4.2. RELATIONSHIP WITH PUBLIC OFFICIALS
Relationships with Public Officials must be guided by ethics and transparency. Edgefy Administrators and Employees shall maintain contact with Public Officials only when necessary, and within the facilities of the public agencies to which they belong and/or within Edgefy's facilities in the performance of their duties—in the latter case, whenever possible, in the presence of two or more Edgefy professionals. This rule must also be observed by Third-Party Intermediaries.
It is strictly prohibited to bribe, promise, offer, or give, directly or indirectly, any Undue Advantage to domestic or foreign Public Officials or to Related Persons.
The prohibition set forth in this policy applies both to conduct committed directly by Edgefy or through any Third-Party Intermediary, whether an individual or a legal entity.
The express prohibition contained in this policy also applies to payments aimed at accelerating or expediting routine acts by Public Officials (e.g., issuing licenses, permits, or authorizations; conducting inspections or visits), known as "facilitation," "acceleration," or "urgency" payments or fees.
Such payments are expressly prohibited by this anti-corruption policy and cannot be made under any circumstances, whether directly or through any Third-Party Intermediaries.
Payments of additional fees to accelerate routine processes will only be permitted if expressly and officially provided for by law, paid directly to the public agency (via appropriate collection forms) and never to a Public Official or intermediary, and provided they have been previously and formally approved by Edgefy's Executive Management.
4.3. TENDERS AND BIDDING
Edgefy and its Administrators, Employees, and Third-Party Intermediaries must strictly comply with all applicable local laws and regulations regarding contracting with the Public Power. Everyone must act in accordance with the highest ethical standards and within the law when interacting with Public Officials and competitors in the context of a public tender or any other means of public procurement.
It is prohibited to engage, directly or indirectly, in any act that could be construed as defrauding or frustrating tenders, preventing or seeking to prevent competitors from participating in a public bidding process, or committing any act harmful to the Public Administration.
If you have any questions regarding how to interact with Public Officials, government agencies, or competitors in the context of public tenders or government contracts, please contact the Compliance department.
4.4. HOSPITALITY, MEALS, GIFT ITEMS, AND PRESENTS
Edgefy does not permit the payment of hospitality, meals, or entertainment (sightseeing tours, sporting events, concerts, among others) for any Public Official or Third Party with the intent to improperly influence or reward an act or decision as actual or intended compensation for any benefit to themselves or to the company.
Edgefy will permit the payment of expenses related to travel, meals, entertainment, or other business courtesies, provided they are closely related to the company's business, are consistent with local law, and comply with the value limits permitted by the Company.
Only individuals directly involved in the professional matters are permitted to receive meal invitations (invitations to spouses, relatives, and friends of the guest are prohibited).
4.5. RELATIONSHIPS WITH THIRD PARTIES
It is strictly prohibited to bribe, offer, or authorize, directly or indirectly, any offer, promise of payment, or payment in cash or through an Undue Advantage to any employee, agent, or representative of a private company that has (or may come to have) a business relationship with Edgefy, for the purpose of attempting to obtain improper interests or inducing such employee, agent, or representative to make any decision to the benefit of Edgefy.
4.6. RESPONDING TO REQUESTS OR DEMANDS FOR INDUE PAYMENTS
If you receive a request for an extraordinary payment or the delivery of an Undue Advantage from any Public Official, Related Person, or Third Party, explicitly and definitively refuse it, and immediately notify your immediate supervisor and the Plant Manager.
4.7. DONATIONS AND SPONSORSHIPS
Any donation or sponsorship must be made in a fully transparent manner and in compliance with current legislation.
All donations made to political parties and/or candidates for public office must follow the strictest legal and ethical standards, and must necessarily comply with the requirements and limits established by local legislation. No Employee may use Edgefy or private resources to make donations to political parties, election campaigns, or candidates for public office on behalf of the company without prior approval from Executive Management.
Sponsorships must be based on formalized contracts between Edgefy and the institutions receiving the sponsorship.
Edgefy maintains an internal approval process for these sponsorships, and, when necessary, they must be approved by Executive Management.
4.8. CONTRIBUTIONS AND CHARITABLE CAUSES
Edgefy's policy mandates that no contributions, sponsorships, or donations shall be made to charitable causes in exchange for favors with any Public Official, even if the beneficiary is a genuine philanthropic institution.
Contributions made to Institutions where a Public Official or a member of their family holds a public role, or made at the behest of a Public Official, may raise suspicions of corrupt acts.
Donations must be made solely for legitimate philanthropic reasons, such as serving humanitarian, cultural, or educational interests. Making a donation in exchange for a Public Official favoring the company will not be permitted.
The approval of contributions, sponsorships, or donations must respect the current hierarchy of Executive Management and shall observe the following procedure:
1. Requests must be made in writing, specifying, at a minimum, the person or organization requesting the contribution, the purpose of the contribution, and the amount requested;
2. Requests will be carefully analyzed to verify that the contribution will not provide a personal benefit to any Public Official and that the institution is registered under applicable local law;
3. The contribution must be made to the Institution and not to an individual, and under no circumstances will the payment be made in cash or via deposit into a personal checking account;
4. Contributions will be previously approved by Executive Management;
5. It is mandatory to obtain a receipt of acknowledgment for every contribution made to a charitable cause.
4.9. HIRING THIRD-PARTY INTERMEDIARIES
No Third-Party Intermediary may exert improper influence over Public Officials, and they must not be recommended by Public Officials. Edgefy must check whether any of these Third-Party Intermediaries are recognized for practicing corruption or are being investigated, prosecuted, or have been convicted. If so, Edgefy must investigate the facts and make a decision based on the results, taking into account the risk of damage to its reputation.
Before doing business with Edgefy, all Third-Party Intermediaries must undergo an analysis to verify their background, structure, relationship with Public Officials, reputation, and qualifications to perform the work for which they would be hired. The review process may be conducted independently or jointly with the Third-Party Intermediary, who must cooperate and provide all information that Edgefy deems necessary.
The Third-Party Intermediary must certify that they will subject themselves to the Brazilian Anti-Corruption Law (12,846/13), the United States Foreign Corrupt Practices Act (FCPA), and all anti-corruption laws of the country in their operating market.
Any hiring and renewals of existing contracts must be justified in advance. Contracts with Third-Party Intermediaries must contain a description of the services, amounts to be charged, and, among others, clauses to ensure compliance with anti-corruption laws, aiming to mitigate the risk of illicit payments and provide the company with the means to terminate the relationship if violations occur.
4.10. MERGERS, ACQUISITIONS, AND CORPORATE RESTRUCTURINGS
Edgefy takes measures to verify whether the company with which it is involved as a result of mergers, acquisitions, or corporate restructuring processes has been or is implicated in harmful acts against the public administration, and whether it possesses vulnerabilities that pose risks to its integrity.
4.11. ACCOUNTING CONTROLS
It is the responsibility of all Administrators and Employees to ensure the maintenance of accurate and complete records of all Edgefy expenses, transactions, and payments.
It is strictly prohibited to make false or inaccurate entries that conceal the true nature or value of any operation. No unofficial or unrecorded funds or accounts may be created or maintained without a purpose, and no false, misleading, or inaccurate entries may be made in Edgefy's accounting books and records.
4.12. PENALTIES
It is the responsibility of all employees to communicate any violation or suspected violation of the requirements of local anti-corruption laws, in particular Brazilian and US laws, as expressed in this policy.
Communications of violations, whether identified or anonymous, must be directed to Executive Management via the email gabriel.bob@edgefy.com. Measures will be taken to protect the confidentiality and anonymity of any report.
Edgefy will not permit or tolerate any type of retaliation against any person who submits a good-faith report or complaint of a violation of this policy.
Any Employee who engages in retaliation is subject to disciplinary action by the Company, including termination of the employment contract. Violations of this policy may result in severe civil and criminal penalties for Edgefy and for the Employees and/or representatives involved. Individuals and their executives are subject to criminal penalties, as well as fines, in the event of a violation of Law 12,846/13 or the FCPA, which cannot be paid by the company.
In addition to the penalties imposed by legislation, violations of the anti-corruption policy may be punished with the following disciplinary measures, depending on the type and severity of the conduct: Formal warning; Best Practices Training (Compliance); Loss or reduction of variable compensation; Transfer to another function; Suspension; Termination with or without prior notice.
5. REFERENCE DOCUMENTS
N/A.
Separated policy. New sequential numbering
Changed federal decree number in item 1. OBJECTIVE.
Changed corporate name from "Sismetal" to "Edgefy". General policy review.
Removed F.00.09 from item 4.4 regarding the offering of hospitality.
Approved by Certifications
