Anti-Corruption and Anti-Money Laundering Policy
This policy aims to guide our Employees and Service Providers on the behavior to be adopted when conducting any business related to our organization, always with the objective of combating corruption and money laundering.
1. Objectives
Build a strong institution aligned with regulations that prevent harmful conduct, not only to the organization but to society as a whole, promoting an anti-corruption culture.
Establish well-defined relationships, including international ones, focused on combating corruption.
Create mechanisms to prevent money laundering and fight corruption, in compliance with the current legal framework in the country.
Encourage suppliers, in addition to committing to the organization’s code of conduct, to implement their own compliance mechanisms.
2. Target Audience
This policy applies to all Employees and Service Providers.
3. Definitions
Public Agent(s): Anyone who performs a public function. The Administrative Improbity Law (Law No. 8.429/92) defines a Public Agent as any individual who performs, even temporarily or without remuneration, by election, appointment, designation, hiring or any form of investiture or bond, a mandate, position, job, or public function.
Compliance Channels: Channels provided by Ikatec and affiliated companies for their Employees and third parties to make compliance inquiries and report suspected violations of the Code of Ethics and other policies. Contact can be made via email at [email protected]. Reports are confidential and can be made anonymously.
Code of Ethics: The Ikatec Code of Ethics, which, together with other internal policies and regulations, establishes the expected conduct of Employees and Service Providers.
Employee(s): All those who act on behalf of or represent Ikatec, including partners, associates, directors, and employees.
Corruption: The act or effect of corrupting someone or something to obtain illicit advantages.
Due Diligence: A detailed examination of information and documents of an individual or legal entity for specific purposes (e.g., contracts).
Compliance Group: Composed of representatives from the Board of Directors, Legal Department, Finance, and Human Resources, it is responsible for drafting, reviewing, and interpreting the Code of Ethics and other policies, managing compliance channels, and investigating suspected misconduct.
Ikatec: The business entity and all its subsidiaries, controlled companies, affiliates, or any entity that is part of its structure.
Money Laundering: The process of transforming resources from illicit activities into assets with an apparently legal origin.
Anti-Corruption Laws: Law No. 12.846/2013, which addresses the administrative and civil liability of legal entities for acts against the national or foreign public administration. For this policy, the term includes other laws and regulations, such as the Brazilian Penal Code and international standards adopted by Brazil.
Anti-Money Laundering Laws: Law No. 9.613/1998, which addresses crimes of money laundering or concealment of assets, rights, and values, as well as the prevention of using the financial system for illicit purposes.
Bribery: Inducing someone to perform a specific act in exchange for illegal favors or benefits.
Undue Advantage: Any advantage that a Public Agent is not entitled to by virtue of their public function.
4. Guidelines
4.1 – Bribery and Corruption
Employees and Service Providers are prohibited from offering bribes or engaging in any act of corruption. We facilitate access for government authorities to databases that help identify money laundering activities and have established mechanisms to train our employees in detecting suspicious operations.
The Anti-Corruption Law prohibits the following conduct:
I. Promising, offering, or giving, directly or indirectly, an undue advantage to a public official or to third parties related to them;
II. Financing, funding, or sponsoring illicit acts provided for by law;
III. Using intermediaries (individuals or legal entities) to conceal the interests or identity of beneficiaries;
IV. Defrauding, disrupting, or manipulating bidding procedures;
V. Hindering investigations by regulatory or oversight bodies.
No Employee or Service Provider will be penalized for refusing to pay bribes or engage in corruption.
4.2 – Facilitation Payments
Facilitation payments made to Public Agents or persons indicated by them to expedite acts are prohibited.
4.3 – Business Partners
No business partner is authorized to engage in acts of corruption or violate the law on behalf of or in defense of Ikatec. All contracts must include clauses ensuring compliance with Anti-Corruption Laws and the Code of Ethics.
4.4 – Charitable Contributions
All requests for charitable contributions must be submitted to the Compliance Group for analysis.
4.5 – Political Contributions
Ikatec does not contribute to or fund political candidates, respecting legislation and the individual freedom of its employees.
4.6 – Union Contributions
We respect the right to union membership, provided that Ikatec’s resources or assets are not used. Contributions are made in accordance with current legislation.
4.7 – Sponsorships
Sponsorships are only made after thorough analysis, focusing on the integrity of the sponsored entity and its relevance to Ikatec’s social objectives.
4.8 – Money Laundering
Employees and Service Providers must avoid suspicious acts and report them to Ikatec. Examples of red flags include requests for cash payments or payments to multiple beneficiaries.
4.9 – Record Keeping
We conduct business with integrity, ethics, and transparency. False, incomplete, or misleading documentation is prohibited.
4.10 – Red Flags
Employees and Service Providers must report suspicious situations, such as a history of corruption or requests for excessive commissions.
5. Responsibilities
Employees and Service Providers must adhere to the Code of Ethics, ensure that business partners are aware of and comply with these values, and report any suspected violations.
6. Final Considerations
In addition to violating ethical principles, unlawful conduct jeopardizes the organization’s image, reputation, sustainability, and longevity. In situations not covered by this policy, consult the Compliance Group. Violations of this policy are subject to the sanctions outlined in the Internal Regulations and Code of Ethics, as well as applicable legal actions.
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