The Corporate Policy of Loyal Practices has as guidelines:

 

• Ensure the existence of an effective process of preventing and combating corruption and bribery, aligned with applicable laws and regulations.

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• Disseminate culture and awareness of the prevention and fight against corruption and bribery and money laundering.

 

• Conduct  business activities with transparency, integrity and commitment to the highest standard and practice of ethical conduct, without ever engaging in illegal activities, complying with laws, regulations and policies, as well as the determinations and rules emanating from anybody or entity, national or foreign, to which it is subject by legal or contractual obligation, whose purpose is to curb or prevent corrupt practices, illegal expenses, related to political activity, harmful acts, infractions or crimes against the economic or tax order, the financial system, the capital market or public administration, national or foreign, of "laundering" or concealment of goods, rights and values, terrorism or terrorist financing, provided for in applicable national and/or foreign legislation.

 

• Provide collaborative and transparent action in all relationships with public authorities ensuring the prevention and fight against corruption and bribery.

 

• Zero tolerance for any form of public or private corruption, including but not least bribery(1), embezzlement, extortion, illegal agreements and facilitation payments(2) made by our employees or third parties in conducting our business.

 

• As an employee or with or through any third party acting on behalf of Umantech you are prohibited from participating in any corrupt activity and from offering, promising, providing or authorizing, directly or indirectly, any person to give money or any valuable sum to a Public Official or any private natural or legal person for the purpose of obtaining or maintaining any undue advantage.

 

• As our employee or third-party, you must comply with all applicable local and international laws, regulations and regulations related to anti-corruption issues where we do business, including the Brazilian Clean Company Law.

 

"Bribery" means any offer, promise or authorization of payment regarding any incentive to any Public Official or person related to it, including any private sector natural or legal person, if the incentive is intended to influence the beneficiary to misuse his or her position or duty to obtain or maintain an improper business advantage for his or her own benefit or third party. "Facilitation Payments": are nominal value payments to Public Officials in a lower hierarchical position to expedite a judicial or administrative process of which a Group company may be a party or to facilitate routine government actions over which Public Employees have no discretion. Examples of routine non-discretionary actions may include the provision of police protection, licensing, permits or public services, or customs clearance services.