Anti-Corruption Policy
Document code: PL3 · Version: 1 · Date: 03/29/2025
1. Definition of the Anti-Corruption Policy
This Anti-Corruption Policy serves as a guide, providing directions to support decision-making that involves agents related to akquinet Brasil, preventing and combating acts of corruption toward public and/or private agents.
It must be interpreted and applied together with the company's Code of Ethics and Conduct, and with international anti-corruption conventions (UN, OAS and OECD), Brazilian Federal Law 12,846/2013 and its regulations, the Foreign Corrupt Practices Act (USA), the United Kingdom Bribery Act and any other applicable anti-corruption laws.
2. Recipients
This Policy must be observed by Partners, members of the Administrative Board, President, Directors, Employees, Interns, Apprentices, Outsourced Workers, Business Partners (consultants, commercial agents and associates) acting on behalf of akquinet Brasil, Vendors and Service Providers (other contractors and subcontractors of akquinet Brasil).
All Recipients must ensure compliance with the provisions set out herein, without exception.
3. General Guidelines
At akquinet Brasil we expect everyone acting on our behalf to behave ethically, transparently and with integrity. We do not tolerate acts of corruption, whether in the Private Sector, Public Sector or the Third Sector.
Corruption can occur through active or passive conduct.
Active: when someone, acting on behalf of or in the interest of akquinet Brasil, gives, promises, offers or authorizes any undue advantage to a public or private agent (or persons connected to them), so that they act or refrain from acting, lawfully or unlawfully.
Passive: when someone, acting on behalf of or in the interest of akquinet Brasil, demands, accepts a promise, receives or authorizes the receipt of any undue advantage from a public or private agent (or persons connected to them), so that they act or refrain from acting, lawfully or unlawfully.
"Undue advantage" means, for example: (i) any financial asset or resource; (ii) favors; (iii) gifts; (iv) nomination for public office or employment; (v) donations; (vi) sponsorships; (vii) hospitality expenses; (viii) training and courses; and (ix) awards.
4. Specific Guidelines
To reinforce the understanding established here, akquinet Brasil highlights some situations that, due to their recurrence, deserve greater attention and guidance.
Gifts, meals and entertainment
We encourage building good relationships with our various External Stakeholders. Exchanging gifts, meals and entertainment is not encouraged for our Partners, Board Members, President, Directors, Employees, Interns, Apprentices, Outsourced Workers, Business Partners, Vendors and Service Providers (the last three while acting on behalf of akquinet Brasil), but it is allowed in cultural contexts or institutional partnership celebrations.
Such exchanges may never be used to influence decisions or gain an undue advantage, and must never be made in cash or cash equivalents, such as vouchers or gift cards.
The exchange must be strictly institutional (never business related); occur transparently; not involve any conflict of interest; and must be immediately reported to the Governance Director of akquinet Brasil.
No exchange of any kind is permitted with government members, authorities, judiciary members or people related to them.
Donations to political parties
akquinet Brasil does not make donations to political candidates or parties, under Brazilian Federal Law 9,504/1997 (Electoral Law) and Federal Law 9,096/1995 (Political Parties Law).
akquinet Brasil respects Recipients' rights to affiliate with political parties and to donate to them or to candidates, but such donations must always be made in the Recipient's own name, never in the company's name.
This obligation also covers the pre-contractual phase, specifically due diligence on the contractor's record, legal status and reputation. Contractors must be informed in advance about the company's Codes and Policies and commit to complying with them.
Contracts must include an anti-corruption clause.
Unlisted situations
Situations not expressly listed in this section 4 are not exempt from compliance.
Any fact that may represent a violation of this Policy — in particular any Recipient engaging in active or passive corruption — must be immediately reported to the Governance Director or via the Whistleblower Channel.
5. Books and Records
akquinet Brasil requires that all accounting records and documents be kept complete and up to date, faithfully reflecting every transaction and asset movement. Records must be properly supported by evidence documentation, in compliance with applicable norms, laws and regulations, including those established by this Policy.
6. Whistleblower Channel
akquinet Brasil provides a Whistleblower Channel to report, exclusively, violations of this Code and the company's other policies. The channel is anonymous and identification is optional. Reports are handled with discretion, respecting the privacy of those involved.
Whistleblower Channel Link
https://app.mub.one/public/9b3c127a-b9c7-47e7-a1d5-d61c0e1f54b3/start7. Disclosure and Validity of this Policy
This Policy remains in force until it is reviewed and a new edition is published. A new review must occur at least every 12 months. Distribution may be physical or digital, upon acknowledgment of receipt, and a copy is always available on the company's Intranet for consultation.