1.1. Main objectives: Ensure that CAMARB's actions are guided by:

 

a) in the ethics and integrity of all actions, ensuring impartial and lawful conflict resolution procedures; 

b) in the best interests of the association, in the general principles of Arbitration, Mediation, Dispute Board and other forms of prevention and extrajudicial resolution of disputes; and

c) in making strategic and management decisions in a manner free from the influence of personal, commercial or other interests, whether of individuals, organizations or groups.

 

1.2. Other objectives: 

 

a) Establish rules of relationship with the target audience; 

b) Support in identifying situations of potential Conflict of Interest by related parties; 

c) Handle all situations of Conflict of Interest through a structured procedure; and

d) Segregate the treatment of situations that, according to CAMARB's Bylaws, are related to Administrative Competencies (more focused on the administration and management of CAMARB), from Procedural Competencies (more focused on procedures held by the Chamber that are regulated by its own Policy).

 

 

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. Characterization of Conflict of Interest. 

 

3.1.1. Situation in which an individual has a personal, professional or commercial interest in a certain action, procedure or decision of CAMARB, which may compromise its independence and impartiality; 

 

3.1.2. The Conflict of Interest exists regardless of the effective influence of secondary interests on a given decision or the occurrence of losses; 

 

3.1.3. The Conflict of Interest may involve CAMARB's financial resources or not directly involve financial resources;   

 

3.1.4. The existence of a Conflict of Interest is presumed in transactions with people or entities linked to CAMARB, as well as in transactions with parties related to them.

 

3.2. Transactions with People or Entities Linked to CAMARB.

 

3.2.1. The hiring or appointment of a person or entity linked to CAMARB to provide goods or services, including to give classes or lectures, even on a pro bono basis, requires prior approval from the Executive Board and must be reported to the Ethics and Integrity Committee, with the Deliberative Council acting as a review body, if necessary.

 

3.2.2. It is prohibited to hire members of the Deliberative Council, Vice-President, President and Director to provide services and/or supply goods to CAMARB, either by themselves (including through legal entities of which they are partners) or through an intermediary.

 

3.3. Duty to inform.

 

3.3.1. Any individual who identifies a matter or situation in which he or she has an interest that conflicts with the interests of CAMARB must immediately report such conflict to the Institutional Vice-President and/or the Ethics and Integrity Committee. 

 

3.3.2. If the individual does not disclose their potential Conflict of Interest, any other member of CAMARB who becomes aware of the fact must do so. 

 

3.3.3. Failure to disclose a situation of Conflict of Interest must be reported by the person who became aware of it to the Institutional Vice-President and/or the Ethics and Integrity Committee. 

 

3.4. Duty to abstain.

 

3.4.1. The conflicted individual must refrain from acting, deliberating on the matter in question or, in any way, influencing the decision. 

 

3.4.2. If you do not abstain voluntarily, you may be asked to do so by the respective body, department or sector of CAMARB, for example, by the Deliberative Council, Board of Directors or at management levels.

 

3.5. Recording of situations involving Conflict of Interest and transactions with Related Parties.

 

3.5.1. Any actual or potential conflicts identified that are reported must be recorded by the Superintendent or in the minutes of the Deliberative Council meeting, and brought to the attention of the CAMARB Ethics and Integrity Committee, clearly describing, at least, as the case may be: 

 

a) the name of the conflicting individuals; 

b) the classification of the secondary interests identified that characterized the Conflict of Interest; 

c) whether the initiative to identify the Conflict of Interest came from the individual himself or from another member of the body; and

d) the record of the individual's abstention within the registered votes. 

 

3.6. Questions, Complaints and Decisions. 

 

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.

 

 

4.1 Preventive measures: 

 

a) Situations of conflict of interest must be immediately reported, as soon as they are identified, by the individual directly involved or by any person who is aware of them;

b) An individual in a situation of actual conflict must be removed from participating in the deliberation or influencing the decision. An individual in a situation of potential conflict may be removed, as decided by the Executive Board, the CAMARB Ethics and Integrity Committee, or the Deliberative Council.

 

4.2 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. Reports: Whenever necessary, the interested party may make reports or complaints through the CAMARB Reporting Channel.

 

a) Email: Ouviria@camarb.com.br

b) Telephone: 31 3308-9437

c) Website: www.camarb.org.br 

 

5.2. Approval and review control