Ethical Behavior

Our company is built upon a solid business foundation, represented by a set of principles that guide our performance and are expressed through our relationships, attitudes, and behaviors, as well as our products, processes, and results. These principles are part of the Votorantim DNA, a document into which Votorantim’s best practices, along with its beliefs and values, have been incorporated. It has been compiled over the course of Votorantim’s 100-year history and extends to its invested companies. GRI 102-16

During the Nexa Integration process, the gradual consolidation of values and beliefs in our international units has been the basis for the formation of a unique culture. In Peru’s case, for example, the Cajamarquilla unit (which has been part of the company for over ten years) has the Votorantim DNA consolidated into its practices and processes. In our mining units, implementation is in progress. It is very focused on information dissemination by the leadership in those facilities and already producing positive results.

Please have a look at our beliefs and values at (www.nexaresources.com/beliefs-and-values).

100
year history and extends to its invested companies

Compliance

We maintain a Risk Management and Compliance area, which is overseen by the Finance Department and receives support from the Internal Audit Committee. This structure is responsible for dissemination and management of the Nexa Compliance Program, which is applied to all units in the countries where we operate. The program lays out a series of activities and instruments to enable the proper management of compliance issues.

The Compliance Program is also supported by documents that underpin our work, which address ethical issues and business transparency. Included here are our Corporate Policy on Internal Controls and Compliance, which was created in 2015 and is in line with best market practices, as well as our Anti-Corruption Policy and our Code of Conduct, which establish directives that serve as the basis for our relation with internal and external stakeholders. GRI 102-16, 103-2, 103-3

Revised in 2016, and analyzed and approved by the Board of Directors, these documents address aspects of our operations, such as human rights, political contributions, conflicts of interest, labor rights and responsibilities, among other topics of interest between parties. Should any questions or concerns arise, individuals are advised to consult these policies, which are available at www.nexaresources.com/corporate-governance-overview. If questions or concerns persist, individuals should contact the compliance team and, thereby, avoid the possibility of any misconduct. GRI 102-17, 408-1, 409-1, 412-2

In 2017, all employees and suppliers had online access to the Code of Conduct and Anti-Corruption Policy. For employees with computer access, there were also online training sessions related to the Code and the Anti-Corruption Policy, which reached 64% and 60% of employees and suppliers, respectively. Our objective is to reach 100% of employees in 2018. In the period, no cases of corruption involving employees or business partners were confirmed. GRI 205-2, 205-3

Compliance Program

In 2017, as a result of the IPO process, the Risks and Compliance division broadened the basis of the Compliance Program to make it more compliant with anticorruption, as well as antitrust laws and regulations governing the Canadian and U.S. capital markets. As a result, higher standards have been established, with greater precision of information, filling gaps, and proposing improvements to the system, among other benefits. GRI 206-1

As part of this process, we sponsor Compliance Week, which includes observance of the UN-established International Anti-Corruption Day on December 9. At that time, during a presentation in our auditorium in São Paulo, we discussed compliance issues pertinent to our business. Among the topics covered were Canada’s Extractive Sector Transparency Measures Act (ESTMA). The legislation addresses the reporting about payments made to government entities (such as taxes, dividends, bonuses, etc.). The concepts therein relate to extraction activities in all countries in which we operate. Participating at the event, in São Paulo and live videoconferencing, were approximately 100 managers representing all of our units in Brazil and Peru, who were able to watch recorded messages from the company’s CEO and CFO.

Another highlight during the year was a review we conducted of our supplier base, with support from Thomson Reuters. Evaluating all Nexa units, we assessed a total 9,137 suppliers, registered since 2014, for a variety of aspects, such as human rights, labor, anti-corruption and finance practices, among others. Of the total evaluated, 114 suppliers presented some concerns. In 2018, we anticipate distribution of this work, which will be followed by a more extensive results analysis. If irregularities are confirmed, corrective measures will be employed.

Compliance Program