Anti-Corruption and Fraud Policy
Last updated: August 1, 2021.
1. Purpose
1.1. The purpose of the Anti-Corruption Policy is to reinforce SELETOBANK's commitment to ethics and integrity in the development of its business, establishing guidelines aimed at preventing and combating corruption, bribery and fraud practices.
2. Scope
2.1. All partners, administrators, employees of any hierarchical level, service providers, suppliers and business partners.
3. Definitions
3.1. For the purposes of this Policy, the terms are understood as follows:
(a) Public Administration: comprises the set of bodies, services and entities of the direct or indirect public administration, and their respective agents, in the Federal, State, Municipal scope, in the Legislative, Judiciary and Executive powers.
(b) Public Agent: any person who performs a public function, even if temporarily or without remuneration, by election, appointment, appointment, hiring or any other form of investiture or bond, mandate, position, job or function. Anyone who works in a contracted or contracted service provider company for the execution of typical activity of the Public Administration is equivalent to the public agent.
(c) Foreign Public Agent: any person who, even if temporarily, with or without remuneration, performs a public function in bodies, state entities or diplomatic representations of a foreign country, as well as in legal entities controlled by the public power of another country or organizations foreign public.
(d) Harmful Act: any act or omission that causes direct or indirect damage to the public interest and/or property to the detriment of the interest of third parties and that contravenes the principles of Public Administration.
(e) Conflict of Interest: occurs when personal interests can influence decision-making or conduct, to the detriment of SELETOBANK's interests.
(f) Undue Advantage: consists of any benefit, economic or otherwise.
(g) Corruption: is the act or effect of corrupting oneself, offering something to a public or private subject, with the aim of obtaining an undue advantage for oneself or for others.
(h) Bribery or Bribe: act of promising, offering or paying a public or private person a value in money or other advantage, is the means through which corruption is practiced.
(i) Fraud: any deceitful, deceitful act, in bad faith, with the intention of harming or deceiving others, or failing to fulfill a certain duty.
4. Guidelines
SELETOBANK does not tolerate or condone any practices of corruption, bribery or fraud, whether with the Public or Private Administration, national or foreign.
4.1. Anti-Corruption Law: SELETOBANK does not tolerate or condone any practice of harmful acts to the Public or Private Administration, national or foreign, as provided for in Law no. 12,846/2013 (“Anti-Corruption Law”).
4.2. Contact with Public Authorities: contacts between administrators, employees or third parties who act representing SELETOBANK with public agents, must occur in accordance with the internal rules that regulate the relationship with the Public Administration.
4.3. Political Contribution, Donations and Sponsorships: SELETOBANK does not contribute, directly or indirectly, whether through donations, sponsorships, loans, or any other means, with political campaigns, political parties, candidates, public offices, or any organization that develops political activity. It is recommended that administrators, as an individual, refrain from making personal donations to political parties and electoral campaigns.
4.4. Relationship with Suppliers, Partners and Third Parties: all SELETOBANK suppliers, partners and service providers, in the development of business on behalf of or on behalf of SELETOBANK, must be guided by ethics and integrity. The hiring of suppliers, partners and third parties acting on behalf of SELETOBANK must be preceded by an analysis of their qualification and reputation, which determines the existence of any of the warning signs. If so, the facts found must be communicated to the Compliance Team, which will submit the decision to the administrators to continue or interrupt the contracting process, or even replace the supplier, third party or partner.
4.5. Gifts, Gifts and Hospitalities: partners, administrators, employees, service providers, suppliers and business partners are prohibited from accepting or offering gifts, gifts or hospitality to agents of the Public or Private Administration, national or international, with the aim of influencing decision-making or to obtain benefit for themselves or for the company.
4.6. Conflict of Interests: partners, administrators, employees of any hierarchical level, service providers, suppliers and business partners, in the exercise of their activities, routines and relationships in a professional scope, must always be guided by the best interests of the institution's objectives, therefore, avoiding that personal interests may influence decision-making or conduct, which may cause a conflict of interest.
4.7. Corporate restructuring: during the corporate restructuring process in which SELETOBANK participates, such as mergers, acquisitions and incorporations, due diligence must be carried out in the company, in order to ensure, among other aspects, compliance with the Anti-Corruption Law. The contracts and documents that are linked to the corporate restructuring must contain a specific anti-corruption clause and any situation identified during the corporate restructuring process that violates this commitment must be immediately communicated for analysis and risk prevention.
4.8. Combating Money Laundering: SELETOBANK is committed to transparency and preservation of legality in financial transactions, thus, any evidence or suspicion of money laundering identified by its partners, administrators, employees, service providers, suppliers and partners business, must be immediately communicated to the Compliance Area so that the necessary measures can be taken.
4.9. Disclosure: This Policy, as well as its updates, is made known to all partners, administrators, employees of any hierarchical level, service providers, suppliers and business partners, and they must also sign a term of adhesion to this Policy. The Policy will also be available on the SELETOBANK website.
4.10. Promotion of improvements in internal processes: SELETOBANK is committed to continuously monitoring internal procedures related to Combating Corruption and Fraud, in order to identify possible opportunities for improvement.
5. Internal Investigations
5.1. Internal investigations must be carried out permanently in order to verify compliance by all partners, administrators, employees and service providers with the rules established in the organization.
5.2. If the internal investigation identifies any alleged irregularity, the matter must be brought to the attention of the Compliance Area so that the necessary measures can be taken, including reporting to the competent authorities or application of internal sanctions such as: written warning, suspension, dismissal, termination of the contract with a supplier, partner or third party.
6. Reporting Suspicious Situations
Everyone must report to their leaders or directly to the Compliance Area, suspected situations of fraud, bribery, corruption or that deserve special attention, ensuring the confidentiality of the information provided.
6.1. Warning Signs and Reporting Duty.
Partners, directors, leaders, employees, interns or service providers should be aware of warning signs that may indicate that corrupt practices are in progress. Some examples of warning signs are:
(a) Counterparty has a bad reputation in relation to receiving or offering a bribe;
(b) The Counterparty's commission or remuneration is incompatible with the services provided, compared to the history of similar operations;
(c) Identification of payments made in cash or through the use of bearer checks, or through the indirect benefits identified as Undue Advantage in this policy;
(d) Counterparty is controlled by a Public Agent or their first-degree relatives or has a close relationship with the government;
(e) Counterparty was appointed by a Public Agent;
(f) Counterparty proposes an unusual financial scheme, such as requesting payment to a bank account in a country other than the country in which the service is being provided or requesting payment to more than one bank account;
(g) Donation to a non-profit institution at the request of a Public Agent;
(h) A Third Party hired to represent SELETOBANK before the Public Administration requested a Facilitation Payment or advance in kind for expenses not clearly specified;
(i) In the operational process, funds are transferred to accounts other than those informed by customers;
(j) Manual changes to grantee data;
(k) Accessing websites or executing suspicious files;
(l) Everyone has the duty to immediately report to the Compliance Area any of the above mentioned warning signs or even others that they observe in their daily activities.
(m) Warning signs are not necessarily evidence of Corruption, nor do they automatically disqualify Counterparties, Employees or other Representatives of SELETOBANK. However, they raise suspicions that must be investigated, ensuring the protection of the ethical standards adopted by SELETOBANK, preventing acts of corruption and preserving its image in the market.
7. Responsibility
7.1. It is the responsibility of all partners, administrators, employees, service providers, suppliers and partners to comply with this Anti-Corruption Policy.
7.2. Adhesion to SELETOBANK employees is mandatory and will be carried out by signing the commitment term with the Anti-Corruption Policy.
8. Communication Channel
8.1. Any situations with indications of being in disagreement with this Policy must be immediately registered and informed to the Compliance Area, through the electronic address: antifraude@seletobank.com.br .