|
Search:
linha
Anticorruption Policy
Home / Anticorruption Policy

1 – INTRODUCTION

This anticorruption policy aims to ensure that all MINASLGIAS’ employees and its representatives meet the requirements of the Brazilian Anticorruption Federal Law (No. 12,846, enacted on August 1st, 2013), which stands for the legal responsibility, administrative and civil, of actions against the the public, national or foreign administration, as well as the guidelines of this policy in order to ensure, during the conduct of business, the adoption of the highest standards of integrity, fairness and transparency.

MINASLIGAS is recognized for its honesty, integrity in its administrative practices and business operations. This policy aims to combat and prevent any form of corruption and also works as a prevention tool to guide people to recognize and avoid conflicts and violations of this law.

To solve your doubts about the applicability of this policy or any related matter contact your immediate manager, the Human Resources Department, the Legal Department or Company’s Directors.

This policy is available for consult at MINASLIGAS site: http://www.minasligas.com.br

APPLICABILITY


This policy applies to all employees of MINASLIGAS, owned or outsourced workers, as well as employees of its subsidiary ML Florestal and even service providers, suppliers, business partners and any person acting on behalf of the company.

DEFINITIONS

EMPLOYEES – All MINASLIGAS employees, Directors, Members of the Board, trainees, apprentices and other people working in the company as well as employees of its subsidiary ML Florestal. The term "employees", for the purpose of this policy, also covers employees from contracted companies.

OUTSOURCED EMPLOYEES
- Service providers, suppliers, business partners or any person acting on behalf of MINASLIGAS (e.g. broker)

CORRUPTION - It's the abuse of power or authority, by a person to obtain advantages for himself or others. Bribery is the most common form of corruption.

BRIBERY - Offering, giving, receiving money or anything with value in exchange for favorable treatment by a public employee or official authority.

PUBLIC EMPLOYEE OR EMPLOYEE OF THE GOVERNMENT – Shall be considered all employees or directors of public companies or controlled by the government, in all entities of the executive, legislative or judiciary, or any department and agency from the state or city or anyone officially representing or acting on behalf of the Government. Falls in this category an employee from a company or entity in which a public institution holds a share and / or over which may, directly or indirectly, has a dominant influence.

For the purpose of our policy shall also be considered as a public employee the political party or a member of a political party or a candidate to a politic career.

An extra careful with relatives or people suspected to be relatives of public employees, or relative of public employees controlling companies, in order to avoid such people to serve as channels for illegal payments to public servers.

ADVANTAGE OR IMPROPER PAYMENT - Payment in cash and any transfer of value, tangible or intangible, to influence or reward any official act or decision of a public server.

GOVERNMENTAL ENTITIES - For the purpose of this policy, a government entity refers to commercial companies, institutions, agencies and departments owned or controlled by the government and other public entities (being the participation or control either total or partial).

COMPLIANCE – A set of disciplines to enforce the accomplishment of legal standards, policies and guidelines established for the business and activities of the institution or company as well as aiming to prevent, detect and treat any deviation or non-conformity that might occur.

2 - ANTICORRUPTION RULES AND PROCEDURES

The anti-corruption law prohibits the offer, payment, promise of payment or authorization to payment of any amount of money, gifts or any goods, materials or any value to any public employee (or person related to him), for the purpose of:

჻ Influence any act or decision from a public employee;
჻ Induce him to perform any act in violation of their legal duties;
჻ Ensure undue advantage, or;
჻ Induce him to use his influence on a government agency to help you achieve, maintain, or directing business to any person.

1) BRIBERY

Employees or people acting on behalf of MINASLIGAS are prohibited from offering, promising, make, authorize or provide (directly or indirectly through third parties) any undue advantage, payments, gifts, or transfer any goods, material or any value for any public employee (including their families) in order to influence or reward any official act or decision of such person for the benefit of the company.

It won’t be tolerated that any person approves the payment of any bribes, provide or accept false invoices, blind the payment of bribes or knowingly cooperate in any way for the payment of bribes.

2) GIFTS, ENTERTAINMENT AND TRAVEL

It’s not allowed to offer gifts, entertainment or travel to public employees to influence or compensate in an improper way an official act or decision for any company benefit.

It is accepted to give small value gifts, if they don’t have a corrupt purpose, such as pens, mugs, shirts, key chains, calendars etc. containing the name and / or company logo.

Inappropriate gifts can cause negative consequences for the company, so the gifts can not be given for favoritism or retribution.

It is expressly forbidden to give money to anyone for any purpose. If any money is offered to any employee or third part, it should be refused.

In case of a travel of a public employee, the reason must be previously defined and approved. The refund is subject to the presentation of documents evidencing the expenditures and this documents shall be archived. It is also prohibited to provide money to organize travels.

3) POLITICAL CONTRIBUTIONS

Contributions or donations to political parties, political campaigns, political and / or candidates for a public career, may only be made in accordance with applicable law, noting the requirements and limits set by the TSE (Superior Electoral Court) and all requirements for public disclosure must be fully observed. These contributions are subject to the approval of MINASLIGAS’ Board of Directors.

4) CHARITABLE CONTRIBUTIONS

MINASLIGAS policy states that contributions should not be made in exchange for favors to any public employee, even if the favored one is a genuine charity institution.

Bribes can take the form of charitable contributions or sponsorships. So make sure that the money paid to a charity institution is not an exchange of a specific treatment for the company by a public employee.

Here are some rules and procedure to be observed when contributing to charitable causes:

• Applications must be made in writing and must be specified the organization, the purpose of it and the amount requested;

• The contribution will only be made to the charity institution constituted as required by the law and, under no circumstances, can be given to individuals.

• These benefits will be analyzed by the Department of Human Resources, with the support from the Legal Department. It will be checked if the contribution will provide personal benefit to a public employee;

• All contributions must be approved by the President Director;

• MINASLIGAS must obtain the receipt of any contribution made to a charitable cause.

3 - CORRUPTION BETWEEN PRIVATE ORGANIZATIONS

Although the Anticorruption Law aims only acts involving public employees, MINASLIGAS will not accept any act of corruption involving private companies or anyone. The company cares for honesty and integrity in all actions taken on your behalf in administrative practices and in their business operations.

4 - COMPLAINT POLICY AND WARNING SIGNALS

To ensure compliance with anticorruption laws, employees and third parties should be aware of warning signs that may indicate improper payments or benefits. Warning signs are not necessarily evidence of corruption, but acts that raise suspicions and, therefore, shall be investigated, ensuring no problem was detected.

Thus, for any warning sign or evidence of corruption, the employee or third party must immediately inform his superior, Human Resources Department, the Legal Department or Company’s Directors, or even use the whistleblowing channel.

This policy does not cover all the corruption possibilities, therefore employees and third parties are encouraged to use common sense and if in doubt, ask support from the Department of Human Resources, Legal Department or Company’s Directors.

Regardless of the complaints being identified or anonymous, the Company will take measures, according to the law, to protect the confidentiality of any complaint made.

5 - VIOLATIONS AND PENALTIES

It is the responsibility of all employees and third parties to report any violation or suspected violation according to this Policy.

Reports of violations and suspected violation may be made, identified or anonymous, to the immediate supervisor or directly to Human Resources Department, Legal Department, Company’s Directors, or even using the whistleblowing channel.

The Company will not permit or tolerate any form of retaliation against any person, making in good faith a complaint of violation of this policy or the Anticorruption Laws. Any employee or third party who engages in retaliation will be subject to Company’s disciplinary actions or even with the termination of its employment.

Violations of this policy may result in severe civil and criminal penalties for the Company and for the employees and third parties involved.

Fines imposed on individuals for violation of this Policy may not, under any circumstances, be paid by the Company, and people involved are also subject to penalties according to the law.

GENERAL ISSUES
჻ The compliance of this policy is mandatory. Therefore, it is important that everyone knows that contrary conduct may lead to the application of disciplinary measures, including termination of employment or contracts in place, and subject to the penalties according to the law.

WHISTLEBLOWING CHANNEL
Link to Whistleblowing Channel

chlamydia treatment cost std testing for free where can i get free std testing
spy mobile android android phone spy free spy apps for android phone
i told my boyfriend i cheated on him click i dreamt my boyfriend cheated on me
k9 sex stories read written adult stories with animals and humans having sex
12 weeks pregnant abortion click how to end a pregnancy
adult stories anal link lesbian sex stories
scraping of the uterus procedure site 24 hour abortion hotline
track text track calls and text messages track sms free
i dreamed my wife cheated on me solveit.openjive.com women cheat husband
renova skoc.net temovate tube
discount coupons for medications discount card pharmacy viagra coupon card
kamagra 100mg mtibytes.com celebrex 200mg
celecoxib 100mg mealmixer.com clomid pill
betamethasone 0.12% open azithromycin 500mg
fluconazole relotrans.com doxycycline 100mg
prescription discounts cards mikemaloney.net cialis discount coupons online
vibramycin 100mg zithromax pill viagra 120mg
can i take antabuse and naltrexone can i take antabuse and naltrexone can i take antabuse and naltrexone
lisinopril and marijuana interaction link lisinopril and marijuana interaction
cialis dosing for bph link cialis dosage for bodybuilding athletes
levitra diabetes diabetes type 2
viagra rezeptfrei kaufen viagra online bestellen viagra online billig
discount cialis prescription lipseysguns.com 10mg cialis price
cialis.com coupon eblogin.com prescription drugs discount cards
prescription drug cards is-aber.net cialis online coupon
kamagra jelly click kamagra ára
sildenafil citrate 200 mg blog.cardsapp.com sildenafil citrate 100mg lowest price
omeprazole omeprazol hinta omeprazol ratiopharm
ataraxis ronnebybloggen.se atarax for dogs
neurontin tablets williamgonzalez.me neurontin alcohol
printable discount coupons drumlishparish.ie abortion pill stories
cialis free coupon unbosqueparaelplanetatierra.com new prescription coupons
coupons for cialis free printable cialis coupons prescription transfer coupon
prescription drug coupons prescription coupon card prescription coupons
duloxetine ptsd duloxetine alcohol interaction duloxetine pharmacokinetics
thyrax duotab thyrax euthyrox thyrax kopen
how much is an abortion in ny history of abortion cost of abortion
where can i get an abortion pill fedbeton.be buy abortion pill online
nootropil myjustliving.com nootropil review
reasons for abortion pill free abortion pill abortion pill rights
when can you get an abortion pill abortion pill procedures abortion pill prices
cialis walgreen coupon searchengineoptimization-seo.net cialis discount
lamisil pastillas by-expression.com lamisil spray
rosuvastatin dose equivalent atorvastatin rosuvastatin dose rosuvastatin tablets 20 mg
discount prescription cards prescription drug discount coupons discount prescription card
amoxicillin 1000 mg agama-rc.com amoxicillin
cialis cialis 100 mg cialis 5 mg
vermox alkohol vermox vermox sirup
information on abortion pill abortion pill pictures pill abortion
prescription coupon cialis free sample coupons free cialis coupon
alternatives to abortion pill average cost of abortion how does abortion pill work
coupon codes free coupons sites free coupons websites
third trimester abortion pill for abortion pill medical abortion pill
metoprolol metoprololsuccinat orion 50 mg metoprololsuccinat orion 50 mg
cialis.com coupons cicg-iccg.com discount coupons for cialis
amoxicillin-rnp americanstreethockey.com amoxicilline
voltaren nedir crownlimos.ca voltaren retard
duphaston i ovulacija duphaston cijena bez recepta duphaston tablete za odgodu menstruacije
cialis 100 mg cialis cialis tablet
coupon for prescriptions prescriptions coupons lilly coupons for cialis
against abortion pill medication abortion pill how much is an abortion pill
neurontin gabapentin lasertech.com neurontin alkohol
rx pharmacy coupon free pharmacy discount card free prescription drug card
ldn capsules read naltroxon
how long does it take for naltrexone to work link medication naltrexone
naltrexone 4.5 mg low dose naltrexone for opiate withdrawal does naltrexone cause weight loss
generic naltrexone vivitrol for alcohol dependence ldn therapy
naltrexone for alcohol charamin.jp is naltrexone an opiate
nalprexon read naltrexone for lupus
how long does naltrexone take to work go naltrexone over the counter
voltar
topo
linha
Copyright MINASLIGAS - 2015 - Todos os direitos reservados.
Rua Paraíba, 1.122, 4º andar - Funcionários - BH - MG - Brasil - CEP: 30130-918
Contato: (31) 3261-8666 / Fax: (31) 3261-8789