BB Foundation adopts the Committee of Sponsoring Organizations of the Treadway Commission - COSO guideline as a guide for the development, implementation and evaluation of its Internal Controls System and established the Reference Model of Lines of Defense to manage the incurred risks and of the necessary controls for its mitigation.
The 1st line of line of defense comprises the management of Bb Foundation's processes and involves identifying and evaluating the risks associated with the processes, as well as implementing and executing controls that mitigate these risks.
The 2nd line of defense corresponds to the typical corporate functions of risk management, internal controls and compliance, as well as the functions of governance, institutional security and legal advice, aiming to subsidize the Executive Board in decision-making and advising the 1st line of defense in the adoption of risk management and control practices.
The 3rd line of defense covers the internal audit function, which assesses the effectiveness of the entire risk management and control cycle of BB Foundation.
As a way of disseminating the risk culture and demonstrating the relevance of the integrity theme in institutional relations, a Communication Plan was prepared and executed, as in previous years, After being presented to the Executive Board. The covered topics were: Integrity, Risk, Internal Control, Information Security and Business Continuity, and the construction of this Plan had the participation of the staff through the application of a survey carried out in January 2021 and, from a list of potential topics to be addressed, each participant could assign grades, thus classifying subjects by interest and relevance, based on their individual perception.
Monthly reports were made to the Management Committee on the development and monitoring actions of the Integrity Program and articles on risk, internal controls, security, prevention and fight against corruption and related topics were published in its various internal channels. In addition, in October and November, the Ethics and Integrity Journey was held, an event with lecture panels to address issues related to integrity that significantly impact the activities of BB Foundation.
Monthly reports are made to the Executive Board on the progress of control activities. The scope of these activities is defined in the Annual Control Plan - PAC approved by the Executive Board.
BB Foundation also has an Internal Controls and Compliance Policy that, in addition to being aligned with COSO principles, corroborates the solidity of the governance structure, fulfilling its premise of helping the organization in achieving its strategic objectives and mitigating compliance risks. The aforementioned Policy provides, among others, that BB Foundation adopts and encourages the unequivocal ethical conduct of all employees of the Institution (employees, contractors and service providers).
The accounting policies adopted by BB Foundation are applied consistently in all periods. The consolidated financial statements are prepared based on the guidelines issued by the Brazilian Corporate Law, and are presented in accordance with the practices of the Accounting Standards Board - CPC and the Federal Accounting Council - CFC, approved by an independent audit.
The financial instruments of BB Foundation are recorded in equity accounts and are comprised mainly of the balances of financial investments, other credits, payable accounts, payable charges and other obligations.
In 2021, the Integrity Bulletin, a quarterly instrument aimed at the Trustee Council, Fiscal Council and the employees of BB Foundation, continued to be produced and disseminated, presenting the development and monitoring actions of the Integrity Program and allowing the visualization of the actions of integrity developed in the period.