Governance

Ethical Conduct
of our Businesses

The principles and guidelines that orientate Cogna are presented in the Code of Conduct and include the behavior expected of employees, suppliers and other partners, as well as definitions of violations of our values.

We have an Anti-Corruption Manual to address corrupt conduct, in line with Brazil’s  Anti-Corruption Law 12.846/2013, in addition to guidelines for relations with public authorities.

  • 100% of the company’s operation are assessed for corruption-related risks.
  • Employees take mandatory training in the Corporate University and must formally adhere to the Code of Conduct.
  • 1,430 trained in the Code of Conduct in 2021.
  • All employees receive the Compliance Newsletter on a monthly basis, which addresses questions such as harassment, bullying, anti-corruption practices, among others.

Cogna Confidential Channel

This is open for employees, students, customers, suppliers and other stakeholders to report any deviations or breaches of the code of conduct. Access via internet or the toll-free telephone number 0800 741 0018.

We constantly monitor any risks that could compromise the full development of the Cogna businesses. Risk management employs a Risk Management Policy methodology oriented to best market practices, such as the COSO-ERM framework (Committee of Sponsoring Organization of the Treadway CommissionEnterprise Risk Management Framework) and ISO 31000/2018, as well as the guidelines of the Brazilian Institute of Corporate Governance (IBGC).

Data security and infrastructure

All our practices are based on international standards such as ISO 27001 (information security management) and NIST CSF (the National Institute of Standards and Technology’s framework on cybernetic security).

  • We have an area dedicated to data privacy, which reports directly to the Compliance structure.
  • Employees receive training in information security, which addresses the main points of data privacy in the Corporate University.

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