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Anti-bribery and corruption Supergasbras, Brazil 5/6/2020

The importance of a trustworthy communication channel

The importance of a trustworthy communication channel

As a company, we ask people to ‘Speak Up’ if they are aware of an attempt to breach our Code of Conduct, a breach, or the potential for there to be a breach. We ask them to discuss this with the person involved, their manager, a member of their Human Resources team or their Compliance Officer. However, the employee may feel that this is not possible.

Having a trustworthy, confidential communication channel available where employees can raise their concerns to all employees and outside stakeholders is of paramount importance. Marco Rogério Ferraz de A. Junior, Compliance Officer at Supergasbras in Brazil, describes the success of the Speak Up programme.

Marco Rogerio Ferraz GREY
“I have witnessed the growing importance of the channel. Analysing the maturity of the programme, I conclude that it made our organisation a better place to work”

Marco Rogério Ferraz de A

Compliance Officer at Supergasbras in Brazil

“As the longest-serving member of the internal committee in charge of analysing cases submitted via the Speak Up tool, I have witnessed the growing importance of the channel and how people improved their use of this important tool. Analysing the maturity of the programme, I conclude that it made our organisation a better place to work. A lot of effort has been devoted to the Speak Up programme at Supergasbras over the years. We are very proud of that!

The Speak Up programme is all about credibility. Like a newspaper that you read because you believe in the journalists who write for it, this channel exists to be trusted by people as a place where concerns related to a breach of our policies can be brought. They must trust that everything will be seriously analysed, and that remedies and improvements will be applied where necessary. When concerns are reported it is clear that they are taken seriously, which helps to build trust in the programme.”

Responding to reports

“Investigations should be done properly, ideally within the business unit. However, confidentiality and non-retaliation must be taken into account to determine who is best placed to conduct the investigation. With this in mind, all Speak Up reports are first checked by a small team at our headquarters in the Netherlands. When they decide that the report can be dealt with in the business unit, they forward it to people who have been trained to investigate and have no involvement with the reported matter.

At Supergasbras, Speak Up reports arrive to me and Vinicius Santos, a colleague from the Audit team. We are what is called the gatekeepers of the cases. After conducting a preliminary analysis of the nature of the case, we divert the reports to other colleagues from Legal, Audit and Human Resources for the proper analysis and investigation. The cases we consider more sensitive or complicated are taken to our Ethics Committee for discussion and deliberation. We take this responsibility very seriously: SHV Energy has trusted us to perform a very important task, and a colleague of ours has trusted us to help resolve his or her concerns.”

Raising awareness of the programme

“Improving the Speak Up mechanism as an effective channel within the company is also about informing people how and when they should use it. The introduction of any new process always provides opportunities for adaptation and improvement. The days where we received Speak Up reports asking us to help fix broken lights or adjust the temperature of an office are gone. Although concerns like this do need to be raised, the Speak Up tool is not the right channel for these types of concerns. Thanks to consistent internal communication, the great majority of the reports we receive today are relevant.

It is important to stress that we strive to have an open culture and the Speak Up tool should not be the first option to raise a concern. People should not be afraid of openly addressing their concerns to other members of the organisation. However, in cases where raising the concern to the person involved, a manager or someone else within the business unit is not possible, Speak Up is a valuable resource.”