Ethics and Integrity at Cocam

Updated on January 2, 2024.

As part of our solid commitment to ethics and integrity, Cocam implemented an Integrity Program in 2023. This program not only provides clear guidelines for handling demands but also serves as a guide for making more efficient decisions, ensuring that our practices align with the highest ethical standards, becoming an important keystone for sustainability and organizational success.

We aim not only to meet legal obligations but to foster a culture grounded in transparency, compliance, and ethics at all levels of our organization, establishing relationships based on these values with all our stakeholders.


Integrity. refers to the quality of being honest and ethical.
At Cocam, integrity involves observance to high moral standards, transparency in actions, and a culture that values honesty at all levels.

Program Development
Unwavering commitment to promoting the highest standards of ethics, legality, and compliance in all our activities.

Compliance. Refers to execution to established norms, regulations, and standards.

Ensuring that Cocam's practices and operations (set of processes and policies) align with these principles.

Compliance Culture
Promotes employees' and stakeholders' commitment to norms and regulations, encouraging integrity and ethical behavior.

Commitments of our Program

- Act with integrity and honesty in all actions and decisions.
- Promote training, technology, and qualified personnel.
- Promote a work environment where reports of irregularities are encouraged and treated with confidentiality, privacy, and respect.
- Comply with applicable laws and regulations in all jurisdictions where we operate.
- Identify, assess, and mitigate risks related to integrity and compliance.
- Take corrective actions and hold accountable when necessary.
- Ensure transparency.

Our Senior Management

Leads by example, demonstrating commitment to established values and ethical principles (Exemplary Leadership).

Allocates the necessary resources to implement and maintain an effective Integrity Program (Adequate Resources).

Encourages all employees to actively engage in observing with our compliance policies and procedures (Support and Involvement).


We also commit to

Monitor changes in legislation and adjust our processes as necessary (Legal Compliance).

Implement a risk prevention action system (Risk Management).

Establish an audit policy and regular monitoring to assess the effectiveness of our integrity program (Audit and Monitoring).

Regularly communicate our progress regarding the Integrity Program to stakeholders (Transparency and Communication).

Our Organizational Structure

The organizational structure is formalized through the Organizational Chart (ORG-723-001), which is accessible for consultation in the Quality Management System.

Pillars of our Program


1. Commitment and support from senior management
2. Unit responsible for implementing the program
3. Profile analysis and risk management
4. Structuring of rules and instruments
5. Continuous monitoring of the program
6. Effective communication with all involved parties

Objective of our Program

Our purpose is to establish internal transparency mechanisms through controls and audits, aiming to meet legal requirements and make adjustments whenever necessary or requested. The goal is to inform both employees and all stakeholders about Cocam's social commitment and ethical conduct. In this way, we seek to reduce business risks by proper complying with applicable company standards.

1. Prevent harmful acts and empower the program to detect them
Report any misconduct to the competent authorities through legal channels (self-disclosure).

2. Ensure that leaders, employees, and all related parties are aligned with the goal of preventing and mitigating risks
Follow the latest corporate governance practices aligned with the values, principles, and standards necessary to fulfill Cocam's mission.

3.Ensure integrity, ethics, and compliance
Promote a corporate culture based on compliance, transparency, legality, and social responsibility in Cocam's organizational practices.

4. Minimize risks, ensuring business sustainability
Strengthen Cocam's reputation and actively contribute to building a fair, ethical, and integral society.

Rules of Consequences

Within this program, consequences for violations by employees have been defined. This includes measures such as corrective actions, training, and disciplinary measures related to behavioral attitudes, and, when necessary, may result in dismissal. The application of these sanctions will be conducted fairly and proportionally, considering the severity of the offense.


a. Gradation of Sanctions (Behavioral attitudes)
b. Precondition of Training (Reintegration)
c. Corrective Actions and Contract Revocation

Within this program, consequences for violations by third parties have been defined. These measures have been carefully outlined, aiming for proportional and fair approaches, ensuring an appropriate response to the severity of the infractions.


a. Formal Warning, Review, and Audit
b. Temporary Suspension of Contract and/or Contract Review
c. Mandatory Training and Education
d. Financial Penalty, Contract Revocation, and Legal Actions
e. Exclusion from Future Business Opportunities

Integrity Committee

A company area with autonomy and independence, responsible for the execution, decision-making, monitoring, and constant review of this program.


OBJECTIVE: Inspire, promote, and supervise the application of guidelines and best governance practices, as well as encourage initiatives that aim to disseminate ethics and integrity.

If you have any doubts or concerns related to Integrity, please contact us at the following email address:

Learn more about Cocam's Reporting Channel here.

The Reporting Channel is available for anyone, whether an internal employee or a third party, who wishes to report a suspected violation of the Code of Ethics or Third-Party Code of Conduct. We guarantee a fair and independent investigation of the facts. The shared information is treated with absolute confidentiality, ensuring the protection, privacy, and confidentiality of both the whistleblower and the accused. Furthermore, it is ensured that there will be no form of intimidation or retaliation against the whistleblower.

Defense Line

In order to establish a robust Integrity Program, defense lines have been implemented that play a crucial role. These lines are represented by three distinct layers, ensuring that Cocam maintains its integrity, leadership, and transparency in all operations.

1st Defense Line: Provision of Resources and Risk Management
In the first defense line, the Directors and Management (Area’s Representatives) play an essential role, ensuring the organization's integrity, leadership, and transparency.

2nd Defense Line: Expertise, Support, Monitoring, and Questioning about Risks
In the second defense line, Leaders and Immediate Superiors take on responsibilities for organizational routines in their sectors, acting as specialized support, continuously monitoring activities related to their functions. They ensure the rigorous implementation of guidelines and policies, offering support, monitoring, and questioning about practices that may compromise integrity. This layer plays a fundamental role in ensuring a safer and ethical organizational environment.

3rd Defense Line: Independent Evaluation and Advisory
Finally, the third defense line, composed of External Audit, ensures an independent evaluation and advisory regarding the achievement of set objectives. Validating the program, this instance plays a crucial role in ensuring the effectiveness of the integrity system, providing confidence and transparency both internally and externally.

By adopting and strengthening these defense lines, Cocam demonstrates its unwavering commitment to integrity and establishes the foundations for sustainable success in its ethical and challenging business environment.

Revisions from the Program

Continuous and thorough review of Guidelines, Policies, and Procedures is an essential component for the effectiveness of our Integrity Program. This process not only ensures compliance with ethical and regulatory standards but also reinforces Cocam's commitment to Integrity, transparency, and responsible practices. Among the central documents subject to reviews in the program are:

Cocam reiterates its ethical commitment to society, outlining the expected behavior of its employees and direct or indirect involved parties. The document reflects values and policies, provides moral and ethical guidelines to guide actions and decisions. It emphasizes the importance of respecting differences and transparency in relationships to promote sustainability. This Code establishes behavior standards, requiring compliance with current norms and international standards, including human rights. It reinforces Cocam's ethical commitment in relationships with employees, customers, suppliers, government agencies, the community, and shareholders.

In addition to its initial commitment, Cocam has established clear guidelines and conduct standards for suppliers, covering legal compliance, internationally recognized standards, and ethical practices. We commit to negotiate ethically, ensuring acceptable working conditions and adhering to high standards in quality, safety, and socio-environmental requirements in its supply chain.

Key documents guiding Cocam's and its Suppliers' ethical conduct:

   Senior Management

   Message to Suppliers of Materials and Services

Immediate Actions

Aiming to strengthen an ethical environment, transparency, and compliance with current regulations at Cocam, the Integrity Committee has defined 6 (six) actions to be implemented between 2023 and 2025 within this program:

1. Compliance with Legislation
2. Ethics and Compliance Training
3. Internal Investigation, Due Diligence, and Audit
4. Review of Contracts, Guidelines, Policies, and internal documents
5. Continuous review of risk assessment
6. Continuous promotion of Ethical Culture