The Orion Compliance Manual was updated in September 2023.
1.
PRESENTATION
GrupoOrion is a technology company specialized in infrastructure management, preventive and corrective maintenance, building installations and
industrial sectors in the areas of electrical, electronics, air conditioning, hydraulics, generators, structured cabling network, electronic security and automation.
The company also offers complete and personalized solutions for secure environments for Datacenters, including design and implementation of the entire
solution (energy management, automation, fire prevention and fighting, image security, access control and air conditioning
precision).
With more than 20 years of experience in the market, it has a multidisciplinary team with extensive experience and permanently updated, training it
thus providing a service with a high technological standard.
GrupoOrion is committed to ethics, focused on ethical and transparent behavior between the Company and all its stakeholders, which leads it
to the constant search for best integrity practices. It already has an Employee Handbook, which is now complemented by this document.
Therefore, GrupoOrion adopted policies and procedures to establish standards, guidelines and internal controls in order to detect, prevent and
mitigate violations of applicable standards and/or regulations contained in this Integrity and Ethics Manual
This document contains policies and procedures relating to various aspects of the Company's business, which all stakeholders must observe.
The Manual addresses different compliance issues and ethical problems that may arise in the daily conduct of business, without the
intention, however, to exhaust all possible risks in daily operations, since relationships are dynamic and changeable, and the possibility of
unforeseen non-conforming situations, which is why monitoring must be ongoing.
However, in the event of any case that, in the perception of the stakeholder, whether employee, supplier or customer, may violate any principle
or misconduct, our Reporting Channel set up via email Ouviria@grupoorion.com.br is available 24/7
hours per day, ensuring the whistleblower's anonymity to report any activities inconsistent with the policies, principles, procedures and/or
legal requirements.
It is essential for Employees to comply with the orders and requirements of all applicable laws and rules described in this Manual and, in addition
Furthermore, the professional responsibility to act ethically in all professional services and activities in which it is involved.
Compliance
4. BOARD MESSAGE
Our group is approaching nearly half a century since the foundation of its first company. It's nearly 50 years of life and resilience amidst numerous changes in government, economic plans, global and domestic crises, that is, five decades of business operation in an extremely challenging business environment where more than half of the created companies do not survive for only four years.
More important than just the existence time of our company are the vitality indicators we are achieving, with new clients, new products, and other types of services constantly being added to our portfolio of solutions. Despite the recent and severe economic recession we have experienced in our country, the organic growth of the company is an important indicator that demonstrates the correctness of decisions and the coherence of the chosen course.
However, the context of success does not allow us complacency or relaxation, quite the opposite, it drives us daily in the pursuit of meeting the demands of customers, which have been increasingly demanding in terms of deadlines, costs, and delivery quality. It is essential to bear in mind that past success is not and will not be a guarantee of future success. Therefore, it is up to all of us, from now on, and more than ever, to persevere in professional improvement for a better company and a fairer society, ensuring that the coming years are even more fruitful.
5. POLICIES FOR PREVENTION, SUPPRESSION, AND MITIGATION OF RISKS
5.1. Initial Context
The term compliance originates from the verb "to comply" in English and broadly means to comply with rules, norms, and procedures. The word integrity refers to mechanisms for controlling and managing risks to prevent cases of fraud and corruption.
The main objective of this Manual is the control and management of anti-corruption and anti-bribery risks.
In the Brazilian context, we see the enactment of the first law specifically aimed at preventing, combating, and repressing corrupt acts, namely Law No. 12,846/2013, also known as the Anti-Corruption Law.
The Anti-Corruption Law was inspired by foreign examples such as the Foreign Corrupt Practices Act (FCPA) of the United States (1977) and the United Kingdom Bribery Act (UKBA) of Great Britain (2010), placing legal entities liable for prosecution.
The current scenario demonstrates the relevance of an Integrity Program within an organization, having been identified as an essential requirement in some states of the Federation for contracts entered into with the Administration.
Aware of the reputational benefit and the global trend of compliance, Grupo Orion presents its policies for the prevention, repression, and mitigation of risks inherent to its activities.
It is reiterated that ignorance of the rules established herein will not be accepted as justification in case of any non-compliance with the Manual, as commitment is required from employees, managers, and senior management, in addition to the rules already provided in the Company's Employee Handbook.
5.2. Ethics and Integrity Committee (CEI), Compliance Officer, and Whistleblower Channel
5.2.1. Ethics and Integrity Committee (CEI)
The Ethics and Integrity Committee (CEI) of Grupo Orion will be composed of the Executive Director, the Engineering Coordinator, and the Manager responsible for the administrative and commercial area, led by the Compliance Officer, who will be the Commercial Manager, as members, along with one substitute, who will replace any absent member in case of absence or impediment.
The CEI will be constituted by written appointment made by the Senior Management of Grupo Orion, which must provide the minimum infrastructure for the Committee's operation.
The CEI will have the following competencies:
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Receive, process, and judge complaints related to violations of this Manual;
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Investigate, ex officio, violations of this Manual;
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Periodically monitor this Manual.
Led by the Compliance Officer, the CEI will periodically provide training to the Company's employees, including Senior Management, to ensure broad knowledge of this Manual and the Company's Integrity Program. Specific training by department or work group may be necessary.
5.2.2. Whistleblower Channel
The primary mechanism for combating corruption regularly instituted is the establishment of a whistleblower channel, even anonymous, regarding acts that may be considered illegal and/or irregular.
Grupo Orion will use a Whistleblower Channel through the email address ouvidoria@grupoorion.com.br and through an anonymous complaint form below:
Compliance
The Compliance Manual of Orion was updated in September 2023.
1. INTRODUCTION
The Orion Group is a technology company specialized in infrastructure management, preventive and corrective maintenance, building installations both commercial and industrial in electrical, electronic, air conditioning, plumbing, generators, structured cabling network, electronic security, and automation.
The company also provides complete and personalized solutions for secure Datacenter environments, encompassing the design and implementation of the entire solution (energy management, automation, fire prevention and suppression, video surveillance, access control, and precision air conditioning).
With over 20 years of experience in the market, it boasts a multidisciplinary team with extensive and continually updated expertise, enabling it to deliver services with a high technological standard.
The Orion Group is committed to ethics, focusing on ethical and transparent behavior between the Company and all its stakeholders, which drives constant pursuit of best integrity practices. It already has an Employee Handbook, now complemented by this document.
Thus, the Orion Group has adopted policies and procedures to establish standards, guidelines, and internal controls aiming to detect, prevent, and mitigate violations of standards and/or applicable regulations contained in this Integrity and Ethics Manual.
This document contains policies and procedures related to various aspects of the Company's business that all stakeholders must observe.
The Manual addresses different compliance issues and ethical problems that may arise in the daily conduct of business, without intending to exhaust all possible risks in daily operations, as relationships are dynamic and mutable, and unforeseen non-compliant situations may occur, necessitating ongoing monitoring.
Nevertheless, in the event of any case that, in the stakeholder's perception, whether employee, supplier, or customer, may violate any principle or deviate from conduct, our Whistleblower Channel, operational via email at ouvidoria@grupoorion.com.br, is available 24 hours a day, ensuring the anonymity of the whistleblower to report any activities inconsistent with policies, principles, procedures, and/or legal requirements.
It is essential for Employees to comply with the orders and demands of all applicable laws and rules described in this Manual and, furthermore, the professional responsibility to act ethically in all services and professional activities involved.
Therefore, this Manual aims to establish rules, procedures, and mechanisms that ensure and enable continuous compliance with current regulations and regulations related to the Company's own commercial activities and to ethical and professional standards applicable to the Orion Group.
This document also aims to reaffirm that the Company expects all stakeholders, according to the highest levels of honesty, integrity, ethical standards, and always complying with the law, to avoid real or apparent conflicts of interest between personal and professional matters.
This Manual will be available to anyone interested on the Company's website at http://www.grupoorion.com.br/.
Partners, managers, employees, interns, suppliers, service providers, and other agents with whom it transacts or may transact. When this manual uses the term "employee," it refers to managers, employees, service providers, or interns of Grupo Orion.
2. MISSION, VISION, AND VALUES
MISSION
Provide engineering technological solutions, bringing happiness to people in harmony with the environment.
VISION
To be a reference as a technology company, driven by a high-performance team and committed to sustainable development.
VALUES
Quality, safety, sustainability, innovation, and enchantment.
PURPOSE
Making the world a better place.
SLOGAN
Increasingly connected.
3. ORGANIZATION
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The Reporting Channel must be accessible to everyone, including the external public, with the preservation of the confidentiality of the information necessary for investigation, without prejudice to compliance with current legislation in relation to intimacy, private life, honor and image of people.
Complaints must be duly investigated, including with a view to responding to the complainant, if possible, whether due to the origin or unfounded nature of the complaint.
If the result of the complaint, if valid, indicates the need to investigate an administrative, civil or criminal infraction, GrupoOrion must inform the competent authorities.
6. CONTINUOUS TRAINING AND REVIEW OF THIS MANUAL
The Orion Group must periodically promote specific training for all employees and Senior Management, jointly or separately, as applicable, on this Manual and the organization's Integrity Program.
This Manual must be reviewed periodically or whenever new risks are identified, in order to verify the need for updating in relation to changes in scenarios, markets in which the Orion Group operates, changes in current legislation, among other factors internal or external to the Company.
7. SANCTIONS
The Orion Group Integrity Program, to be successful, must be accompanied by sanctions for any of the related parties, including possible contractual termination, without prejudice to compliance with the Company's existing Employee Handbook.
The Orion Group may have Personnel Regulations that specify the disciplinary measures envisaged and the cases in which they apply, in addition to the applicable procedures and the indication of the Compliance area as responsible for providing an opinion on the most appropriate measures to be adopted in the disciplinary field. .
The rules of the Compliance Manual apply to all employees and Senior Management of the Orion Group.