1.1. The objectives of this Policy are:

 

a) Regulate and inform internal and institutional communication processes;

b) Ensure coherence, effectiveness and agility in CAMARB's communication process; and

c) Define responsibilities regarding CAMARB communication.

 

 

2.1. The target audience of this Policy is:

 

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”).

 

 

3.1. CAMARB General Communication Guidelines: CAMARB communication must follow the following general guidelines: 

 

a) Preserve and strengthen CAMARB’s reputation and credibility;

b) Ensure that the information disclosed to external and internal audiences is transparent, assertive and coherent;

c) Respect the secrecy, confidentiality and privacy of information protected by applicable legislation or regulations;

d) Align with ethical and integrity principles, reflecting CAMARB’s institutional values;

e) Adopt clear, objective and inclusive language, adapted to the target audience and the means of communication used;

f) Promote accessibility, ensuring that information is available in formats that meet the needs of different audiences;

g) Avoid demonstrations that may compromise the impartiality and neutrality of CAMARB; and

h) Prioritize official channels for the dissemination of information and maintain a continuous and organized flow of communication with interested parties.

 

3.2. Internal Communication: 

 

3.2.1. Objective: Internal communication aims to:

 

a) Keep the target audience of this Policy informed about CAMARB's initiatives and activities, in a timely and transparent manner, respecting the conditions of secrecy and confidentiality provided for by law;

b) Promote values and encourage behaviors aligned with CAMARB's organizational culture; and

c) Engage Employees, Arbitration, Mediation, Dispute Board Professionals and Third Parties in CAMARB initiatives. 

 

3.2.2. Communication channels. 

 

a) Corporate email: Must be used for formal communications, announcements and instructions of interest to CAMARB;

b) Intranet: Tool that should be used to share policies, procedures, manuals, forms, awareness campaigns and other institutional documents and information; 

c) Internal meetings: They should be held for strategic, operational alignments or feedback; and

d) Collaborative tools: Platforms such as Teams or WhatsApp for agile day-to-day communication.

 

3.2.3. Confidentiality and Information Security

 

a) Confidentiality and Secrecy: Everyone must maintain confidentiality and secrecy regarding strategic issues and arbitration, mediation and dispute board procedures administered by CAMARB or that may impact CAMARB's reputation;

b) Security: Everyone must follow CAMARB's guidelines on information security, adopting the use of secure passwords and other security measures proposed by the IT professionals who advise CAMARB; and

c) Handling sensitive information: It is everyone's duty to ensure that internal documents and communications are not shared with people outside the authorized public.

 

3.2.4. Specific guidelines for internal communication:

 

a) Formal communications, announcements and important instructions must be previously approved by the Chairman of the Executive Board;

b) Must establish clear deadlines for responding to internal demands and sending information;

c) All messages must be written concisely, highlighting the most important points; and

d) It must be carried out through CAMARB’s official internal channels.

 

3.3. Institutional Communication: 

 

3.3.1. Objective. The objective of institutional communication is to:

 

a) Strengthen CAMARB’s image and credibility before its external audiences;

b) Disclose information about CAMARB’s services and initiatives in a transparent and accessible manner;

c) Establish a positive relationship with stakeholders, including companies, lawyers, arbitrators, public bodies and society in general; and

d) Promote the culture of extrajudicial means of conflict prevention and resolution and encourage dialogue on the topic at national and international levels.

 

3.3.2. Institutional communication channels

 

a) Institutional website: Main channel for disseminating public information, including events, publications and services;

b) Social networks: Tools for disseminating educational content, news and engagement campaigns;

c) Newsletters and Reports: Regular communication with stakeholders to inform about CAMARB's news, events and achievements; and

d) Events, competitions and seminars: Moments of direct interaction with the public to promote the culture of arbitration and publicize initiatives.

 

3.3.3. Guidelines for institutional communication

 

a) All institutional content must be aligned with CAMARB’s strategic guidelines;

b) Institutional publications and communications must be reviewed by the Institutional Vice President and approved by the President of the Board of Directors to ensure their quality and consistency;

c) The language must be clear, objective and consistent with CAMARB’s values; and

d) Institutional communication must seek an educational and informative tone, promoting arbitration as an effective method of conflict resolution.

 

3.3.4. Definition of Spokespersons: 

 

a) Only spokespersons designated by CAMARB are authorized to speak on behalf of the institution;

b) The following are CAMARB spokespersons, in this order of priority: (i) President of the Board; (ii) Institutional Vice-President and (iii) Administrative Vice-President;

c) To meet specific demands, the President of the Board may designate an “ad hoc” Spokesperson to speak on behalf of CAMARB.

 

3.3.5. Communication with the press: 

 

a) All interaction with the press must be conducted exclusively by the President of the Board, in accordance with the item Definition of Spokespersons, ensuring that the information disclosed is accurate and aligned with CAMARB's strategic objectives;

b) All requests from the press and/or other third-party media, as well as invitations to events involving official representation of CAMARB, must be forwarded to the Institutional Vice-President for analysis and notification by the President of the Board.

 

 

4.1. Disciplinary measures:  

 

a) They will 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; 

b) May include: (i) verbal or written warning, (ii) removal or suspension, (iii) application of a fine, (iv) compensation for damages; (v) termination of contracts of those involved in serious cases of illegality or non-compliance with CAMARB's internal rules and (vi) adoption of applicable legal and contractual measures;  

c) Any violations may also result in reports to the competent administrative and/or police authorities, depending on the severity and legal requirement.

 

 

5.1. Questions and Complaints: 

 

Once doubts, queries, reports, suggestions, opinions, complaints, reports have been received, on issues involving this Policy, it will be up to you, in accordance with the CAMARB Bylaws and the CAMARB Code of Ethics and Conduct: 

 

a) To the Superintendent, carry out the initial registration, preliminary analysis and bring it to the attention of the President of the Board;

b) To the President of the Board of Directors, adopt urgent measures, of a precautionary and/or immediate nature, if necessary, and inform the Ethics and Integrity Committee;

c) To the CAMARB Ethics and Integrity Committee: (i) receive, analyze and report on complaints, queries, reports, suggestions, opinions, disciplinary proceedings, investigations and complaints received through the different CAMARB communication channels on issues related to Ethics, Integrity and ESG so that they can be deliberated by the Deliberative Council; (ii) guide, recommend and advise the Deliberative Council so that it deliberates on complaints, queries, reports, suggestions, complaints, opinions, disciplinary proceedings and investigations received by CAMARB, in accordance with Art. 17, sole paragraph, of the CAMARB Bylaws.

d) To the CAMARB Deliberative Council, to deliberate in the last instance.

 

5.2. Reporting Channel. Whenever necessary, interested parties may report or report issues through CAMARB's Reporting Channel:

 

a) Email: ouvidoria@camarb.com.br

b) Telephone: 31 3308-9437

c) Website: www.camarb.com.br 

 

5.3. Control of approvals and reviews.