found in the Code of Ethics, distributed to all employees, and the integration training courses for new employees covers themessuch as money laundering and anti-trust actions.Among the administrative and managerial positions, these themes are subject to periodic training, which may be in the presential or online format. In 2010, trainings onpreventing money laundering covered 100% of the public.The trainings on antitrust cases involved 2,128 employees of all units in 2010, including 1,054 in Brazil. By incorporating the theme in the integration training, the percentage ofcoverage was near 100% on this theme.Measures taken in response to incidents of corruption.As in 2009, in 2010 there were no recorded cases of corruption. To avoid this type of conduct, we have made available to the internal public our Code of Conduct, and directeveryone to report any violation of the principles explained in the document. The complaint may be made directly to a superior or via a Hotline, a toll free telephone line withattendants in Portuguese, English and Spanish. The complaints made by employees to this channel remain anonymous and checking the complaint occurs confidentially.Public PoliciesSO5Positions relative to public policy and participation in public policy development and lobbying.Through various forums, we participate in the discussion of public policy and seek to collaborate with the development of the sector where we operate with actions aligned to ourstrategic planning.In Brazil, for example, Guilherme Lima, manager of Institutional Relations, is vice president of the National Research, Development and Engineering Association of InnovationCompanies (Anpei) that brings together companies, representatives of ministries and development public bodies. He also serves on the Advisory Board of the Research and ProjectsFinancing (FINEP), the Thematic Council of Industrial Policy and Technological Development of the National Confederation of Industry (Copin-CNI/Anpei) and the Advisory Board of theCenter for Strategic Studies and Management (CGEE / Anpei). We maintain an ongoing dialogue with trade associations (see complete list on page 40) to ensure that decisions followlegal and ethical standards adopted by us, always focusing on economic, social and environmental sustainability.Through Embraco Slovakia, we support projects developed in partnership with local authorities. In Mexico, the dialogue with the National Council of Science and Technology with thestate government of Nuevo Léon aims to collaborate with the construction of public policies related to innovation, energy efficiency, tax issues, product regulations and certifications.