Compliance and Anti-Corruption Efforts in Brazil

In face of challenges of advocacy and the world scenario as a whole, and in line with their Values and Beliefs, Promare started implementing the Promare Compliance Program.

Their Compliance Program is focused on creating a set of internal integrity mechanisms and procedures in the fight against corruption, encouraging, through preventive and ostensive measures, the adoption of conduct in accordance with the ethical laws applicable to advocacy as well as to the field of performance of their customers.

Thus, their Program is one of the six main pillars:

  1. Identifying and encouraging compliance with laws and regulations, including anti-corruption legislation and policies;
  2. The creation of an internal control mechanism for the implementation, execution and monitoring of the program;
  3. Encouraging its direct and third-party employees to comply with the Promare Code of Ethics and Conduct and anti-corruption laws and regulations;
  4. Preventive action to prevent fraud and illicit;
  5. The establishment of disciplinary measures and remediation of possible damages in case of violation to the standards related to Compliance Promare
  6. The adoption of transparency regarding donation to candidates and political parties.

Their team, aware that the corporate conduct is materialised through the actions of each of its employees, identified three main norms that regulate its activity: the Law Statute, the Penal Code and the Anti-Corruption Law.

Compliance with the rules, besides avoiding the application of penalties, brings other fundamental benefits. The main thing is maintaining a working working environment. Another benefit is the good reputation in the market and the good acceptance of the public opinion, since the Brazilian society does not tolerate more companies with the name related to corruptive practices, valuing even more those that maintains its reputation unblemished.

The Promare Compliance Department is an independent communication channel for members of the office as well as anyone who is aware of the practice of unethical acts by any member of staff. The compliance departments governed by an anti-recrimination policy, according to which no one will be harmed by making a complaint in good faith.

The communication channel receives reports with the indicated authorship or even anonymous ones, always guaranteeing the confidentiality with respect to the data of the one that uses the Compliance department.