We have established the main guidelines and ratified the company's position on repudiating and combating any form of corruption, including but not limited to extortion and bribery. The company does not adopt, encourage and/or allow the practice of any conduct that constitutes or results in acts harmful to the national or foreign Public Administration and other private companies, observing the provisions of Law No. 12.846/2013 ("Anti-Corruption Law") and the items highlighted below:
Promising, offering or giving, directly or indirectly, an undue advantage to a public official or a third party related to them;
Financing, funding, sponsoring or in any way subsidizing the practice of the illegal acts provided for in this law;
Using a natural or legal person to hide or disguise their real interests or the identity of the beneficiaries of the acts carried out;
With regard to contractsFrustrating or defrauding, by means of an arrangement, combination or any other expedient, the competitive nature of a public bidding procedure;
Preventing, disturbing or defrauding the performance of any procedural act;
Driving away or seeking to drive away a bidder/supplier/customer by means of fraud or offering an advantage of any kind; Fraudulent contract;
Fraudulently or irregularly creating a legal entity to participate in the conclusion of contracts;
Obtaining undue advantage or benefit, fraudulently, from modifications or extensions of contracts entered into,
Manipulating or defrauding the economic and financial balance of contracts.
Contact with Public Officials: Contact between employees, as well as suppliers who act as representatives of the company with public agents, must take place in accordance with guidelines established in an internal rule governing relations with the Public Administration.
Political contributions: The company does not contribute, directly or indirectly, whether through the donation or loan of goods, use or assignment of physical or advertising space, sponsorship of events, assignment of labor and/or any other resource, pamphleteering, sending electronic messages, posting posters, or in any other way, to political campaigns, political parties, candidates for public office or any other type of organization that carries out political activity.
Employees' responsibilities: Observe and ensure compliance with this policy, as well as the provisions of the Code of Ethical Conduct and, when necessary, contact the Risks, Compliance and Prevention department for consultation on situations that conflict with this policy or upon the occurrence of situations described therein. Third parties and suppliers: Observe and ensure compliance with this Policy, as well as the provisions of the Code of Ethics and Conduct for Suppliers and, when necessary, contact the channels available in the company for consultation on situations that conflict with this Policy or when situations described therein occur.
Responsible for Purchasing: Carry out the process of prospecting, selecting, contracting and monitoring with criteria of quality and suitability, in accordance with internal rules and procedures. In addition, notify management of any signs of corruption on the part of suppliers, when identified.
Legal Department: Advising the company on the applicability, interpretation and updating of laws or regulations related to the topics.
