You can also download the Code of Conduct here.

Introduction

Embraer's good reputation and credibility are built by our entire ecosystem, through actions and attitudes day after day, and our suppliers are key partners of it and having this in mind Embraer has published the Embraer Supplier Code of Conduct ("Code").

The Code is based on Embraer's Corporate Values, the principles of the United Nations Global Compact, and best practices in corporate and accounting governance. It sets forth expected standards and minimum requirements for our suppliers to achieve our business objectives in an ethical, honest, and transparent manner, strengthening the relationship between the parties and contributing to the well-being of the communities where we operate.

As part of this Code, suppliers are expected to fully comply with applicable laws, rules, regulations, and requirements (national and international) and also to fully understand and apply this Code throughout their entire supply chain.  No provision contained in this Code will replace any other stricter provision contained in any contract entered between Embraer and suppliers.

Human Rights

Suppliers are expected to conduct their business respecting and promoting human rights, complying with all applicable national and international laws, as well as the requirements derived from the Universal Declaration of Human Rights.

Also, suppliers must promote a culture and a work environment in which discrimination, harassment practices, including moral and sexual harassment, threats, or retaliation for any reports, are not tolerated. Also, suppliers must treat employees equally, with dignity and respect.

Forced Labor, Child Labor, and Human Trafficking

We expect our suppliers not to be involved in any kind of slave labor, including forced labor, child labor, and human trafficking. The work must be carried out in accordance with the ILO (International Labor Organization) Declaration on Fundamental Principles and Rights at Work.

Suppliers must provide decent working conditions for its employees, ensuring compliance with the laws in force in each country of their operation.

Diversity

Suppliers are committed to promoting a culture of diversity and opportunity for all people regardless of race, identity, gender, age, nationality, religion, person with disability, marital status, among others, ensuring a safe and welcoming work environment, where there is equality and justice.

Suppliers must be committed to combating prejudice and discrimination in the workplace and promoting continuous awareness and training for all its employees on this topic.

Working Conditions

Suppliers must comply with and ensure that all laws, regulations, and standards applicable to working conditions for all of its employees are followed, such as payment of the legal minimum wage according to each category; compliance with rest periods required by law; adequate working conditions; freedom of association and non-retaliation; privacy, collective agreements; immigration rights; and a safe and healthy working environment.

It is expected that suppliers create and adopt a working environment where employees can report any concerns with safety rules and can report violations of such rules or incidents.

Integrity, Ethics, and Anti-Corruption Practices

Embraer believes that integrity, ethics, and compliance with anti-corruption laws are fundamental to the sustainability and success of its business. As part of its values, Embraer expects its suppliers to also adopt these principles in their activities.

Suppliers are expected to seek the highest level of integrity and ethics in their activities. To do so, suppliers are expected to establish an Ethics and Compliance Program aimed at promoting and supporting all actions that aim to comply with the laws and regulations applicable to their businesses and supply chain.

Suppliers should avoid situations that may create or appear to create a conflict of interest with Embraer and voluntarily report any existing conflicts. Embraer is firmly committed to combating corruption in all its forms, including extortion and bribery. The company complies with anti-corruption laws and regulations in all locations where it does business, and suppliers are expected to do the same. Any form of active or passive corruption, such as extortion or bribery, in an attempt to influence business or obtain any undue advantage, will not be tolerated. For more information, please refer to Embraer's Anti-Corruption Policy and Code of Ethics and Conduct.

Gifts, Giveaways and Hospitality

Suppliers should avoid offering gifts, giveaways and hospitality, such as entertainment, travel expenses, accommodations, or other advantages or benefits that may create the appearance of impropriety or undue advantage. Gifts should not be offered. Giveaways and hospitality should be modest and reasonable in value, without extravagance, offered or accepted in connection with the promotion, demonstration, or explanation of products and services to the company. Finally, it is important to remember that gifts and entertainment should never be offered or accepted in cash or when prohibited by law or regulation applicable to the parties involved.

Environment

As part of its commitment to sustainability, Embraer strives to positively impact the society and the environment, especially the communities where it operates through educational, social, cultural, and environmental projects.

Embraer is aware of the environmental challenges in its industry and is committed to adopt continuous improvement processes and investing in new technologies to reduce potential environmental impacts, while suppliers are also expected to demonstrate the same commitment.

In 2023, Embraer became part of the CDP* Supply Chain Program. This program supports organizations defining a strategy for engaging suppliers through the analysis of risks and opportunities associated with climate change with a recognized methodology to monitor carbon emissions associated with its main suppliers.

In this sense, suppliers are expected to adopt measures to minimize its environmental impacts, including a preventive approach to risks related to the topic, including carbon emissions measurement in its organization and throughout its value chain.

It is expected from suppliers to actively work on the development and dissemination of sustainable technologies, which contribute to the progressive reduction in the emission of greenhouses gases, to better manage their waste, to promote an adequate energy transition and on the maintenance of biodiversity and sustainability of the environment.

*CDP is a global recognized non-profit organization that manages a system of self-reported environmental data for businesses and governments. Find more information at: www.cdp.net.

International Trade

Embraer is subject to foreign trade laws and complies with all regulations related to the import and export processes of products, services, technology, information, and financial operations.

Therefore, suppliers must ensure that they comply with all laws and regulations regarding export control, including US and EU laws and regulations and any other applicable regulations to the business.

Suppliers must provide export control, export licenses, or other necessary authorizations to Embraer when required. In addition, through its supply chain, suppliers must observe and comply with applicable laws regarding the import and export control (especially ITAR and EAR, when applicable) of goods, services and industrialization, in accordance with the procedures and policies established by the company.

Conflict Minerals

Suppliers shall identify, with adequate measures, and provide the requested information related to the products, raw materials, parts or other materials supplied that may contain the minerals tin, tantalum, tungsten, and gold originating from conflict regions.

Embraer supports the end of violence and human rights violations in the Democratic Republic of Congo and adjacent countries. As part of our social impact management process, we have established the "Conflict Minerals" clause in our contracts, which requires suppliers to report the origin of minerals contained in the products supplied by them and their subcontractors to Embraer in accordance with applicable American law (Dodd-Frank Act).

In order to eliminate the social impacts of our activities, one of our initiatives has been to make Embraer an integral part of various global Conflict Minerals programs, including but not limited to: Aerospace Industries Association ("AIA") and the Responsible Business Alliance - Responsible Minerals Initiative ("RBA-RMI").

Confidentiality

Suppliers shall maintain the confidentiality of all information, specifications, processes, or technical and/or commercial initiatives identified as confidential, sensitive, and/or intellectual properties belonging to Embraer.

Cyber Threats

Embraer expects suppliers to implement appropriate security measures to protect against cyber threats, such as malware, phishing attacks, and data breaches. Additionally, suppliers are expected to comply with all applicable laws and regulations related to cybersecurity and to follow applicable market standards.

Suppliers must guarantee that they will provide Embraer with timely and transparent disclosure of any incidents or cybersecurity vulnerabilities that may affect their products or services.

Reporting Violations

All stakeholders of Embraer, including employees, suppliers, customers, shareholders, and business partners, among others, must report any concerns about potential violations of the principles and values of this Code.

Embraer provides various channels for reporting concerns or violations. Anyone can report a concern or violation through these channels, such as the Board of Directors and its Audit, Risks and Ethics Committee, the employee's leader or manager, the Compliance Department, Internal Audit, the Human Resources Department, the Legal Department, or the Helpline channel.

The Helpline is a confidential channel for employees and stakeholders to report potential violations of Embraer's policies, procedures, this Code, or any applicable law or regulation.

Embraer does not tolerate any retaliation, direct or indirect, against anyone who reports, through the channels made available by the Company, a good-faith concern. Additionally, all matters reported, concerns, or violations directed to the Helpline channel will be treated with confidentiality and respect for anonymity.

How to submit a concern?

By phone:
Brazil: 0800-721-5968

China: 400-120-4946

United States of America: 1-877-900-8779

France: 0805-080608

Netherlands: 0-800-022-7230

Portugal: 800-180-118

Singapore: 800-130-2122

By website:
www.embraerhelpline.com 

At Embraer, we are committed to responsible sourcing of minerals to promote ethical and sustainable practices in our supply chain, and we expect our suppliers to be likewise committed to responsible sourcing of minerals. Our Responsible Minerals Sourcing Policy supports the Dodd-Frank Wall Street Reform and Consumer Protection Act (‘Dodd-Frank’) and is aligned with the Organization for Economic Co-operation and Development (‘OECD’) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Our pledge is to ensure that none of our products contain conflict minerals that contribute to the funding or support of armed groups and human rights violations, either directly or indirectly. Our policy is consistent with the standards set forth in the OECD Due Diligence Guidance for

Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas:

We encourage our suppliers to take steps to determine if their products contain conflict minerals (tin, tantalum, tungsten and gold) and if so, implement Reasonable Country of Origin Inquiry (‘RCOI’) due diligence processes to identify sources of these minerals and support efforts to eradicate the use of conflict minerals which directly or indirectly finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries; and encourage them to request their suppliers to do the same.

We encourage our suppliers to undertake RCOI due diligence with their supply chains in an effort to assure that the minerals within our products are being sourced only from mines and smelters/refiners outside the Covered Countries, or mines and smelters/refiners which have been certified by an independent third party as “conflict free” if sourced within the Covered Countries; and encourage them to request their suppliers to do the same.

We conduct a RCOI with our supply chain as part of our conflict minerals due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

We work with industry groups, including but not limited to RBA-RMI (RBA Responsible Minerals Initiative) and AIA CMWG (Aerospace Industries Association Conflict Minerals Working Group), to strengthen our Conflict Minerals processes and share best practices.

We recognize these rules have required, and will continue to require, time and effort on the part of our suppliers. We appreciate their ongoing support in this important subject.

Embraer’s Conflict Minerals Report can be accessed below.


Embraer needs Suppliers that are committed to responsible minerals sourcing, and will not establish relations of any kind with organizations which directly or indirectly finance or benefit armed groups, human trafficking, child labor or forced labor in any form, and employs suitable measures to identify the presence of 3TG minerals (tin, tantalum, tungsten and gold) sourced from conflict countries (Democratic Republic of the Congo and adjoining countries) in the products, components, parts or materials they supply.

View the SD-CMR (Specialized Disclosure - Conflict Minerals Report).