Anti-Corruption Policy
1. OBJECTIVE:
The Bertolini Group structured an Integrity Program and adopted internal regulations with
the objective of communicating the values, commitments and institutional guidelines that guide its
business practices and operational routines, in order to prevent, monitor and combat risks of
corruption, legal non-compliance and inappropriate conduct.
In this context, the Bertolini Group recognizes the importance of ethical and
transparent with public authorities, suppliers, service providers, business partners
and customers, to prevent and combat corruption and other illegal practices, as well as
for the promotion of its legitimate interests and the development of a business environment
fair. Additionally, Brazilian anti-corruption legislation provides for liability for
legal entities for acts of corruption (in the administrative and civil spheres), and their
representatives and administrators can be held individually responsible, and there are also
criminal sanctions applicable to public agents and individuals involved.
This Anti-Corruption Policy (�Policy�) is part of the Integrity Program of
Bertolini Group and was established with the purpose of guiding its members in order to guarantee
that the Group's interactions with representatives of public authorities and also with agents
private, are conducted in an ethical, transparent manner, in accordance with legislation
applicable and in alignment with the principles of your Integrity Program.
The guidelines established here are complementary to the provisions of the Code of Ethics
and Conduct of the Bertolini Group.
2. SCOPE:
This Policy is adopted by all entities and operational units that make up
the Bertolini Group, including Bertolini S.A., its controlled and subsidiaries, in Brazil and in
exterior.
The guidelines set out here must be observed by all its members
(shareholders, members of the Board of Partners, members of the Board of Directors,
administrators, employees, interns, apprentices) and third parties who, in an authorized manner and in
reason for carrying out their duties, act on behalf of the Bertolini Group.
This Policy will be communicated to all suppliers, service providers and partners
commercial (including sales representatives, franchises, distributors, consultants,
advisors and other business partners) of the Bertolini Group (�suppliers�),
regardless of the existence of a formal contract signed between the parties, and its provisions govern the relations between them, themselves, their partners, administrators, collaborators and/or
outsourced, with the Bertolini Group.
3. APPLICABLE STANDARDS:
Penal Code Criminal liability
Law No. 8,429/1992 Administrative Improbity
Law No. 9,613/1998 Prevention of money laundering
Law No. 12,813/2013 Conflict of Interest
Law No. 12,846/2013 Anti-Corruption
Decree No. 11,129/2022 Anti-Corruption
Anti-corruption legislation in force in the countries where the Group
Bertolini operates
Anti-corruption
Anti-corruption legislation in force in the states and municipalities in
that the Bertolini Group operates
Anti-corruption
Law No. 14,133/2021 Tenders
Bertolini Group Code of Ethics and Conduct Internal policy
Gifts, Gifts and Hospitality Policy of the Bertolini Group Internal policy
Bertolini Group Supplier Relationship Policy Internal policy
4. ACRONYMS AND DEFINITIONS:
Public administration. Public Administration is made up of bodies and entities
members of the direct administration (bodies that make up the structure of the Executive Powers,
Legislative and Judiciary), indirect (authorities, foundations, public companies,
mixed economy and other entities controlled by the State) and foundational, of any of the
powers of the Union, the States, the Federal District and the Municipalities (art. 2, Law n� 9,784/1999).
Public Agent. A public agent is a political agent, a public servant and any other
who exercises, even if temporarily or without remuneration, by election, appointment,
appointment, hiring or any other form of investiture or bond, mandate, position,
employment or function in direct and indirect public administration entities, within the scope of
Union, States, Municipalities and the Federal District (art. 2, Law No. 8,429/1992).
Acts harmful to public administration. According to Brazilian anti-corruption legislation,
constitute acts harmful to public administration, national or foreign, those carried out by
legal entities that attack national or foreign public assets, against
principles of public administration or against international commitments assumed by the
Brazil, defined as follows: (I) promising, offering or giving, directly or indirectly, undue advantage
the public agent, or the third person related to him/her; (II) demonstrably, finance,
finance, sponsor or in any way subsidize the practice of illegal acts provided for by law;
(III) demonstrably, use intermediary by