Discover our Compliance Program
Committed to Integrity and Ethics
In addition to our constant effort to expand the applications and market for Niobium, we are deeply committed to fostering an organizational culture that sets a benchmark for dedication and adherence to rules, legislation, and internal policies. This commitment extends to our respect for clients, suppliers, employees, shareholders, the environment, and the communities in which we operate.
A structured Compliance Program, with actions for detection, remediation, prevention, and risk mitigation, is an essential tool for maintaining our high standards. Implemented in an industrial plant with initiatives designed to promote ethics and transparency, it also contributes to a fairer and more inclusive society.
We believe that integrity is the greatest legacy we can leave for the next generations of employees, and it is also a core value for the longevity of our business.
How does our Compliance Program works?
Our Compliance Program is a comprehensive initiative designed to foster a sense of responsibility and integrity. In addition to our policies and procedures, the Compliance team is actively present on a daily basis, whether at the industrial plant, corporate offices, or regional commercial
locations, to address specific business needs and maintain direct contact with employees and third parties.
To achieve this, we ve implemented a range of initiatives to make Compliance more accessible and educate everyone on topics like ethics and transparency in an easy, practical, visual, and interactive way.
The core premise is to show that Compliance is much more than just bureaucracy.
Here are some examples:
Compliance Partners
Every year, employees have the opportunity to sign up to become Compliance Partners, attending monthly meetings where we discuss topics
related to the Compliance field. These meetings also explore ethical dilemmas and how they apply to our daily lives, both inside and outside the
company.
The goal of these meetings is to help employees gain a deeper understanding of how the Compliance Program works, enabling them to share this knowledge with their colleagues across departments
Integrity Day
Every year, we host Integrity Day, an event that brings together employees and third parties to participate in discussions with the Compliance team, engage in activities designed to develop leadership skills, and interact with external professionals to share experiences related to Compliance.
DDS – Daily Safety Dialogue
The plant teams conduct Daily Safety Dialogues before starting their activities each day, with the goal of addressing both physical and psychological safety for employees. Periodically, the Compliance team participates in these DDS sessions across different areas and shifts to discuss topics such as harassment, conflicts of interest, fraud prevention, corruption, and more. This initiative is crucial for bringing the Compliance team closer to employees, as well as promoting the company s Confidential Hotline and providing guidance on how to use it
IWPWA Internal Week for the Prevention of Workplace Accidents
Once a year, CBMM hosts Internal Week for the Prevention of Workplace Accidents, during which the Compliance team conducts training sessions on psychological safety, as well as moral and sexual harassment in the workplace.
This initiative is extremely important because the traditional view of workplace accidents is often associated with physical injuries. However,
accidents related to psychological well being are rarely discussed. That s why Compliance training aims to shed light on this other aspect of
workplace accidents.
In addition to these initiatives, the Compliance Team provides training for all areas within CBMM, tailored to the specific needs of each role and function. These personalized training sessions are designed to integrate seamlessly into the daily routines of all employees.
Everyone's Responsibility
Through initiatives like these, CBMM aims to demonstrate that the Code of Ethics and Conduct, as well as the other policies of the Compliance
Program, reflect the company s values. Therefore, responsibility for compliance is not limited to the Compliance team it belongs to everyone, guiding the behavior of CBMM employees and third parties.
In this way, we hope that the daily activities of employees and third parties are guided by integrity and transparency, encouraging their colleagues to do the same. To achieve this, it is essential that any misconduct or violation of policies be promptly reported. We provide reliable mechanisms reliable mechanisms for handling reports made by employees or external individuals, ensuring confidentiality, anonymity, and protection against retaliation for good faith whistle blowers and those who cooperate in the investigation process.
Reports can be made to CBMM s Compliance Department or through our Confidential Hotline, ensuring fair and confidential treatment for all good faith reporters.
Confidential Hotlin
Global Recognition: Our ISO 37001-Certified Anti Corruption Commitment
Our Compliance Program was built on our conviction to do what is right and to maintain a company where culture is a differentiator, as the future of any organization depends on practices rooted in ethics and integrity.
As a direct result of these efforts, we have received formal recognition for the rigorous practices adopted by our company in the fight against corruption, through ISO 37001 certification. This standard, issued by the International Organization for Standardization (ISO) and granted in Brazil by Inmetro, specifies requirements for the evaluation and certification of Anti-Bribery Management Systems. The processes and controls we have
implemented in accordance with the ISO standard are now an integral part of CBMM s Compliance Program, further strengthening our governance and ethical business practices.
Joining the Global Group of Ethical Companies
This certification places us among an exclusive group of 204 companies in Brazil and 5,969 companies worldwide that are dedicated to controlling and mitigating risks related to corruption and bribery in their operations and hold this certification.
Achieving ISO 37001 is not only a milestone for CBMM but also a reflection of our ongoing commitment to integrity, transparency, and good governance practices. We remain dedicated to maintaining and improving our standards, promoting an ethical and sustainable business environment for all.