1. PURPOSE
This document aims to provide guidance on the main principles that govern the relationship between the Organization and its partners (clients, suppliers, and service providers).
The Organization values these partnerships, considering them essential for fulfilling its mission and for building healthy, transparent, and sustainable relationships.
The topics addressed herein seek to meet the legitimate interests of all parties involved.
2. RELATIONSHIP WITH CLIENTS
Regarding clients, the Organization commits to:
- Valuing the trust of its clients;
- Competing ethically in the market;
- Never applying any measures that restrict free competition;
- Not using or benefiting from information obtained through illicit means;
- Being transparent in presenting the products and services offered, so that the client can understand how our offerings meet their needs;
- Presenting a clear and honest pricing strategy, in compliance with applicable legislation;
- Respecting and making the best use of the client’s opinion in the search for solutions and in the delivery of contracted services;
- Maintaining absolute confidentiality of all confidential information provided by the client, regardless of its source or access method, unless required by court order or regulatory investigation;
- Taking appropriate measures to protect the client’s licenses and intellectual property rights;
- Ensuring independence and impartiality in the client’s decision-making process, disclosing any pre-existing relationships or ties before presenting products or services;
- Never offering advantages to any client representatives, agents, or intermediaries with the intent of gaining preference in service selection or other benefits;
- Presenting honest and responsible business practices;
- Clearly providing instructions related to each of the services offered;
- Ensuring accuracy in billing and invoice issuance;
- Properly informing about potential risks of the products and services offered;
- Sharing this policy with all clients, making them aware of the current document.
3. RELATIONSHIP WITH SUPPLIERS / SERVICE PROVIDERS
Suppliers are a fundamental part of our business, as through them we deliver services to our clients. Therefore, the Organization has prerequisites that must be evaluated at the time of supplier contracting, as described in the Organization’s procedures.
In this context, the Organization adopts the following principles:
- Acting with integrity in production, delivery, and execution of signed contracts, ethically maintaining confidentiality and commercial conditions;
- Being committed to its suppliers, honoring established contracts and working to improve partnership relations;
- Sharing the content of this policy with all participants in its supply chain, making them aware of the current policy from this date forward;
- Valuing honesty in communication, which is essential for any serious and lasting partnership;
- Rejecting any form of prejudice, intimidation, pressure, or threats of any kind;
- Ensuring independence and impartiality in the Organization’s decision-making process regarding suppliers, disclosing any pre-existing relationships or ties prior to contracting products or services;
- Maintaining appropriate and ethical conduct, promoting these values among all individuals involved in third-party relationships, guided by dignity and sobriety, and never placing the supplier in a situation of discomfort or embarrassment.
The Organization expects its suppliers to adopt the same conduct we practice.
4. SUPPLIER / SERVICE PROVIDER EVALUATION
The purpose of the partner evaluation procedure is to collect specific data about the supplier or service provider in order to minimize risks related to contractual and integrity matters.
4.1 EVALUATION ITEMS
- Verify the regularity of the CNPJ registration;
- Verify the regularity of the articles of incorporation;
- Verify the regularity of the municipal registration;
- Submit the Organization to a Due Diligence process to increase confidence in contracting and mitigate potential compliance risks with suppliers;
- Assess technical capacity to perform the service;
- Check with other clients the quality of services provided;
- Require full compliance with Brazilian legislation, whether in service provision or in the production of items supplied to the Organization;
- Require compliance with current environmental legislation;
- Require compliance with our Code of Conduct and Anti-Corruption Policy.
5. RELATIONSHIP WITH THE PUBLIC SECTOR
The Organization acts ethically and with integrity in its relationships with both public and private sectors.
Precautions taken in this relationship include participation in public tenders and price consultations for private organizations, always aiming for excellence in service delivery, risk mitigation, and client loyalty.
6. PRINCIPLES AGAINST CORRUPTION
In the current national context, organizations play a crucial role in helping combat corruption, acting to promote a more ethical and transparent market. Given the uncertainties caused by mutual corruption between the public and private sectors, organizations must seek sustainability for their businesses, as illicit acts are among the factors that harm the entire value chain.
Corruption goes far beyond harming institutions—it affects society as a whole, depriving it of the resources necessary for a dignified life, which is a right of all citizens. This distortion of values is devastating and can severely damage a nation, as well as undermine its credibility internationally.
The role of organizations extends beyond job creation and economic stimulation: it is essential to join efforts to prevent direct and indirect corruption, striving for transparency in relationships, establishing corporate governance mechanisms, and continuously improving these mechanisms based on identified evidence. The goal is to prevent corruption and demonstrate that we can fight for a fairer and more equitable society.
The Organization values healthy relationships with its partners, ensuring that commercial transactions are clear and aim to fulfill signed contracts, based on laws and market best practices.
Our Anti-Corruption Policy aims to align with laws that address corporate liability for illicit acts, fraud, and tampering against public and private administration, and prohibit violations against economic order. It is notably based on Laws No. 12.846/2013, No. 12.529/2011, No. 8.666/1993, and No. 11.129/2022, the United Nations Convention against Corruption (UN Convention), and the Inter-American Convention against Corruption (OAS Convention), all ratified by Brazil, among others.
The Organization is committed to combating illicit, fraudulent, corrupt, and tampering practices against public administration, as well as prohibiting violations against economic order, and ultimately adopting standards of integrity, legality, and transparency in its actions and relationships with partners, Managers, and Directors.
6.1 CONFLICTS OF INTEREST
Some situations may favor or suggest a conflict of interest. Below are examples we consider important to highlight in this document:
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- Receiving improper personal benefits due to one’s position;
- Using one’s position to influence or participate in a transaction with a supplier, client, or partner in which there is a personal interest;
- Performing activities that are not requested by the Organization;
- Having a personal, habitual relationship between suppliers and employees;
- Accepting, directly or indirectly, money or valuable items from any person or entity interested in establishing commercial relations with the Organization;
- Having financial interests, ownership, or conducting business in partner or competing organizations;
- Avoiding communication that is inappropriate for good business relations and may generate conflicts of interest;
- No asset, information, resource, or position may be used to obtain personal gain or for competition.
6.2 GIFTS AND HOSPITALITY (ENTERTAINMENT, TRAVEL EXPENSES, ACCOMMODATION, AND OTHER BENEFITS)
Employees, Managers, and Directors of the Organization may receive any type of gifts, giveaways, gratuities, travel, and other benefits up to a maximum value of R$200.00.
Regarding the offering of gifts and giveaways, the Organization reserves the right to offer its partners (clients, suppliers, and service providers) gifts and giveaways up to a maximum value of R$200.00. This amount will be adjusted at least annually.
The Commercial Cell contacts the partner to identify the policy in place, aiming to avoid offering gifts to partners who adopt a zero-receipt policy. In cases where the value exceeds R$200.00, the Compliance Committee and Senior Management must be notified to authorize the release. Offering cash gifts (check, deposit, transfer, or equivalent) is strictly prohibited.
6.3 DONATIONS AND SPONSORSHIPS
No contribution (e.g., sponsorships, donations) may be made with the intent of obtaining illegitimate benefits or favors for the Organization.
Partnerships and contributions (e.g., sponsorships, donations) to any philanthropic entity, non-governmental organization, or public sector origin must comply with applicable legislation and our corporate guidelines.
7. IMPROPER OR ILLEGAL PAYMENTS
Payments made to service providers and suppliers must comply with the Organization’s Financial, Accounting, and Tax Management procedures, as well as the billing of services provided by the Organization to its clients.
All payments made or received by the Organization and its employees on its behalf must be properly recorded and accounted for. The following are strictly prohibited:
- Conducting secret, unregistered operations;
- Inadequate, ambiguous, or fraudulent accounting entries;
- Using accounting schemes intended to conceal or otherwise cover up illegal payments;
- Falsifying or requesting reimbursement for expenses that do not meet the Organization’s internal requirements and procedures.
8. FACILITATION OR EXPEDITING PAYMENTS
The Organization does not permit “facilitation payments” or “expediting payments,” which refer to any small or nominal payment made to a public authority, individual, or private legal entity with the intent to facilitate, expedite, accelerate, or guarantee the performance of a bureaucratic procedure.
9. HARASSMENT / ABUSE OF POWER
The Organization is committed to providing an environment free from any type of harassment or intimidation, whether verbal, written, or physical. Such practices are subject to disciplinary measures and appropriate penalties.
The Organization promotes diversity and seeks to eliminate all forms of negative discrimination based on race, color, gender, sexual orientation, age, religion, political opinion, nationality, social status, or physical condition. This Organization does not tolerate harassment—whether sexual, economic, moral, or of any other nature—nor situations that constitute disrespect, intimidation, or threats in relationships among employees, regardless of hierarchical level.
Any form of sexual harassment involving the mention of favors or the initiation of any such approach is not tolerated by the Organization.
10. UNFAIR COMPETITION
Regarding competition, the Organization values partners who respect all regulatory norms and does not tolerate any form of unfair competition or unethical business practices, including the use of agreements or monopolies that may cause harm.
It is the partner’s obligation to maintain respectful relationships with their competitors and refrain from providing information or making statements that could damage a competitor’s image.
11. FORCED OR CHILD LABOR
The Organization opposes forced labor and situations involving coercion, punishment, and degrading disciplinary measures. It encourages its partners to monitor their value chain to prevent and combat such practices.
The Organization is against child labor and does not condone any situations that may potentially involve:
- Irregular employment of adolescents under 16 years old (except as apprentices starting at age 14);
- Inadequate working conditions for the development of adolescents aged 16 to 18;
- Any form of discrimination, violence, or violation of fundamental rights as defined by the Child and Adolescent Statute.
The Organization does not allow or encourage hiring or partnerships with organizations that support any form of adult or child labor exploitation.
The Organization rejects such practices and reserves the right not to maintain any type of relationship with organizations, entities, or institutions that adopt such conduct.
12. OCCUPATIONAL HEALTH AND SAFETY
The Organization encourages its partners to comply with laws related to occupational health and safety. Documents and procedures required by the Ministry of Labor must be renewed within the deadlines established by regulatory standards.
It is essential to adopt healthy habits related to leisure, sports, hygiene, and nutrition, aiming at collective well-being.
13. ENVIRONMENT
Given the current context in which environmental awareness is increasingly important, the Organization’s main objective is for organizations to act in a socially and environmentally responsible manner, also achieving long-term business success.
14. CONFIDENTIALITY AND NON-DISCLOSURE
Confidential and strategic information must not be disclosed. Partners must treat as confidential any non-public information received—by any means or form—during the preparation of proposals and throughout the duration of their contracts and/or proposals.
Confidentiality extends for a period of five (5) years after the end of the contract, unless there is a court order, regulatory investigation, or force majeure event that makes the information public.
15. PAYMENT METHODS
Payments related to services provided by suppliers will be negotiated directly with the person responsible for the purchase, who interacts with the Procurement Cell, and subsequently in accordance with the Organization’s Accounting Policy.
Regarding clients, the payment method will be negotiated with the Commercial Cell and formalized through contract signing, in accordance with the Financial, Accounting, and Tax Management Policy.
16. POLICY COMPLIANCE
We expect our partners to respect and support this policy in force, confident that this is the path to combat irregularities that hinder the adoption of best practices that underpin compliance. It is the duty of all of us engaged in this ongoing effort for moralization, ethics, and integrity to apply practices in our daily routines that promote compliance and sustainability.
The Organization reserves the right to monitor compliance with this policy and to encourage corrective measures among its partners in cases of non-compliance, under penalty of contract termination and disqualification from future bidding processes.
The guidelines in this policy do not override other specific rules and/or service agreements.