1.1. General information: CAMARB is a non-profit association, established in 1998, which administers extrajudicial arbitration, dispute board and business mediation procedures.

 

1.2. CAMARB Mission, Vision and Values:

 

a) Mission: To offer and promote solutions for the prevention and extrajudicial resolution of business disputes in an efficient and safe manner;

b) Vision: To be a benchmark in quality, agility and innovation in the administration of extrajudicial solutions to business disputes.

c) Values: Ethics, innovation, governance, people and quality.

 

1.3. Purpose of this Code: To consolidate and disseminate the principles, policies, internal standards and good practices that will guide the conduct of CAMARB Employees and other parties that interact with it.

 

1.4. Who is it for: 

 

a) Employees, interns, coordinators, managers, superintendents, secretaries, procedure assistants, service providers, directors, vice-presidents, president, administrators, board members and members of other administrative structures of CAMARB and/or who, in some way, develop activities in favor of CAMARB (“Collaborators”);

b) Third parties, including volunteers, who carry out activities related to the topics covered by this Policy or maintain an institutional, professional or contractual relationship with CAMARB (“Third Parties”).

 

1.4.1. Employees and Third Parties, for all purposes, are considered Recipients of this Code of Ethics and Conduct (“Recipients”).

 

1.4.2. For all purposes, this Code of Ethics does not apply to Arbitrators, Mediators and members of Dispute Boards, Experts and other participants in procedures conducted by CAMARB, whose activities are governed by a specific Code of Ethics and Conduct, available on the website of CAMARB – Chamber of Business Mediation and Arbitration – Brazil.

 

 

 

 

2.1. Guiding Principles. The actions of all those who interact with CAMARB must be guided by the fundamental principles of honesty, integrity, morality, responsibility, independence, impartiality, impartiality, competence, and efficiency.

 

2.2. Compliance. It is everyone's duty to respect and comply with applicable legislation, this Code of Ethics and Conduct (“Code”), as well as CAMARB's Rules, Administrative Resolutions and Policies, as well as the Guiding Principles (for all purposes, “CAMARB Rules”).

 

2.3. Combating Corruption, Fraud, and Illicit Payments. CAMARB does not tolerate any type of bribery or corruption, whether public or private. Likewise, it does not tolerate any type of fraud.

 

2.4. Money Laundering Prevention. CAMARB does not participate in and does not tolerate any involvement with money laundering, terrorist financing, slave labor, and/or human trafficking. Recipients must strictly comply with the legislation on Money Laundering and Terrorist Financing Prevention (AML/FT).

 

2.5. Conflict of Interest. Conflicts of interest occur when an individual has a private, personal, professional, or commercial interest that may conflict with CAMARB's interests. These conflicts can compromise the individual's independence and impartiality of analysis or even harm CAMARB.

 

2.5.1. Any situation that may result in conflicts of interest (or that may be interpreted as such) must be reported and dealt with promptly, as provided for in CAMARB's Conflict of Interest Policy. 

 

2.6. Sponsorship, Institutional Support, Donations, Gifts, Giveaways, and Hospitality. Recipients must ensure that the acceptance or offer of any benefit does not involve illegal, improper, or unethical conduct, or conduct that may generate a conflict of interest.

 

2.6.1. All Employees must follow the procedures, authority levels and requirements set out in the Sponsorship, Institutional Support, Donations, Gifts, Giveaways and Hospitality Policy before offering or accepting these activities.

 

2.7. CAMARB's Image and Reputation. All those who interact with CAMARB must safeguard its reputation and credibility, maintaining ethical and professional conduct in any environment, including social media and public appearances. 

 

2.8. Communication and Positioning. All public statements, including interviews, articles, social media posts, and other forms of external communication related to CAMARB, must be aligned with the guidelines established in the Communication Policy. Recipients should exercise caution in personal communications and positions to avoid causing negative impacts on CAMARB.

 

2.9. Confidentiality and Information Security. CAMARB adopts strict measures to ensure the protection and confidentiality of information in its custody. All Employees and Third Parties must:

 

a) Maintain confidentiality regarding all information obtained as a result of their work at CAMARB, unless expressly authorized by the parties involved or required by law or court order;

b) Use only secure and authorized means for storing and transmitting information, preventing unauthorized access;

c) Follow good market practices, CAMARB information security protocols and good IT practices to prevent data leaks or compromise.

 

2.10. Intellectual Property. The works, studies, and design pieces developed by CAMARB employees in the performance of their duties are considered CAMARB's intellectual property.

 

2.10.1. Everyone must ensure its protection, ensuring that its use, reproduction or disclosure occurs only with the express authorization of CAMARB.

 

2.10.2. Unauthorized sharing of protected knowledge, documents or materials may give rise to legal liability and remedial measures.

 

2.11. Respect in the Workplace. CAMARB condemns any behavior that violates human rights, manifests violence, prejudice, harassment, or discrimination, both in interactions between coworkers and in relation to third parties.

 

2.11.1. In all work environments, including virtual environments and social networks, the following conduct is considered unacceptable:

 

a) Use of offensive or prejudiced language;

b) Acts of physical violence, shouting, intimidation or threats of any nature;

c) Harassment, comment or action that aims to humiliate, coerce, embarrass, belittle, isolate, disrespect, subjugate or repeatedly offend the dignity, image, physical or psychological integrity of another person, regardless of their hierarchical position;

d) Dissemination of rumors, hearsay or malicious comments, as well as disrespect for individual limitations due to physical or mental conditions;

e) Harassment of a sexual nature, non-consensual or unwanted approach;

f) Use of derogatory nicknames or offensive conduct against any person;

g) Making inappropriate requests or offers of personal favors or benefits, internally or externally, that are not aligned with CAMARB’s activities and values.

2.12. Diversity and Inclusion. CAMARB respects and values diversity. Employees and Third Parties are strictly prohibited from engaging in any form of discrimination, regardless of factors such as sex, ethnicity, religion, marital status, age, gender identity, sexual orientation, disability, political opinions, or cultural values.

 

2.13. Asset Protection. All Employees and Third Parties are committed to respecting and protecting CAMARB's assets, whether tangible, such as equipment, facilities, and documents, or intangible, such as strategic information, institutional reputation, and intellectual property. 

 

2.13.1. The use of these assets must be appropriate and restricted to institutional purposes, and any form of misappropriation, damage, loss or unauthorized use is prohibited.

 

2.14. Protection of Personal Data. Everyone must ensure the protection of personal data under their responsibility and observe the provisions of applicable legislation, CAMARB guidelines and policies on personal data protection.

 

2.15. Environmental, Social, and Governance Practices. CAMARB encourages, values, and adopts environmental, social, and governance (ESG) practices in its activities and institutional relationships. All Employees and Third Parties must act ethically and responsibly, contributing to sustainability, inclusion, and integrity in CAMARB's processes and decisions.

 

 

3.1. Available channels: Violations, misconduct or suspected non-compliance with CAMARB Rules must be immediately reported to the following channels: 

 

a) Email: ouvidoria@camarb.com.br

b) Telephone: 31 3308-9437

c) Website: www.camarb.com.br 

 

3.2. Duty to Report and Promptly Interrupt. All CAMARB Employees and Third Parties have a duty to report violations, misconduct, or suspected noncompliance with CAMARB's Rules in order to enable (i) the prompt interruption of any irregularities or infractions, and (ii) the timely adoption of measures to remedy any damages caused.

 

3.3. Accurate information. The communication must be presented in sufficient detail to enable the investigation and confirmation of the facts, citing, whenever possible, all existing evidence, forms of proof, documents, witnesses, as well as dates and individuals involved.

 

3.3.1. Inaccurate, generic, superficial, unproven reports and/or reports that make it impossible to confirm the occurrence of the facts may be decided as unfounded, unsubstantiated and/or archived.

 

3.4. Confidentiality and anonymity. Communications and reports will be kept confidential and will remain anonymous, with anonymity permitted.

 

3.5. Prohibition of retaliation. Any type of retaliation against CAMARB Employees and Third Parties who report violations of the Code is prohibited.

 

 

4.1. Receipt: The complaint, query, suggestion, opinion, report, related to CAMARB Standards will be initially received by the Superintendent and brought to the attention of the President of the Board and the Ethics and Integrity Committee.

 

4.2. Responsibilities of the Chairman of the Board: The Chairman of the Board shall be responsible for adopting urgent, precautionary and/or immediate measures, if necessary, and informing the Ethics and Integrity Committee.

 

4.3. Responsibilities of the Ethics and Integrity Committee: The Ethics and Integrity Committee is responsible, by a simple majority of its members:

 

a) decide summarily on the manifest lack of minimum requirements for continuation, ineptitude, lack of just cause, inadmissibility of investigations, disciplinary proceedings or inquiries;

b) guide and suggest actions to the Executive Board, in the case of precautionary, urgent, executive and/or legal representation measures;

c) receive, analyze and report on complaints, queries, reports, suggestions, opinions, inquiries, disciplinary proceedings and complaints received through CAMARB's different communication channels on issues related to Ethics, Integrity, ESG and CAMARB Standards, so that they can be deliberated by the Deliberative Council; 

d) guide, recommend and advise the Deliberative Council so that it deliberates on complaints, queries, reports, suggestions, claims, opinions, disciplinary proceedings and inquiries received by CAMARB. 

 

4.4. Powers of the Deliberative Council: It is up to the Deliberative Council to decide, in the final instance, on complaints, queries, reports, suggestions, claims, opinions, investigations and disciplinary proceedings, received through the different CAMARB communication channels on matters related to CAMARB's Rules.

 

4.5. Investigation Procedure: once received and admitted by the Ethics and Integrity Committee, the complaint, claim or report about a fact that, in theory, may characterize a violation of CAMARB's Rules will begin the investigation procedure consisting of gathering information, conducting interviews, hearing the accused, technical expertise and/or analysis of documents internally by CAMARB or professionals designated by it.

 

4.6. The Investigation Procedure will be coordinated by one of the members of the Ethics and Integrity Committee (“Investigation Coordinator”) who will be responsible for preparing an investigation plan and may count on the support of specially designated CAMARB Employees or third parties hired by CAMARB.

 

4.6.1. The Investigation Coordinator may request support and resources from the Executive Board in order to promote the investigation of the facts and the preparation of a report in the form of a technical and/or legal opinion that will be submitted to the Ethics and Integrity Committee and then to the Deliberative Council.

 

4.6.2. The Investigation must be carried out impartially, with the aim of determining whether, in fact, there was a violation of CAMARB Rules.

 

4.6.3. Depending on the nature of the reported facts, the Investigation Coordinator may: 

 

a) Propose the application of preventive and/or provisional measures, provided they are necessary to ensure the smooth running of the investigation, protect the accused, as well as to protect the image and reputation of CAMARB;

b) Request the complainant (if identified), the accused and witnesses to attend an interview in order to provide clarification on the facts that are the subject of the complaint; and

c) Request information, technical expertise and/or documents from CAMARB.

 

4.7. Deadline for investigation. The investigation must be carried out over a period of up to 60 (sixty) days, with extension permitted by decision of the Ethics and Integrity Committee. 

 

4.8. Conclusion of the Investigation. Upon completion of the Investigation, the Coordinator will present a report analyzing the factual issues, evidence, potential violations of CAMARB Standards, and any applicable disciplinary measures, along with supporting documents, for deliberation by the Ethics and Integrity Committee. Once approved, the report will be submitted for deliberation by the Deliberative Council. 

 

4.9. Communication. After making a decision, the Deliberative Council must communicate it in writing to the President of the Board.

 

 

5.1. Disciplinary measures: Applicable to Employees and/or Third Parties, they depend on the severity of the situation and/or conduct, as well as the consequences that were or may be faced by CAMARB and/or the person, and may be:

 

a) Low severity: (i) verbal warning, (ii) written warning; 

b) Medium severity: (iii) removal or suspension; 

c) High severity: (iv) application of fine, (v) compensation for damages, (vi) termination of contract.

 

5.2. Any violations of CAMARB's Rules may result in the application of other applicable legal measures, contractual measures, reports to the competent administrative and/or police authorities, depending on the severity and legal requirement.

 

 

6.1. Questions, suggestions and complaints: Situations involving questions, suggestions, communications or complaints must be reported or submitted to the Vice President of Institutional Relations.

 

6.2. Where can the Code be found: The Code is available for consultation on the CAMARB website.

 

6.3. Revisions and Updates: The Code is subject to periodic review. The review must be proposed by the Ethics and Integrity Committee and approved by the Board of Directors, taking into account the suggestions, comments, and experiences of CAMARB employees, the evolution of legislation, and the most recognized practices.

 

6.4. Interpretation: It is the responsibility of the Ethics and Integrity Committee, in collaboration with the Deliberative Council, to clarify any doubts regarding the interpretation of this Code.