Anti-Corruption Statement:
We have established the key guidelines and reaffirmed ADD IT’s position regarding the rejection of and fight against any form of corruption, including, but not limited to, extortion and bribery.
ADD IT does not adopt, encourage, and/or permit any conduct that constitutes or results in acts harmful to national or foreign public administrations or other private companies, in accordance with 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;
To exclude or attempt to exclude a bidder, supplier, or customer through fraud or by offering any kind of benefit; Committing fraud in connection with a resulting 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.
Employee Responsibilities: Comply with and ensure compliance with this policy, as well as with the provisions of the Code of Ethical Conduct, and, when necessary, contact the Risk, Compliance, and Prevention Department for guidance on situations that conflict with this policy or in the event of situations described herein.
Third Parties and Suppliers: Comply with and ensure compliance with this Policy, as well as with the provisions of the Supplier Code of Ethics and Conduct, and, when necessary, use the channels available within the company to seek guidance regarding situations that conflict with this Policy or when situations described herein 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.
