Code of Ethics    4.8GC 1GC 6GC 10

To guarantee effective and transparent management, Eternit adopts clear directives for the conduct of its employees in the businesses, and in its relationship with its interested public audiences, respecting professional, regulatory and internal standards. These directives are expressed in the Company’s Code of Ethics. Any deviation from these standards is treated with disciplinary action, which can even include dismissal of the employee in question. The Code of Ethics repudiates any form of discrimination or corruption, and the Company adopts mechanisms to protect its employees in the event of denouncements being made on these matters. In all the companies in the group, there is a specific communication channel for anonymous denouncements to be made directly to the Human Resources Department, the President or any Director. There were no cases of discrimination or corruption at the Company in 2012.

All employers are acquainted with Eternit’s anticorruption procedures which are set out in the Employee Manual, dissemination via the intranet, periodic training sessions, and internal company communications. In 2012, the Company updated its Employee Manual, which was given to all employees. The 357 hours of training were provided in the companies of Eternit and Precon, and 970 hours at Tégula on the code of ethics and policies and procedures referring to rights aspects in the operations. At SAMA, 1,820 training hours were carried out on the code of ethics, including employees, outsource staff, suppliers, and the security personnel that guard the premises.

All the units are evaluated by internal and external auditing from a corruption perspective. 2012, 52 audits were carried out by the Company, none of which identified any evidence of corruption.

Integrated Program System

The Integrated Program System (PSI) was reformulated in 2012 as part of the Program for Excellence and Management (PEG) and involve the integration of Eternit’s management tools, and provides guidelines or activities in the production plants in a quest for continuous improvement in the area of health and safety and the environment. In 2012, the PSI was disseminated within Eternit, involving the training of 1,269 employees. The Integrated Management System controls aspects related to PSI, as well as social and environmental responsibility. Eternit and its outsourced transport companies also conform to the requirements of the Sector Quality Program (Chrysotile PSQ).

Relationship with the market

Specifically within the environment of the capital markets, the Company complies with the requirements of the CVM (Brazilian Securities Commission), having its own Manual for the Disclosure and Use of Information, and Securities Trading Policy for the shares of Eternit S.A. which has been in existence since 2002. This document establishes the best practices with respect to the disclosure and use of privileged information and the trading of the Company’s shares, and is event to managers, employees and service providers.

Pacts and commitments

Eternit has been a signatory of the United Nations Organisation Global Compact since 2007, and for this reason adopts the 10 principles of this initiative in its business practices. Samples of this relationship between business practices and the principles of the Global Compact are highlighted throughout this report. In addition to this, the Company supports the UN Millennium Targets, and is making preparations to implement the so-called “Blueprint” over the medium and long term – Action Plan for Leadership in Corporate Sustainability, also part of the Global Compact.

DIRECTIVES OF THE INTEGRATED SYSTEM PROGRAM

• TO PROVIDE QUALITY PRODUCTS AND SERVICES, WITH A VIEW TO GIVING CUSTOMER SATISFACTION.
• TO PRESERVE THE ENVIRONMENT AND MINIMIZE THE ENVIRONMENTAL IMPACTS GENERATED BY OUR ACTIVITIES.
• TO GUARANTEE THE HEALTH AND PHYSICAL INTEGRITY OF OUR EMPLOYEES AND SERVICE PROVIDERS IN OUR ACTIVITIES, INCLUDING THE SECURE USE OF CHRYSOTILE ASBESTOS.
• TO ASSUME A PUBLIC COMMITMENT FOR THE DEFENCE AND PROTECTION OF HUMAN RIGHTS, CHILDREN’S RIGHTS, FUNDAMENTAL LABOR RIGHTS, THE COMBATING OF CORRUPTION AND THE PROMOTION OF GOOD CORPORATE GOVERNANCE PRACTICES, IN FULFILMENT OF ALL THE REQUIREMENTS APPLICABLE TO OUR ACTIVITIES.
• TO ATTRIBUTE WORTH TO OUR HUMAN CAPITAL, COMPLYING WITH INTERNATIONAL LABOR PRACTICES AND INSTRUMENTS FOR THE PREVENTION OF WORK ACCIDENTS AND OCCUPATIONAL DISEASES, UNDERSTOOD BY OUR EMPLOYEES TO BE FUNDAMENTAL FOR THE COMPANY’S ACHIEVEMENTS.
• TO CONDUCT OUR BUSINESS IN AN ETHICAL MANNER WITH RESPECT TO SOCIETY, SHAREHOLDERS, SUPPLIERS AND CUSTOMERS, SEEKING TO PROMOTE THE SUSTAINABILITY OF OUR BUSINESSES.

In this, corporate sustainability is defined as the capacity of a company to continually meet all the principles and and questions related to the Compact to increasingly instil values in financial, socio-environmental and ethical terms.