• Comply with anti-corruption laws and regulations and work to ensure that business partners, suppliers, and service providers share this commitment.

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• Combat and not tolerate any unethical or illegal conduct by employees or Third Parties acting on its behalf or in its interest.

 

• Do not promise, offer, pay, or deliver, directly or indirectly, any bribe, kickback, or other undue advantage to public officials, related persons, or third parties.

 

• Do not accept or make any offer, promise, or payment intended to expedite or obtain undue advantage or favoritism in the issuance of permits, licenses, authorizations, or in the processing and analysis of administrative procedures in general.

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• Hire suppliers only after prior qualification analysis and Due Diligence to assess their commitment to professional bodies, compliance with laws, and international standards.

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• Train all employees regarding the matters addressed in this policy.

 

• Perform accounting records and supporting documentation transparently, accurately reflecting the transactions conducted by the company to ensure that its assets are not misused.

 

• Do not finance, sponsor, fund, or in any way subsidize or support the practice of illicit acts and irregularities.

 

• Do not use intermediaries or “fronts” to hide or disguise the company’s interests in any request, demand, or dealings with public administration.

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• Do not obstruct investigations or inspections by public agencies, including regulatory bodies and financial system authorities.

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• Do not allow any contributions or donations to political parties, political campaigns, and/or candidates for public office by employees on behalf of the company.

 

• Know your business partners, whether clients, suppliers, or service providers, following the company’s internal procedures and policies.

 

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Application: This policy applies to all its directors, employees, third parties, or any person acting on behalf of the company.

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During a bidding process, employees responsible for the company's negotiation and participation must not accept invitations, gifts or any undue advantage offered by other bidders.

 

Any possible or apparent conflict of interest during a bid must be reported to the Compliance Department for analysis.

 

In the bidding process, the offer, promise or granting of entertainment, gifts, meals, travel or any similar advantage to a Public Agent, their relatives or any other person involved in the process is prohibited.

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In dealings with public administration entities responsible for inspecting and/or supervising the company’s activities, employees are prohibited from obstructing, concealing, segregating, or manipulating information requested in the scope of specific or routine inspection processes. It is expressly forbidden to seek artificial outcomes through bribery or any form of influence or interference.

 

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Employees must be familiar with and adhere to the guidelines of the Public Administration Relationship Policy. For more information regarding the company’s participation in public bids, please refer to the Public Administration Relationship Policy.

 

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In interactions with Public Administration or other parties, employees must refrain from promising, offering, delivering, or authorizing, directly or indirectly, any Undue Advantage, whether to influence decisions affecting the company’s business or for personal gain of the employee or related persons.

 

To ensure compliance with the Code of Conduct and Ethics and this Anti-Corruption Policy, and to prevent risks related to anti-corruption laws, in cases of acquisition of shares or quotas in other companies, mergers, incorporations, or other corporate agreements, the company will follow the anti-corruption Due Diligence guidelines and procedures established in the Third-Party Relationship Policy.

 

This aims to assess and identify signs of irregularities or illegal acts in the target company of the transaction, or the existence of vulnerabilities in its compliance program and internal control system that could, in any way, harm the proper conduct of the company’s business.

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The hiring of suppliers must be carried out after a prior analysis that determines their qualifications and reputation, seeking to identify potential involvement in violations of anti-corruption laws. In cases of identification or suspicion of deviations in ethical conduct by suppliers, the facts must be communicated to the Compliance department for analysis.

 

To ensure compliance with this policy and the code of conduct and ethics, the supplier that acquires shares or stocks in other companies, or in the event of a merger, incorporation or other corporate agreements, must follow the guidelines of the qualification and Due Diligence process, aiming to evaluate and identify signs of irregularities or illicit acts in the company targeted by the transaction or the existence of vulnerabilities in its internal control system, which may, in some way, be detrimental to the proper conduct of business with the company.

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Anti-Corruption Laws require accurate and faithful accounting of all payments made by the company, as well as their documentation. Similarly, employees and suppliers must be instructed to ensure that all transactions or operations related to the company’s business are fully and clearly documented in detail, with correct expense descriptions, and that they are properly approved and classified.

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The company establishes and maintains internal controls, ensuring that:

 

All expenses and payment operations are approved according to internal approval procedures;

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• All transactions are recorded in a manner that allows the preparation of financial statements in accordance with accepted accounting principles;

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• Recorded assets are reconciled with existing assets (inventory), and any discrepancies are investigated and duly corrected.

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Employees involved in any stage of operations related to expenses, payments, and accounting entries must comply with this policy.

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The company conducts its activities in compliance with applicable national and international laws regarding Anti-Money Laundering and condemns all forms of corruption, whether direct or indirect, in its public relations (transactions involving the government, directly or indirectly) or private relations (transactions between private companies without government involvement).

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Money laundering practices are characterized by the intent to conceal or disguise the nature, origin, location, disposition, movement, or ownership of assets, rights, or values derived, directly or indirectly, from criminal activities. A person is considered the perpetrator of the crime if, with the intent to launder money, they:

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• Acquire, receive, exchange, negotiate, give or receive as collateral, move, or transfer assets;

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• Use assets, rights, or values derived from criminal activity in economic or financial activities.

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The origin and destination of received assets and values must be analyzed, taking into account the reputation and identity of the third parties involved, as well as transparency in business conduct.

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Our employees are prohibited from engaging in any of these activities and must strictly comply with anti-money laundering laws.

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The Hotline is a channel intended for employees and third parties to report any suspicions related to standards of conduct and ethical principles, including potential violations of this Policy.

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If an employee identifies or suspects a situation that may constitute a potential violation of this Policy, they must immediately contact the Reporting Channel.

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Reports can be made through the Hotline communication channel, by phone at 0800-941-4114 or via the website http://bit.ly/ecohotline-brazil.

 

If the reporter prefers, reports can also be sent by mail addressed to the Compliance Department, using the following label:

 

TO THE COMPLIANCE DEPARTMENT
Av. Rio Branco, nº 123, 10th floor, Centro, Rio de Janeiro, RJ – ZIP Code 20040-905.

 

The report should be as detailed as possible (indicating date, location, time, involved parties, and detailed facts) to enable a proper investigation process, which will always preserve the confidentiality of the information obtained.

 

When using the communication channels, employees may choose to remain anonymous if they wish. No employee who, in good faith, reports a suspected violation of laws, regulations, or the company's internal policies should suffer any retaliation or reprisal.

 

After making a report, do not share information with any third parties other than members of the Compliance Department, so that investigations are not compromised.

 

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NOTE: We have zero tolerance for any act of corruption, whether by our personnel or any third party acting on our behalf.

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