Compliance Policy

1.1 GUIDELINES

1.1.1 GEPLAN acts in accordance with current legislation and the international commitments made by the Federal Government with regard to preventing and combating money laundering, terrorist financing and corruption. In this sense, it declares that its activities are totally free, directly or indirectly, from involvement in any illegal conduct, corrupt practices or those that contravene constitutional, ethical and commercial principles. It hereby declares that it is fully aware of all the terms of the Brazilian Anti-Corruption Law (Law No. 12.846/13) and Decree No. 8.420/2015, committing itself, its partners, employees, contractors and/or subcontractors to refrain from any conduct or act that may result in a violation of said legislation.

1.1.2 GEPLAN also declares that it has implemented and disseminated, or is in the process of implementing and disseminating, internally and to its partners and/or third parties linked to this contract, or is in the final stages of implementing and disseminating internal mechanisms and procedures for integrity, auditing, encouraging whistleblowing, investigating irregularities and effectively applying codes of ethics and conduct, agreeing to submit to the Contractor, within 10 working days of the request, due proof of the applicability and effectiveness of such mechanisms and procedures, on an ongoing basis and in compliance with current legislation.

1.1.3 When dealing with the public or private sector, whether national or foreign, it is forbidden to offer, promise or receive money or anything of value, or favors, either directly or indirectly, for the purpose of obtaining any kind of undue advantage for GEPLAN, for oneself or for third parties.

1.1.4 It is unacceptable to carry out acts aimed at unduly influencing a public agent, commercial or business partner, national or foreign, with the aim of obtaining or maintaining business, a contract, authorization or any other benefit or advantage.

1.1.5 Facilitation payments are not permitted.

1.1.6 GEPLAN does not make contributions or donations of any kind for political purposes to any person, party or related organization, either directly or through third parties.

1.1.7 With a view to identifying signs of money laundering, terrorist financing and/or corruption, any economic or legal transactions that may indicate or be related to the commission of these crimes must be analyzed.

1.1.8 Training and awareness-raising actions on integrity should be offered regularly in order to strengthen the Entity’s ethical and compliance standards.

1.2 SPECIFIC GUIDELINES FOR CONTRACTING

1.2.1 It is forbidden to establish relationships with business partners listed in the Register of Ineligible and Suspended Companies (CEIS) and the National Register of Punished Companies (CNEP) of the Office of the Comptroller General (CGU).

1.3 SPECIFIC GUIDELINES FOR GIFTS AND HOSPITALITY

1.3.1 No gifts or premiums in excess of individual use should be offered.

1.3.2 In commercial and business relations, the offering of gifts, presents and hospitality should be avoided more than twice in a calendar year, so as not to appear improper.

1.3.3 The offer of gifts and hospitality to a public official, whether national or foreign, must comply with current legislation and the rules of the Public Body to which the beneficiary is linked.

1.4 SPECIFIC GUIDELINES FOR RECORDING AND ACCOUNTING

1.4.1 All payments and receipts must be recorded, accounted for and documented in a timely, accurate and detailed manner, so as to correctly reflect all transactions, events or facts.

1.4.2 Controls must be in place to ensure that:
a) All transactions or operations are classified under the correct description of the corresponding expense;
b) No assets are kept or used without proper registration;
c) All operations carried out are legitimate and verifiable;

1.5 SPECIFIC GUIDELINES FOR CONFLICT OF INTEREST

1.5.1 Situations of actual, potential or apparent conflict of interest must be avoided.

1.5.2 When faced with a situation of conflict of interest, the people covered by this Integrity Policy must declare themselves to be conflicted, refraining from participating in discussions and from voting on matters related to the identified conflict, in order to ensure the independence, impartiality and transparency of the process.

1.5.3 Direct or indirect participation in processes that involve:
a) Contracting companies or operations with public bodies or entities that have relatives or close relations in decision-making positions;
b) Managing contracts and other transactions with companies in which there is a personal financial or family interest;
c) Selecting candidates to fill positions or exercise functions, including the selection of directors and/or trustees, in which family members up to the third degree are involved.

1.5.4 Participation in external activities that could negatively affect GEPLAN should be avoided.

1.5.5 The improper use of position or function and privileged information to benefit oneself or third parties is forbidden.

1.5.6 In commercial and business relationships, an attempt should be made to identify the existence, with the counterparty to the operation, of an employee or former employee who has been dismissed from GEPLAN for less than 2 years, who has had access to relevant information as a result of holding a position or function at GEPLAN and who will act directly or indirectly in the fulfillment of the contractual object. Any cases identified should be brought to the attention of the Executive Board.

1.6 SPECIFIC GUIDELINES FOR INVESTMENTS

1.6.1 In the internal processes involving decision-making, prospecting, acquisition, divestment and investment management, GEPLAN will permanently observe this Policy and the other guidelines established in the Investment Policies.

1.6.2 GEPLAN’s Investment Policies must establish parameters of integrity to be observed in the application and management of the entity’s resources.

1.6.3 In its relations with companies in which it holds shares or other types of investments, including real estate-based companies, GEPLAN will continuously encourage the adoption of measures that strengthen its commitment to ethics and integrity, as well as combating and preventing acts of fraud and corruption.

1.6.4 GEPLAN should support initiatives where it can effectively contribute to the dissemination and improvement of practices aimed at consolidating a healthy business environment.