Ethics and Compliance

JBS is committed to ensuring we conduct our business with high ethical standards, and that our team members adhere to all laws, regulations and policies across our global footprint.

This commitment, at every level of the company, is essential to maintaining the trust of our customers, suppliers, third-party partners, investors, regulators, enforcement agencies and other external stakeholders.

Illustrative Image - Compliance Program

Even with the ever-changing business landscape and necessary risk management, JBS considers “Always Do It Right” a non-negotiable expectation of ourselves and our business partners.

Conducting ourselves accordingly also aligns with our core JBS values, and the guidelines established by the Board of Directors, company leadership, and the JBS Global Ethics and Compliance team.

Global Compliance Program

In 2022, JBS designed and implemented a Global Compliance Program that brings Ethics and Compliance consistency across our geographic regions.

Highlights of the Global Compliance Program and its administration include:

Highlights of the Global Compliance Program and its administration include:

Global Executive Ethics and Compliance Committee

A Global Executive Ethics and Compliance Committee to develop, implement and oversee the Global Compliance Program. This Committee is comprised of the four most senior compliance officers in the company, as well as the Chairman of the JBS Board.

Global Chief Ethics and Compliance Officer

A Global Chief Ethics and Compliance Officer to lead the continued development and operation of the Global Compliance Program and team.

Code of Conduct and Ethics and global policies

Maintaining a Code of Conduct and Ethics, and creating global policies across key issue areas, such as Antibribery and Anticorruption, Antitrust, Mergers and Acquisitions, Human Rights, Conflict of Interest, and Non-Retaliation.

Local governance aligned with the global program

While maintaining global oversight, allowing the regions to implement separate policies and procedures to account for local laws and regulations, so long as they are consistent with the global policies.

Regional Ethics Committees

Ethics Committees in each region are comprised of the respective CEOs, CFOs, Heads of HR, a business unit leader, a member of the legal team, and a member of the ethics and compliance department in that region. These Ethics Committees address local issues in the context of the Global Compliance Program.

Close relationship with the Board

Senior members of the Global Compliance Team regularly report to the Board of Directors and routinely interact with leadership.

The Pillars of the Program

The Global Compliance Program is based upon the essential and well-established pillars of an “Effective Compliance Program,” in line with the expectations of regulatory and enforcement agencies:

“Tone at the Top”

Ethics and Compliance begins at the top, and our leaders are committed to ensuring that ethics and compliance is embedded in our business operations. JBS leaders support our mission by promoting a strong ethics culture through their actions every day.

Risk Assessments

JBS routinely conducts company-wide and tailored risk assessments to identify, prevent and mitigate risks. These assessments allow for the proper allocation and focus of resources.

Policies and Procedures

JBS implements and regularly reviews policies and procedures to ensure our team members have clear guidelines, standards and expectations.

Training

JBS has a robust and mandatory training program. Part of this company-wide program includes required annual training on key issue areas. In addition, JBS regularly provides more tailored trainings to specific business and operational units based upon specific job functions.

Communications

Through a variety of means, JBS routinely communicates with leadership and team members regarding historic, emerging and potential ethics and compliance issues.

Ethics Line

JBS has a “Speak Up” culture. JBS operates a 24/7 Ethics Line where team members or third parties can voice any concerns, and do so anonymously if they choose. All allegations are investigated by appropriate and trained personnel, and remedial or disciplinary action is taken when warranted. Relatedly, JBS also has “zero tolerance” for any form of retaliation, embodied in its Global Non-Retaliation Policy.

Third Party Relationships

Using technology, JBS conducts initial and ongoing due diligence on its third parties, and heightened due diligence when necessary. JBS also requires its third-party partners to comply with our Business Associate Code of Conduct.

Testing and Controls

JBS conducts internal and external audits, testing, and surveys to identify potential gaps, implement remedial measures when necessary, and understand how ethics and compliance has been absorbed into JBS culture.

Ethics Line

We foster an open-door culture, with a channel available 24/7, accessible to both employees and third parties. Reports can be made anonymously, and we have zero tolerance for retaliation — a principle required by our Global Non-Retaliation Policy.

linhaeticajbs.com.br

Argentina

0800 666 1659

Brazil

0800 377 8055

Uruguay

0800 401 90861

jbsethicsline.jbssa.com

Australia

1-800-763-983

China

400-120-3062

Mexico

800-681-6945

Canada

1-800-235-6302

United States

1-800-492-3981

New Zealand

0800-002341

Italy

800-727-406

United Kingdom

0-(808)-189-1053

France

0805-080339

Netherlands

0-808-022-0441

Ireland

1800-904-177

Business Associate Code of Conduct

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Code of Conduct and Ethics

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