POLICIES
Anti-Corruption Policy
The present Anti-Corruption Policy was created with the aim of ensuring the PMI Group's commitment to maintaining the highest standards of transparency and ethics in all its activities. The PMI Group has implemented a compliance program in accordance with Brazilian laws, as well as foreign laws that establish international corporate conduct standards, such as the United States' Foreign Corrupt Practices Act (“FCPA”) and the United Kingdom's UK Bribery Act.
The Group's compliance program reflects its zero-tolerance policy regarding any illegal practices by its employees, including its directors and advisors, or by any individual or institution representing or acting on its behalf. This same "Zero Tolerance" principle is now reflected by the PMI Group through this Anti- Corruption Policy.
The Anti-Corruption Policy is an essential part of the PMI Group's compliance program, reflecting the Group's senior management commitment to ensuring compliance with its activities and establishing the internal rules that must be followed by employees, representatives, and affiliates of the Group when acting on its behalf.
The Anti-Corruption Policy also serves as a guide for identifying and addressing problematic, conflicting, or even illegal situations.
The Anti-Corruption Policy is an annex to the Group's Code of Ethical Conduct and must be read and applied in conjunction with the principles and rules established in the aforementioned Code and in its other policies and procedures.
As important as following the ethical conduct and anti-corruption standards is the responsibility to not overlook violations of the Group's Code of Ethical Conduct and this Policy. If you have any doubts, please contact the Compliance Department.
POLICIES
FOR THE PURPOSES OF THIS POLICY, THE FOLLOWING IS UNDERSTOOD AS:
Gifts: Promotional items with no or low market value, which contain the
company logo. Employees or representatives of the PMI Group may only
to give, offer, promise or receive gifts when in the form of freebies.
All directors, employees, and internal consultants.
Consultants who provide services to the PMI Group in a manner
continues.
Consultants hired by PMI Group for projects
specific.
Offering or promising an undue advantage to a third party, directly or indirectly.
indirectly, to obtain or contract business or to determine it to practice, omit or
delay an act for its direct or indirect benefit. The concept also includes the receipt of
undue advantage of a third party, directly or indirectly, for their own benefit, in
detriment to the best interests of the PMI Group.
Any person who, even temporarily or without
remuneration, hold a public office or function full-time or part-time, including a position
or function in public companies or mixed economy companies. The term encompasses
also any employee, representative or leader of a political party or candidate for
elective position.
Anyone who, even temporarily or without
remuneration, holds a public office, employment or function in state entities or in
diplomatic representations of a foreign country, or holds a position, employment or function in
companies controlled, directly or indirectly, by the Public Authority of a country
abroad or in international public organizations.
National and foreign laws that establish criteria
for the prevention of corruption not only by public bodies, but also by companies and
people from the private sector. For the purposes of this Policy the most relevant standards are:
- Law 12.846/2013;
- Law 8.429/1992;
- Law 8.666/1993;
- Criminal Code;
- Foreign Corrupt Practices Act (FCPA of the USA);
- UK Bribery Act (United Kingdom).
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