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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.
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.
  • 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.

The Talanoa Institute is committed to working towards the development of climate and socio-environmental solutions with integrity. This means having zero tolerance for bribery and corruption, prohibiting them in all their forms.

 

  • Bribery: employees and managers must not, directly or indirectly, give, promise, offer or authorize a payment or anything of value to any government official or to any person in order to obtain an undue advantage.

 

  • Facilitation payments: employees and administrators must not make facilitation payments (any extra payment to receive the service faster).

 

  • Gifts: It is forbidden to give gifts of any kind, whether objects, gifts of money, or equivalents such as gift cards, to a government official or any other person.

 

  • Political Contributions: employees and administrators must not make a political donation or contribution, directly or indirectly, on behalf of the Talanoa Institute. This includes donations or contributions to political parties, political candidates or electoral campaigns. It is forbidden to grant paid or unpaid leave to employees who want to support a political party, a political candidate, or run for office. This rule is subject to the application of local labor laws and collective bargaining terms and agreements.

 

  • Rules relating to third parties: employees and directors must not ask a third party to do anything that the Institute is prohibited from doing. You must not give anything of value, directly or indirectly, to a third party in the knowledge that all or part of the payment will be offered, given or promised to a government official - or anyone else - with the intention of corrupting them.
  • Social and Environmental Investments: Instituto Talanoa may receive social and environmental investments through donations, sponsorships and/or contributions. However, these investments may not be made or offered to government officials or any other person in order to obtain an undue advantage and must be made in accordance with this Policy, and respecting all the limits, rules and approvals and prohibitions established in the regulatory documents.

  • Meals and Entertainment: May be permitted if pre-approved by Corporate Integrity, within the limits and rules described in this Policy.

  • Per diems for Government Officials: may be allowed in extremely limited cases, where local law permits and with prior approval from Corporate Integrity.

  • Emergency requests: the Institute recognizes that certain external events may require the hiring of suppliers on an emergency basis. Even in cases of emergency, the rules of this Policy and the specific emergency procedures that will be issued on a case-by-case basis must be observed, always respecting the necessary approvals.

  • Meetings with Government Officials: Before holding a meeting with any government official, collaborators and administrators must make sure that they are authorized to represent Instituto Talanoa. It is recommended that more than one employee and/or administrator attend a meeting with a government official and that the details of the meeting be documented.

  • Due Diligence: an appropriate Anti-Corruption Due Diligence must be carried out in relation to third parties and/or in all transactions involving acquisitions of new investments/financing to identify possible red flags. Some third parties or opportunities may be subject to an additional level of anti-corruption due diligence. The level, extent and how it should be requested will be determined by Corporate Integrity, based on the area's regulatory documents.

  • Warning signs: employees and managers must always be on the lookout for warning signs (anything that signals the need for a check, such as rumors or news about the third party's misconduct) throughout the course of the relationship and must report any warning signs they become aware of to Corporate Integrity.

  • Records: the board of directors must keep books, records and accounts that clearly and transparently reflect the company's transactions.

  • Reporting: the Institute must have a system of internal controls that provides reasonable comfort that all transactions are carried out with due authorization, documentation, accuracy and transparency.

  • Cooperation: employees and managers must fully cooperate with the organization's investigations into problems or conduct related to anti-corruption policies and rules and maintain the confidentiality of the information being investigated.

  • Training: the Institute will conduct periodic anti-corruption training for managers, employees and, where appropriate, third parties. Everyone must attend the anti-corruption training indicated by Corporate Integrity or the Management area. Failure to attend such training may lead to disciplinary measures, which may even include termination of the employee's employment contract or the third party's contract.
  • It is the responsibility of all directors, employees and third parties to follow this Policy.

  • The Institute's Board of Directors is primarily responsible for managing the implementation, monitoring and enforcement of this policy and the anti-corruption rules.

  • The Institute's financial management must adopt the highest standards of integrity, fairness, legality, transparency and accountability.

  • Corporate Integrity must be independent and have the tools to investigate and bring suspicious situations or possible violations of the rules of this Policy to the Institute's General Assembly.

  • Corporate Integrity is responsible for determining the guidelines for carrying out Anti-Corruption Due Diligence and other requested analyses, as well as for establishing guidelines and providing the necessary training for compliance with this Policy.

  • Corporate Integrity should be consulted if in doubt about the rules set out in this Policy.

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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