1

ComplianceInitiatives

Jun.2020

Compliance Milestones 2017

2

Named Marcelo Proença as Global Compliance Director

Establishment of direct reporting to the JBS Board of Directors

JUN

OCTHired Deloitte to develop a software for automatization of Third Party Due Diligence process

Released the Compliance Program called “Always do it Right”JUL

AUG

Restructured the department, hiring new team members

Launched an outsourced Ethics Line (24/7)DEC

Establishment of 7 Ethics Committees, in each Business Unit in Brazil to oversight the Compliance Program and the Ethics Line

Compliance Milestones 2018

3

Approval by the Board of Directors of a new Global Code of Conduct and Ethics and also a Code of Conduct for Business Associates

MAR

Hired a Head of Ethics and Compliance at JBS USA

JBS became a signatory of the Business Pact for Integrity and Against Corruption.This agreement was developed on the initiative of the Ethos Institute.

APR

AUG In-Person Code of Conduct Training for the top management: Board Members, Presidentsand Directors

DEC End of 2018 Training cycle, with more than 115 thousand employees trained on the Code of Conduct guidelines

OUT Launched the Conflict of Interest survey covering Managers, Directors, PresidentsImplemented the Conflict of Interest form for new employees

Compliance Milestones 2019

4

MAY

AUG

OUT

Anti-Corruption training in Brazil for 100% of the administrative office employees, including presidents anddirectors

Beginning of the Code of Conduct Training in Brazil for 100% of the employees (including presidents/directors)

Compliance Day event held at JBS headquarter in Brazil

JULCreation and launch of the JBS Compliance website

Start of Third Party Training Project

MAR Risk Assessment review for all Business Units in BrazilImplemented 20 controls for risk mitigation

1

2

3

SET

New communication campaign for the Ethics LineConflict of Interests Global Policy publishment

NOV Due Diligence Policy publishmentEnd of Code of Conduct and Ethics training with more than 116,000 employees trained

5

Numbers 2019

• 116,650 team members (including members of the Board of Directors and advisory committees) trained on the

Code of Conduct and Ethics

• 16,075 team members (administrative and leadership) trained on Anti-Corruption Practices

• 33 companies trained (third party) on the guidelines of the Business Partner Code of Conduct (pilot project)

• 66 pieces of communication were made available to employees and third parties

• 2,512 complains received by JBS Ethics Line

• 69% of the complains received went to investigation by the Compliance area, with an average of 32% of

substantiated

• 259 consequences (action plans and disciplinary measures established/applied) for misconduct

• 9,486 reputational analysis (due diligence) were carried out (including companies and partners)

• 2,100 internal processes were evaluated or monitored

• More than 45 hours of interviews conducted to update Company's Compliance Risk Assessment

Compliance Milestones 2020

JANDue Diligence software improvements and updates

Evaluation of Compliance area processes by Internal AuditABR

MAR

Launched the Global Anticorruption Policy

44

MAYBeginning of the Training Cycle on specific Compliance topics

Carla

MontenegroCoordinator

Jonas

ScalengheCoordinator

Emily KnappDirector

Organizational Chart

7

Trainings Due Diligence

José Marcelo M. ProençaGlobal Compliance Director

André DamasoManager

Fernanda BrunoAnalyst

Wanessa

RibeiroAnalyst

Kauã

Pelegrini Analyst

Nick WhiteHead of Compliance

JBS USA

Board of Directors

Wesley

SouzaAnalyst

Ethics LineCommunication Risk Assessment

Controls

Conflicts of Interest

Jessica

DinsmoreAnalyst

Patrícia

TopanAnalyst

Gabriela

MazzettoExecutive Assistant

Unrestricted support from senior management and members of the Board

Tone at the Top

Participation in all Compliance trainings and also in the event held (Compliance

Day)

Members of the Ethics Committees

Communications with the “tone at the top” about the relevance of Compliance

Participation of the CCO in the Board of Directors meetings

Presentation of the Compliance Program's initiatives and developments to the

Board and Committees (audit, governance)

7

Valid since May, 2018

In all regions where JBS operates (South America, North America, Europe, Asia)

In two versions – For employees and for third-parties (attached to the contracts)

Documents available at Compliance Website www.jbs.com.br/compliance

Codes of Conduct

8

JBS Compliance Website

10

jbs.com.br/compliance

JBS Compliance Day

11

Event held in August, 2019

Trainings 2019

Anti-corruption

JBS Brazil

Administrative office employees

(~17.700)

Corporate Friboi Seara NN Leather SwiftJBS

94% 91,3% 95,8% 98,3% 93,2% 94,8%92,6%

Code of Conduct and Ethics

JBS Brazil

116,642Employees

98%

JBS USA

96,500Employees

12

85,5% Concluded

Pending

11

JBS Ethics Line

13

Launched in December, 2017

Available for employees and third-parties 24h/7, in 4 languages

Issues reported by allegation type

163 168

242

285305

288266

236

274

319

172 180

228

JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN

Complaints per month

69%

7%

5%

5%

2%1%

11%

Behavior (harassment)

Violation of labor laws

Conflict of interest

Fraud/Corruption

Non-compliance with internal

policies and procedures

Leakage or misuse of

confidential information

Other

2019 2020

Ethics Committees

14

Board of DirectorsJBS Ethics

Committee

Friboi Ethics Committee

Seara Ethics Committee

JBS Leather Ethics

CommitteeS

JBS New Business EthicsCommittee

Swift Ethics Committee

Corporate EthicsCommittee

Global Compliance Director

South America

Operations President

Legal Director

Finance Director

BU President (rotating seat)

JBS Senior Director

Compliance

Local HR

Labor Legal

15

Third-Party Analysis (Due Diligences)

Not Recommended

148 169 166 198 159 142 109

287368

184

810708

596

21 15 169

8 11 11

7

21

7

63

20

17

JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN

Monthly Analysis

Approved Not recommended

24%

8%9%

4%

7%

24%24%

Waste

Intemediaries

Consulting firms

Law firms

Associations

Marketing

Others

2019 2020

Compliance News16

17

Communication Campaign - JBS Ethics Line

Gifts

Private Corruption

Conflict of Interest

Conflict of InterestConflict of Interest

Quality

Animal Welfare

Process mapping to identify, assess and monitor Compliance risks

Risk Assessment

Schedule defined based on prioritization of

identified risks

Risk Assessment periodically updated

Risk Matrix with all risks are consolidated and

classified (probability x impact)

Action Plan under development with the Business

Units

1

2

3

17

Controls and Monitoring

19

Preventing and detecting corruption through implementation of controls is a key focus of JBSCompliance Program

Companies and individuals

blocked (Watch List)

Monitored companies and

individuals Preventive and Detective Controls

+780 +261 20

Direct or indirect

mention in J&F

executives plea-bargain

process

Involvement in

suspected non-

compliance actions

(Yellow List)

Limitation of cash in units

and the monitoring of any

additional money requests

Risk Third Parties payments

Payments for individuals

Company’s aircrafts use

Travel expenses individuals

Discounts /Bonus for clients

Gifts/ Donations/

Sponsorships

Follow the money

18

Controls and Monitoring

145

12

2

3

14

1

7

2

8

1

Donations

Consultation

Media

Sponsorships

Yellow List Compliance

Payments for Individuals

Risk Third Parties

Gifts

Exit Interview*

Additional Money - 5k

Some controls have not been reported for not occurring

Number of Processes Evaluated or Monitored

19

3035

4741

32 3325

12

2315 18

2

12

JUN JUL AGO SET OUT NOV DEZ JAN FEV MAR ABR MAI JUN

Consultation

13

20

7

11

16

6 68 7

28

1815 14

JUN JUL AGO SET OUT NOV DEZ JAN FEV MAR ABR MAI JUN

Yellow List

Policies and Procedures

Documents for specific topics that guide employees in conducting their activities

New Policies Status Scope

Compliance Under validation

Existing Policies Status Scope

Anti-bribery and Corruption Published

Sponsorships Under review

Donations Published

Conflict of Interests Published

Gifts, Entertainment and Hospitality Published

Due Diligence Published

Whistleblower Channel Published

Consequences Published

20

22

01 02 03 04Develop a tailor

made training for

specific positions

Increase Due

Diligence

analysis

Develop global

and local

policies based

on risk

Priorities in 2020

05

Assessment of the

Compliance

Program Evolution

07 Measure the

evolution and

maturity of the

integrity culture

06 Ensure the

effectiveness

of the

implemented

controls

08 Application for

Compliance

certifications

Enhance

Communication

worldwide

Stakeholders

23

Example of stakeholders currently monitoring the JBS Compliance Program

Customers

Banking andInsurance

Government / Investors

Auditors and Rating Agencies

See more at: www.jbs.com.br/compliance

Thank you!!

compliance@jbs.com.br