What is Itaú Unibanco’s Integrity and Ethics Program?
See below for our codes of ethics and supplier relations and corporate integrity policies.
voluntary commitments / covenants
Itaú Unibanco in the media
Our values are our identity. This is what sets us apart from other companies and makes us unique. At Itaú Unibanco, our Corporate Culture known as “Our Way” drives the way we relate to customers, employees, shareholders, competitors, suppliers, governments and society at large. It establishes the way we pursue our vision:
“To be the leading bank in sustainable performance and customer satisfaction.”
Among the principles that make up our organizational culture, we value our ethics, which is non-negotiable, that is, we commit ourselves to always doing what is right, without any devious way, without shortcuts. And we exercise our leadership in a transparent and accountable manner, fully committed to society and best governance and management practices. For this:
• We always do what is right, even the hardest.
• We never do anything that cannot be published on the front page of newspapers.
In addition, we do not tolerate:
• Questionable or “devious” conduct in business.
Click here to access Our Way.
We are constantly challenged to serve our customers with excellence and exceed their expectations in a highly competitive environment. The current moment, with rapid and intense changes in technology and consumption habits, makes this challenge even greater. At the same time, we must seek differentiated results, always in an ethical manner and aligned with our values, an indispensable condition for these results to be sustainable. To ensure that the conduct of the bank's employees is known and practiced on a daily basis, we have the Itaú Unibanco Code of Ethics. It expresses our conviction that organizations wishing to be perennial do not admit to gain at any cost and that the success of an institution depends on its ability to lead with ethics, integrity and accountability.
Click here to access Itaú Unibanco Code of Ethics.
The Compliance function at Itaú Unibanco aims to prevent and mitigate Itaú Unibanco's exposure to situations of non-compliance with internal and external norms and rules, being responsible for governance, compliance certification, conduct and transparency.
Compliance Risk (*) is managed through a structured process aimed at identifying changes in the regulatory environment, analyzing impacts in the institution's areas and monitoring actions aimed at adhering to regulatory requirements and to our Code of Ethics.
Compliance risk governance is governed by the Compliance Policy, which addresses the regulatory requirements of Brazilian CMN Resolution No. 4,595/2017.
Compliance risk management should address existing or new processes, products and services, including relevant outsourced services.
The Corporate Compliance Department at Itaú Unibanco covers relationship activities with regulators, self-regulators and representative entities, corporate policy management, research and capture process, distribution of norms and monitoring of action plans for regulatory compliance. It also covers risk environmental, labor compliance, product governance, monitoring of Personal Investment Policies and Securities Trading Policy issued by Itaú Unibanco Holding SA, management of the Customer Relationship Program, Integrity and Ethics Program and monitoring of Abusive Practices ( Trade Surveillance).
(*) Compliance Risk is the risk of legal or regulatory sanctions, financial loss or reputational damage arising from failure to comply with legal and regulatory provisions, local and international market norms, or commitments made through self-regulatory codes, technical standards, codes of conduct or internal policies.
While Brazilian law considers only deviations in relations between public and private agents as corruption, we consider corruption to be deviations between public and private agents as well as between private agents, based on global best practices on the subject. Our Corruption Prevention Corporate Policy reinforces our commitment to proactively cooperate with national and international initiatives to prevent and combat corruption in all its forms. Our policy applies, in Brazil and abroad, to all managers, employees and controllers of the organization and its non-profit entities in Brazil, and to any interaction the bank has with customers, partners, suppliers and other stakeholders. Based on national and foreign laws (Federal Law No. 12,846 / 2013, the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, among others), case law and global market information, we identify the countries most at risk of corruption. In the countries where we operate, we have processes and controls relating to our relationship with clients, the public sector and third parties, according to the specific regulations and particularities of each jurisdiction.
In January 2014, a new anti-corruption law (Law 12,846 / 2013) entered into force in Brazil, which states that legal entities have objective liability (regardless of guilt or negligence) if they are involved in any form of corruption. Although known as the anti-corruption law, the text also covers other unlawful acts contrary to Brazilian or international public administration, such as bid fraud and obstruction of justice. The law provides for stringent penalties through administrative and judicial proceedings, including the dissolution of the company, prohibition of access to financing from public agencies and participation in public tenders. In addition, the law authorizes the public administrative authorities responsible for the investigation to enter into leniency agreements. Disclosure by the infringing parties themselves of violations committed and their cooperation could lead to the reduction of fines and other sanctions, as determined by Decree 8.420 / 2015. This new regulation provides parameters for anti-corruption law enforcement, including with respect to penalties and compliance programs.
Click here for Federal Law No. 12,846 / 2013
Financial institutions play a key role in preventing and combating illicit acts, such as money laundering and terrorist financing. Money laundering is the concealment or disguise of the nature, source, location, disposition, transfer or ownership of property, rights or values arising, directly or indirectly, from criminal offense. Terrorism financing is when someone, directly or indirectly, by any means, provides financial support, provides or collects funds with the intention to use them for or knowing that they will be used, wholly or partially, by terrorist groups for the practice of terrorist acts.
The great challenge is to identify and suppress ever more sophisticated operations that seek to conceal or disguise the nature, authorship, origin, location, disposition, ownership, and / or movement of goods and values derived directly or indirectly from illegal activities.
Itaú Unibanco has established a corporate policy aimed at preventing its involvement with unlawful acts and protecting its reputation and image vis-à-vis employees, customers, strategic partners, suppliers, service providers, regulators and society through a governance-oriented structure driven towards transparency, strict compliance with rules and regulations and cooperation with the police and judicial authorities. It also seeks continuous alignment with national and international best practices to prevent and combat illicit acts, through investments and permanent training of its employees.
Financial institutions also play a key role in preventing and combating illicit acts, including fraud and claims, where the major challenge is to identify and crack down on increasingly sophisticated operations that seek to appropriate assets or move values from illegal activities. Fraud refers to any unlawful activities, attitudes, or actions that are intended to mislead or deceive someone by using them in bad faith for their own or others' benefit. Examples are: omission / manipulation of information, appropriation of values, tampering with documents, records and financial statements. Claim refers to atypical events that result in losses or disasters to Itaú Unibanco, such as: burglaries to agencies and clients, extortion through kidnapping, theft, accidents, burglaries, among others.
In order to ensure transparent and sustainable relationships between our employees and suppliers, we have developed our Supplier Relationship Code. In this code, we present Our Principles, which deal with the values that guide the proper conduct in the business relationship between Itaú Unibanco and its suppliers. The code also translates these values into objective guidelines, stating the expected form of action between both parties in everyday interactions.
Click here to access our Suppliers page.
Our motto at Itaú Unibanco is "We are all risk managers."
Risks are inherent elements of all the Institution's activities and are part of the daily routine of employees, being present in existing or new processes, products and services, including outsourced services. Properly managing operational risks is an essential condition for the sustainability of Itaú Unibanco's business.
Itaú Unibanco adopts the strategy of the three lines of defense to operationalize its risk management structure.
Inserted in the second line of defense, the Internal Controls Department consists of an area composed of Internal Control and Risk Officers (called OCIRs) who, together with their teams, are responsible for:
For this reason, it is forbidden for this area to manage any business that may compromise its independence.
In order to maintain and strengthen our commitment to ethics, we have an internal ombudsman channel - the Ombudsman - which is an independent area with full autonomy in the organization and reports directly to the CEO.
How it works
Guided by trust, dialogue, transparency, ownership, integrity and ethics, the Ombudsman channel works to assist Itaú Unibanco* employees in resolving interpersonal conflicts, conflict of interests in the workplace, ethical misconducts and violations to institutional policies, such as bullying or sexual harassment, discrimination in all spheres of diversity, favoritism, behaviors contrary to risk management, etc., always based on its operational pillars.
(*) Itaú Unibanco employees and associates managed by the Personnel Area.
There are three pillars that guide the Ombudsman’s performance:
Confidentiality – all information is received with discretion and confidentiality. The employee decides whether to remain anonymous or not.
Neutrality – there is no judgment from anyone. The goal of the channel is to understand the situation and seek the solution.
Independence – the channel works in defense of best practices within the workplace. This means free acting at any hierarchical level.
The channel has twelve years of existence and during this period more than 26 thousand employees were served. This number reflects the credibility gained, above all, by the commitment to quality in the work developed over the years and its consolidation as a fundamental piece to build a company that values respect and integrity in all relationships and seeks to achieve its goals without deviating of the ethical values we believe.
Information is one of the main assets of any organization. For the proper protection of this asset, Itaú Unibanco Holding SA establishes an Information Security and Cyber Security policy to ensure the application of the principles and guidelines for the protection of intellectual property and information of the organization, customers and the public in general. The Information Security and Cyber Security strategy is designed to prevent data security breaches, minimize the risks of unavailability of our services, protect the integrity and prevent any information leaks. To achieve this goal our strategy is based on expanded perimeter protection, supported by control processes for incident detection, prevention, monitoring and response ensuring cyber security risk management and building a robust foundation for the increasingly digital future of Itaú Unibanco. The expanded perimeter concept assumes that information should be protected regardless of where it is, whether it is in a service provider or an international unit, throughout its life cycle, from the moment it is collected through processing, transmission, storage, analysis and disposal.
Click here to access our Security page.
Itaú Unibanco has always believed that banks are people, and that the ethics, respect and appreciation of the people who build them are the essence of all its achievements. We recognize our role in driving diversity, striving to be an example of best practice and continually seeking equal opportunity for all. In June 2017, we set an important milestone in the transformation journey of our history and shared with our market our Commitment to Diversity Letter.
Diversity of people is in our DNA. We are a company with over 90,000 employees and more than 60 million customers, i.e. we are a stratum of society and therefore we aspire to have a framework with a plurality of backgrounds, cultures, beliefs, experiences, races, genders, needs, sexual orientation, gender identity, diverse ages and generations. We believe that a diverse group broadens perspectives, increases our creative potential in finding better solutions for our customers and encourages cooperation and synergy among employees. As a recognized and valued theme in our culture, the management of internal diversity is guided by the Internal Diversity Appreciation Policy and the commitments we have signed over time.
In our Human Resources Department there is a Diversity & Inclusion team, responsible for working on the theme at the institution and disseminating it in all areas of the bank. Thus, several work fronts are implemented to promote diversity, equity and inclusion: accessibility and empowerment actions for people with disabilities, reflections on career and age, deconstruction of stereotypes, broadening racial representativeness, broadening career opportunities for women, security and respect for LGBT + public issues and different religions. In addition, in partnership with other areas of the bank, actions related to customers, suppliers, society and shareholders are developed. The purpose of this agenda is to promote a safe and respectful environment that enables the real inclusion of all.
Click here to access Itaú Unibanco's Commitment to Diversity Letter.
Itaú Unibanco is an institution that prides itself on acting with integrity and ethics. Therefore, we strive to establish lasting and perennial bonds with our stakeholders, we value the permanent satisfaction of our customers through our products and services, we assess the social and environmental impacts of our financial activity, act transparently and fully in our business and relationships, and adopt practices that contribute to building shared value.
Click here to access Itaú Unibanco’s Sustainability page
The relationship maintained with Public sector and its officers, regardless of their organization, position or hierarchy, require extensive transparency, act in good faith, and accurate books and records.
This relationshionship can happen (i) in Governamental and Institutional activities and/or (ii) during an acquisition of a product (ii) or during a bidding process that Itaú Unibanco and Agencies, Entities and Companies of the Public Sector are participating.
For this reason, we need to ensure that all interaction with Public sector will be guided by the maintenance of an ethical and transparent relationship, respecting the public administration law, the applicable laws and regulations and the principles established by the Itaú Unibanco Code of Ethics, such as legality, morality and administrative integrity.
Click here for more information