Anti-Corruption Policy

Since January 2014, the Act establishes assumptions which must be met by companies in fighting corruption.

Failure to comply with the provisions of the Act can result in fines of up to 20 % of sales, full compensation for the damage caused to public coffers and closing of the activities of the corporation, among others.


How to be safe

Processes and controls aimed at institution and mitigate the risks of fraudulent operations will be key in preventing any contingencies.



• Evaluation (identification / measurement) risk of fraud and corruption.
• Evaluation of business partners, service providers, suppliers, and others.
• Assessment, design and implementation of compliance.
• Review mapping operations in order to identify possible irregularities.
• Identification of relevant risks, including financial, regulatory or other potential related to third parties.
• Support the implementation of processes and controls.
• Monitoring exceptions / signs of violation of the rules.
• Review the internal audit, if any, or implementation of periodic internal audits.
• Action plan for adjustment and correction and mitigation of critical points.
• Design and code of ethics review.
• Training.


• Understanding and analyzing the technological environment as the company's operations.
• Monitoring the system to check risk violations.
• Validation within the scope of approval.
• Parameter Review.


• Investigations in the context of fraud, litigation and arbitration of economic and financial nature (assessment of damage and loss of profit, post-transaction purchase price adjustment etc.).




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