Anti-corruption policy

Objective

The Talanoa Institute is a Brazilian non-partisan and independent think and do tank, which aims to improve the effectiveness, efficiency and effectiveness of Brazilian public policies. Based in Rio de Janeiro, the Institute is dedicated to analyzing and proposing public policies, mainly in the field of climate change and the environment.

The purpose of this anti-corruption policy is to clarify the Talanoa Institute's precepts, as well as to reflect its values of ethics and transparency in relations between employees, third parties, partners, investors, public agents and society in general.

Application

This Policy applies to Instituto Talanoa, as well as to all the projects that are part of the organization's activities. All employees, administrators, third parties, partners and investors must comply with this Policy. In addition, third parties who represent, act on behalf of or benefit the Talanoa Institute directly or indirectly, must behave in a manner consistent with the anti-corruption rules described in this Policy.

Definitions

Directors: These are members of the Board of Directors, the Strategic Council and the Supervisory Board of the Talanoa Institute.

Something of Value: is more than just money, it includes gifts, meals, entertainment, sponsorships, donations, job vacancies, goods or property, among others.

Full Members: admitted at the General Meeting, these are those who are up to date with their statutory obligations, are in full exercise of their social rights and functions, and can vote at meetings, a right that is exclusive to them.

Knowledge: understanding, comprehending and yet willfully ignoring; ignorance and/or willful blindness.

Corruption: a form of dishonest, unethical or illegal conduct that constitutes an abuse of power or authority, involving the exchange of undue advantages with a government official (public corruption) or with any other person (private corruption) in order to obtain some personal benefit.

Per diems: cash payments (usually calculated on a daily basis) that genuinely estimate the reasonable cost of travel, meals and accommodation that a government official receives to attend a business meeting or event.

Anti-CorruptionDue Diligence: assessment of a third party's risk of corruption by means of publicly available information, which can take place before and/or after contracting.

Employees: any employees, own or outsourced, permanent or temporary, interns and/or trainees.

Suppliers: any supplier of goods and/or services, including consultants, agents, commercial representatives, brokers and intermediaries, among others.

Government official: this is not just someone who is elected, it includes:

a. an official, servant, employee or representative of a government, a state-owned or mixed-capital company, or any person exercising public functions on behalf of the aforementioned entities;

b. a member of an assembly or committee, or an employee involved in the performance of public functions, in accordance with applicable laws and regulations, to assist in the performance of public functions, such as modifying or drafting laws or regulations;

c. an employee of the Legislative, Executive or Judicial branches, regardless of whether they are elected or appointed;

d. official or employee of a government agency or regulatory authority;

e. officer or person holding a position in a political party or a candidate for political office;

f. an individual who holds any other official, ceremonial or other appointed or inherited position with a government or in any of its agencies;

g. an official or employee of a public international organization, such as the United Nations, the World Bank or the International Monetary Fund;

h. a person who is, or poses as, an intermediary acting on behalf of a government official;

i. a person who, although not a public official, is determined by applicable law to be treated in the same way as a public official; and

j. a person who, although temporarily or without remuneration, holds a public office, employment or function.

Corporate Integrity: the area responsible for implementing and monitoring the Institute's anti-corruption rules, formed by the Board of Directors in accordance with its Bylaws.

Socio-environmental investment: all expenditure (costing, investment, research and development) that directly benefits society and is carried out with a social, environmental, cultural and institutional purpose.

Facilitation Payment: any payment to expedite or ensure the execution of routine government actions by a government official. Such as:

a. inspection and release of goods, temporary import authorizations or classification of a product;

b. granting permits, licenses, certifications;

c. providing security and safety services;

d. issuing visas, residence and work permits, medical certifications; or

e. release of taxes or refunds.

Warning Signs: a fact or circumstance that serves as a warning that a third party has acted or may act corruptly. Red flags can arise in a variety of ways, such as from rumors or news about the company or individuals, including Politically Exposed Persons (PEPs), from requests made by the third party that do not appear to be connected to a legitimate purpose, or from other unusual or unexpected conduct.

Bribery: offering, promising, paying, or giving something of value to a government official or any other person, with the intention of giving or achieving an advantage.

Third parties: any individual, company or entity with which the Institute has a professional relationship, including suppliers, business partners and beneficiaries of investments.

Undue Advantage: an advantage or benefit that the company or individual receives as a result of a bribe to a government official or any other person.

General provisions

Violations of this Policy and/or Talanoa Institute's anti-corruption rules will result in the application of appropriate disciplinary measures, which may include dismissal of the employee and/or Directors, and/or termination of contracts with third parties. The disciplinary measure will be imposed based on the seriousness of the violation and the circumstances of the situation.

Violations of anti-corruption and anti-bribery laws may subject the violator and the Institute to civil and/or criminal penalties, including fines and imprisonment.

Violations of the prohibitions of this Anti-Corruption Policy, or of any anti-corruption and anti-bribery law by Third Parties, may result in the termination of the business relationship with that party.

All employees, administrators and third parties must immediately report any suspicion or possible violation of the anti-corruption rules, this Policy or any related document to the Institute's Board of Directors. The report must also be made in cases of direct or indirect approach to participate in an act of bribery, corruption or in which there is suspicion of the existence of an act of corruption and/or bribery.

This Policy must be reviewed periodically, at least once every three (3) years or on demand.

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Anti-corruption policy

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General provisions