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Investor Relations / Corporate Governance

Corporate Policy for Prevention and Combat to Illicit Acts
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DURATEX S.A. CORPORATE POLICY FOR PREVENTION AND COMBAT TO ILLICIT ACTS

  1. Objective

    To identify actions which are non-compliant with the regulatory and self-regulatory environment and propose adequate measures.

  2. Policy Control

     Risks and Ethics Committee

  3. Scope

    Duratex  Companies, subsidiaries and affiliated companies in Brazil and abroad.

  4. Regulatory and Self-Regulatory Environment

    For being an open capital company with shares traded in the stock exchange, it must comply with CVM specific regulations and accounting practices accepted in Brazil, including in accordance with the Brazilian Corporate Law and CVM, Code of  Ethics and Conduct and other internal applicable norms.

  5. Illicit Acts to be Combated

    There are different types of activities which configurate illicit acts, including the different modalities of fraud and money laundering operations.

    Examples of fraud are: undue appropriation of assets, adulteration and falsification of financial documents and data, electronic fraud, undue use of inside information and intentional omission/manipulating acts in accounting transactions, records and statements,  inclusion in expense accounts submitted to the Company of personal expenses or expenses which are non-compliant with the Policies and norms in effect,  rise in mileage run with own vehicle at Company service when requesting reimbursement, among others.

    Typical money laundering operations are those, which insert funds resulting from illegal acts in legal economic activity circles, which may cause damages to Company image and reputation.

  6. Preventive Actions

    6.1. Documental Record: In accordance with item 17 of the Code of Ethics and Conduct, all transactions must be supported by a documental record to ensure business transparency and control. For this reason: (i) All transactions – as payment of penalties, event sponsorship or any other action involving monetary amounts must be supported by the proper documentation and be correctly and immediately recorded under the pertinent accounts and within the adequate periods and (ii) No payment or receipt by Itaúsa Industrial companies can be approved or carried out with an intention or understanding that part or all of it shall be used for a purpose other than that described in the document that records the transaction. All doubts concerning the documentation must be addressed to the Audit Area.  

    6.2. Internal Audit: The Audit Executive Management holds controlled, although unrestricted access to the information required for the development of their analyses, either being data extracted on an independent basis from information systems, or subsidies obtained from interviews with employees at all hierarchic levels  (strategic, operational and productive). The methodology for analysis and tests must be evaluated at each work, depending on the audited process, always privileging the good development and allowing adequate conclusion.

    The department uses the Canadian software ACL – Audit Command Language, on an advanced basis, for routine monitoring and for most of their audits, being not disregarded the contracting of independent auditors to assist in the monitoring of compliance.  

    6.3. External Audit: Among the attributions of the Board of Directors is the contracting and dismissal of external auditors to analyze and issue an opinion on Company financial statements.

    6.4. Fiscal Council: The members of the Fiscal Council shall be in charge of supervising the activities of the administration boards. 

  7. Denunciation

    Non-conformities with regulating and self-regulating norms, as well as the occurrence of illicit acts must be promptly informed to the Committee of Risks and Ethics and, whenever possible, supported by material, which proves the denunciation. This may be carried out openly, by means of electronic mail or anonymously, by phone or mail, as follows:

    Electronic mail:  disk.conduta@duratex.com.br
    Telephone: 011 3543-3543
    Mailing address: Risks and Ethics Committee, Av. Paulista 1938 5th floor, São Paulo – SP, 01310-942, Brazil

    Duratex commits to ensure, for this policy, the involvement of its administrators and adherence of all its employees. For this purpose, it promotes dissemination of the Organization ethical values, practices a rigid employee selection and monitoring process, discloses prevention guidelines and keeps a team fully dedicated to the management and execution of preventive activities, besides promoting different qualification and recycling actions. Knowledge of any infraction to this Policy and not reporting the fact represents a serious fault, subject to punishment.

  8. Penalty

    In case it is verified the occurrence of any illicit act the Committee of Risks and Ethics may warn the infractor or submit the case to a higher hierarchic level. Any eventual internal penalties shall not exempt the infractor from legally responding for their acts.

  9. Continuous Improvement

    No matter how effective our established processes and procedures are, evil-minded individuals and organizations eventually discover unusual ways to break the law. For this reason, Duratex continuously seeks to keep updated on the best practices, by means of investments and ongoing qualification of its employees.
Updated on August, 2008