Políticas

Anti-Bribery Policy

PT/BREN/US

1. Purpose

This policy establishes the guidelines and principles designed to prevent, detect, and mitigate bribery risks in all operations and relationships of CPD Informática. It ensures compliance with current legislation and the NBR ISO 37001:2016 - Anti-Bribery Management System.

The purpose is to foster an organizational culture grounded in ethics, transparency, and integrity, ensuring that employees, suppliers, and other stakeholders understand and adopt practices that prevent illicit acts, safeguarding trust and the sustainability of the business.

2. Scope

This policy applies to all employees, directors, board members, suppliers, third parties, business partners, and any stakeholders who have a direct or indirect relationship with CPD Informática.

It covers all operations, activities, and business transactions, regardless of the location where they are conducted.

3. References

All members of CPD Informática must strictly comply with anti-bribery laws and regulations applicable in the jurisdictions where the organization operates, including but not limited to:

  • 3.1. ABNT NBR ISO 37001:2017 - Anti-Bribery Management Systems.
  • 3.2. ABNT NBR ISO 37301:2021 - Compliance Management Systems.
  • 3.3. COD.SGI.001 - Code of Ethics and Conduct.
  • 3.4. POL.SGI.002 - Compliance Policy.
  • 3.5. POL.SGI.003 - Human Rights Policy.
  • 3.6. Brazilian Law No. 12.846/2013 - Law on the Administrative and Civil Liability of Legal Entities for Acts Against Public Administration, whether domestic or foreign (commonly known as the Brazilian Clean Company Act).

4. Definitions

  • 4.1. Bribery: The offering, promising, giving, soliciting, or receiving of any undue advantage (whether financial or non-financial) to improperly influence a decision or action.
  • 4.2. Third Parties: Companies, suppliers, consultants, and partners performing activities on behalf of the organization, who may represent a bribery risk.
  • 4.3. Whistleblower Channel: A secure and confidential mechanism for reporting concerns or evidence related to anti-bribery violations.

5. Guidelines

This policy aligns with CPD Informatica’s values and strategic objectives, promoting an ethical environment free from illicit practices. Integrity is a fundamental pillar for building trust and ensuring business sustainability.

Bribery, in any form—direct or indirect—is strictly prohibited. No employee, supplier, third party, or business partner is authorized to offer, promise, give, solicit, or accept any undue advantage, whether financial or non-financial, with the intent to improperly influence a decision.

The organization is fully committed to complying with the requirements of the Anti-Bribery Management System and to continuously improving it. This includes ensuring that processes, training, controls, and monitoring mechanisms are regularly updated and effective in response to new challenges and regulatory changes.

6. Authority and Independence of the Anti-Bribery Compliance Function

The Integrated Anti-Bribery and Compliance Management System operates with an independent structure, fully authorized to oversee, monitor, and report bribery risks directly to Senior Management.

The Compliance Officer has full autonomy to conduct investigations, recommend corrective actions, and foster an ethical culture within the organization.

7. Whistleblower Channel and Protection Against Retaliation

The organization encourages third parties and all stakeholders to report, in good faith, any suspicions or evidence of bribery. The company ensures confidentiality, protection against retaliation, and proper handling of all reports.

The Whistleblower Channel is confidential and accessible to everyone, allowing anonymous reporting and ensuring impartiality in investigations.

8. Penalties

Violation of this policy will be met with zero tolerance and may result in disciplinary actions, including termination for cause, contract termination with third parties, and legal action as appropriate.

All infractions will be thoroughly verified, ensuring fairness and equity in the application of decisions.