Ethical behavior GRI 102-16, 103-2, 103-3

We are committed to running our business to the highest ethics and integrity standards and, based on this commitment, in 2018 we optimized our Compliance Program (Programa de Compliance), which specifically spells out the conduct we expect from all of our own and outsourced employees in dealing with a wide variety of different situations. The Board of Directors is one of the main agents in promoting the program and we are determined to ensure its compliance so that we can manage our business to the highest standards, with a penalty for actions that do not conform to our program. The area of Risk Management, Internal Controls and Compliance is responsible for managing and disseminating this program. Linked to the Financial Department, the area is supported by Internal Audit.

One of the main pillars of the Compliance Program is the Nexa Code of Conduct, essential in guiding activities and supporting decisions made at all levels of our company. Based on the century-old values of the Votorantim Group, this document was revised in 2018 and guides our internal behavior and the way we interact with different stakeholder publics. In the year, all BoD members received training in the human rights guidelines. Beginning in the first quarter of 2019, this training will be applied to all our employees. GRI 412-2

The Code of Conduct is a public document, shared with all stakeholders, including employees, suppliers, customers, communities, NGOs, government entities, shareholders and other individuals and organizations with whom we interact, to ensure that we achieve excellence in all our practices.

Our beliefs and values are detailed on the internet ( GRI 102-16

New policies SDG 10.3

In 2018, the Compliance area underwent restructuring, in line with its configuration and global coverage, standardizing the guidelines for all units. We reviewed and optimized our Compliance Program to ensure fulfillment of the laws of the countries in which we operate. We published four new policies (Compliance, Anti-Corruption, Antitrust/Competition, and Prevention of Money Laundering and Terrorism Financing) available in three languages on the company’s website (, as well as nine internal procedures that detail day-to-day management of these topics. SDG 16.5

Analyzed and approved by the Board of Directors, these documents address aspects such as human rights, political contributions, conflicts of interest, worker’s rights and duties, among other topics. Because the Anti-Corruption policy has changed, a new e-learning course is being prepared to be applied to all Nexa representatives in 2019. GRI 205-2

The Code of Conduct has also been updated in the light of the new policies. In addition to online consultation of the documents, doubts can be clarified directly with the Compliance team. The ensure dissemination of the documents to all of the company’s areas and suppliers, an e-mail was sent out and physical materials delivered for consultation. The signing of a Receipt Protocol confirmed that the document was received.

In all countries, we organized a Compliance Day in December, involving board members, managers and general managers. By 2019, these activities will be extended to the entire organization. No cases of corruption or violation of antitrust laws involving employees or business partners were confirmed in the period. GRI 205-2, 205-3, 206-1

Compliance-related issues are reported to the Audit Committee, which is responsible for periodically bringing them to the attention of the Board of Directors.

Ethics Line GRI 102-17 SDG 5.1

To become cognizant of, analyze and resolve any issue related to Compliance or to report possible violations of the Code of Conduct or any policy, procedure, law or regulation, we have made an Ethics Hotline available to the in-house and outside publics. Through this channel it is possible to fully, anonymously, report any suspicion of financial crime, fraud, corruption, discrimination, harassment or other types of ethical violations. Available in Portuguese, English and Spanish, the service can be accessed through the electronic address: ( or by phone (Brazil: 0800-892-0741 (Portuguese); Peru: 0800-50-000 (Spanish) and 0800-50-288; United States: 1-855-888-9926; Austria: 0800-200-288; Canada 1-855-888-9926 and 1-855-350-9393; and Luxembourg: 800-201-11 (English and French).

The channel is administered by an independent and qualified outside company. This organization receives all complaints, makes a preliminary classification and releases systemic access to members of the Nexa Conduct Committee who are responsible for handling complaints, conducting investigations and recommending corrective measures, when necessary.

Conduct Committee GRI 102-17

The Conduct Committee is an executive body composed of Nexa’s CEO and those responsible for the Legal, Human Resources, Compliance and Internal Audit areas. It may request the participation of other areas, if necessary. In any case involving members of the Executive Board, the Conduct Committee shall refer the matter to the Audit Committee and the Board of Directors to always assure the independence of the process. These bodies are responsible for investigating and managing any penalties.

All reports are evaluated and monitored until they are duly resolved. In 2018, 139 reports were received through the channel, being resolved and/or closed in an average period of 28 days, compared to 41 days over the previous year.

Complaints and denunciations of another nature, such as customer services, supplier management or community-related issues are addressed to Customer Service (SAC) and, in the case of labor issues, to the Human Resources (HR) area.

7 For the 27 cases considered to have standing, 10 were related to harassment and/or abuse of power and 17 to persecution, disrespect and discrimination. In all cases, corrective measures were adopted, such as dismissals, verbal warnings, suspensions and/or transfers.

We have made gains in improving the processes of standardization of due diligence for the evaluation of suppliers, which is carried out at the beginning of the relationship and thereafter throughout the contractual periods with third parties. The documentation requested from suppliers is aimed both at ensuring adherence to the policies and the Nexa Code of Conduct and the requirements of countries with which we have commercial relations.