PeopleDBA Anticorruption Policy (Version 2.0)
1. Introduction
PeopleDBA, an official Oracle partner and leader in information technology solutions, reaffirms its unwavering commitment to ethics, integrity and legal compliance in all its operations. This Anticorruption Policy reflects our dedication to the highest standards of business conduct and to the strict compliance with all applicable laws and regulations against bribery and corruption.
2. Objective
To establish comprehensive and rigorous guidelines to prevent, detect and respond to any form of corruption or bribery in PeopleDBA's activities, ensuring compliance with national and international anticorruption laws, including, but not limited to, the Brazilian Anticorruption Law (Law No. 12.846/2013), the United States Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
3. Scope
This policy applies, without exception, to all directors, executives, employees, contractors, business partners, suppliers, consultants, representatives and any person or entity acting on behalf of PeopleDBA, in all its operations in Brazil and Latin America.
4. Definitions (Expanded)
4.1. Corruption: Abuse of entrusted power for private gain, including active and passive corruption.
4.2. Bribery: Offering, promising, giving, accepting or requesting an undue advantage of any value, which may be financial or non financial, directly or indirectly, and regardless of location, in violation of applicable laws, as an incentive or reward for a person to act or fail to act in relation to the performance of their duties.
4.3. Facilitation Payment: Small payments made to secure or expedite routine or necessary actions to which the payer has a legal or other entitlement.
4.4. Money Laundering: Process of concealing the origin, ownership or destination of money obtained illegally or dishonestly, making such proceeds appear to originate from a legitimate source.
4.5. Influence Peddling: Use of position or influence over a third party to obtain favors or preferential treatment.
5. Main Guidelines (Expanded)
5.1. Prohibition of Bribery and Corruption: PeopleDBA strictly prohibits any form of bribery or corruption, whether direct or indirect, through third parties, in all its operations and business relationships. This includes, but is not limited to, bribes, kickbacks and any other form of improper payment.
5.2. Relationship with Public Officials: It is expressly prohibited to offer, promise, give or authorize the delivery of anything of value to a public official, directly or indirectly, with the intent to influence their actions or obtain an undue advantage. This includes employees of state owned companies and public international organizations.
5.3. Facilitation Payments: PeopleDBA prohibits facilitation payments, regardless of the amount or local practice. Employees must immediately report any request for a facilitation payment.
5.4. Gifts, Hospitality and Entertainment: Offering or receiving gifts, hospitality or entertainment must be done in accordance with the company's internal policies, always transparently and without the intention of influencing business decisions. All gifts above R$ 100.00 must be recorded and approved by management.
5.5. Donations and Sponsorships: All donations and sponsorships must be approved by senior management, properly documented and in compliance with applicable laws. A detailed record of all donations and sponsorships will be kept and audited regularly.
5.6. Political Contributions: PeopleDBA does not make political contributions on behalf of the company. Employees may make personal contributions, provided they are not associated with the company and do not use company resources.
5.7. Conflict of Interest: All employees must avoid situations that may create or appear to create conflicts between their personal interests and those of the company. Potential conflicts must be declared and managed in accordance with internal procedures.
5.8. Third Party Due Diligence: PeopleDBA performs appropriate due diligence before engaging with third parties, including business partners, suppliers and agents. The process includes background checks, risk assessment and ongoing monitoring.
5.9. Mergers, Acquisitions and Joint Ventures: Before any merger, acquisition or formation of a joint venture, PeopleDBA will conduct comprehensive anticorruption due diligence and will include appropriate protections in the contracts.
6. Accounting and Financial Records
PeopleDBA keeps books, records and accounts that accurately and fairly reflect all transactions and asset dispositions. It is strictly prohibited to make false or misleading entries in the company's books and records. All payments and transactions must be accurately recorded, including sufficient details to ensure transparency.
7. Training and Communication
7.1. All employees will receive regular and mandatory training on this policy and the applicable anticorruption laws. The training will be adapted to the specific risks faced by different roles and levels within the organization.
7.2. The company is committed to maintaining clear and continuous communication about the importance of anticorruption compliance, including regular updates on changes in legislation and best practices.
8. Reports and Non Retaliation
8.1. Whistleblowing Channel: PeopleDBA establishes a robust and confidential Whistleblowing Channel to report any suspected violation of this policy or unethical behavior. The Whistleblowing Channel is available 24 hours a day, 7 days a week, through the following means:
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Email: denuncia@peopledba.com.br
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Website: www.peopledba.com.br
8.2. Confidentiality and Anonymity: All reports will be handled with strict confidentiality. The whistleblower will have the option to remain anonymous, if desired.
8.3. Investigation of Reports: All reports will be promptly investigated by an independent team, ensuring impartiality and objectivity.
8.4. Protection against Retaliation: PeopleDBA does not tolerate retaliation against anyone who, in good faith, reports a concern about a possible violation of this policy. Any act of retaliation will be considered a serious violation of this policy and will result in disciplinary action.
8.5. Feedback and Transparency: Whistleblowers will receive feedback on the progress and outcome of investigations, to the extent possible and appropriate.
9. Monitoring and Audit
9.1. PeopleDBA conducts regular internal audits to ensure compliance with this policy and the applicable anticorruption laws.
9.2. The Policy will be regularly monitored and reviewed to ensure its effectiveness and compliance with applicable laws.
10. Consequences of Violations
10.1. Violations of this policy will result in disciplinary action, which may include warning, suspension, dismissal for just cause and/or legal action.
10.2. The company reserves the right to terminate business relationships with third parties who violate this policy.
10.3. When applicable, violations will be reported to the competent authorities for possible criminal prosecution.
11. Review and Update
11.1. This policy will be reviewed annually by the PeopleDBA Ethics and Compliance Committee.
11.2. Updates will be made as necessary to ensure its continued effectiveness and alignment with best practices and legal requirements.
11.3. All significant changes will be communicated to all employees and relevant stakeholders.
12. Responsibility
12.1. Ultimate responsibility for compliance with this policy lies with the Board of Directors and senior management of PeopleDBA.
12.2. Each manager and supervisor is responsible for ensuring that their subordinates understand and comply with this policy.
12.43. All employees have the individual responsibility to adhere to this policy and to report any suspected violation.
This Anticorruption Policy takes effect from the date of its publication and must be widely disseminated to all employees, partners and stakeholders of PeopleDBA. The company is committed to providing the necessary resources for the effective implementation of this policy.
Update date: 11/10/2024
Approved by: Rodrigo Leite Fuentes
CEO PeopleDBA
