Whistle-blowing Policy

It is the policy of Estaleiro Jurong Aracruz Ltda (“EJA” or the “Company”) to encourage the reporting by any person of any possible improprieties in matters of financial reporting or other matters that he/she may encounter.

Examples of possible improprieties include:

  • Non-compliance with EJA’s policies or Code of Conduct, including the Anti- Bribery Compliance Policy
  • Fraudulent acts or misappropriation/ misuse of company assets
  • Non-disclosure of conflict of interest and abuse of authority
  • Inappropriate acts or inadequate controls that may cause financial loss or damage to the reputation of EJA
  • Fraud against investors and regulatory authorities
  • Acts or omissions that are likely to or do deceive or mislead internal or external auditors or accountants relating to the preparation or audit of EJA’s records or financial statements

EJA does not condone any retaliatory action taken against any complainant that has filed any complaint alleging possible improprieties and may take disciplinary action against any person who threatens to take or is found to have taken retaliatory action. Any complaint alleging retaliatory action shall be received, reviewed and investigated by the Company in the same manner as any complaint alleging Possible Improprieties.

Complains can be filed anonymously but complainants are encouraged to disclose their identities when submitting complaints. The identity of a complainant and the information provided, so disclosed, shall be kept confidential. The AC and the SCM Whistle Blow Complaints Committee (“WBCC”) shall deploy their best efforts to keep the identity of any complainant and the information provided confidential, save where:

  • the identity of the complainant and the information provided, in the opinion of the AC and SCM WBCC, are required on a confidential basis by a party appointed by the AC to carry out an investigation or by professionals engaged to advise on the complaint. The written permission of the complainant who has disclosed his/her identity shall be obtained prior to the release of his/her identity to facilitate the investigation or for the purpose of obtaining professional advice
  • it is required by law, order or direction of any court, regulatory body or stock exchange, or the information is provided to the relevant authority for criminal investigation

Investigation reports and records under this Policy are confidential and are not to be released by the SCM WBCC and the AC appointed investigation team, except under circumstances as provided for within EJA’s Whistle Blowing Policy and Procedure.

The policy and procedures set forth in EJA’s Whistle Blowing Policy and Procedure. shall be read in conjunction with any laws, regulations, rules, directives or guidelines issued by the relevant authorities from time to time prescribe or issue on the receipt, retention and/or treatment of complaints regarding accounting, internal controls or auditing matters or any matter governed by this policy. In the event that any policy or procedure herein is inconsistent or in conflict with the applicable laws the matter is to be raised to the SCM WBCC immediately for its action

A whistle blow Complaint may be submitted to the AC Chairman or SCM HIA/SCM CRO through one of the following channels:

  • Email: Este endereço de e-mail está protegido contra spambots. Você deve habilitar o JavaScript para visualizá-lo.
  • Hard copy complaint letter post to:
    Estaleiro Jurong Aracruz Ltda, Rodovia ES 010, Km 56, s/n, Barra do Sahy, Aracruz, ES CEP 29198-025
    addressed to the Internal Audit Manager or the Risk Manager or
  • Telephone:
    EJA Toll Free Hotline: 0800.8787901


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ARACRUZ / ES: +55 (27) 3270 6900 / (27) 3270 6944