1.1. Main objectives. Establish criteria, guidelines, and procedures for:

 

a) Granting and obtaining institutional support and sponsorships;

b) Making or receiving donations to public and private entities; and

c) Offering or receiving invitations to participate in events, gifts, giveaways and hospitality.

 

1.2. Other objectives: 

 

a) Structure, make transparent and guide CAMARB's decisions when considering requests related to the topics covered by this Policy;

b) Maintain the integrity of its internal principles and policies; and 

c) Detail the guidelines and procedures, as well as reinforce the ethical standards present in the Bylaws, in the CAMARB Code of Ethics and Conduct and in Administrative Resolution No. 27/23, which implemented the ESG (Environmental, Social and Governance) Policy at CAMARB.

 

 

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. General criteria. The Activities covered by this Policy must meet the following criteria:

 

 

a) They must be aligned with CAMARB's institutional objectives and in compliance with legislation, Articles of Association, Codes of Conduct and other CAMARB Policies; 

b) They must be carried out with the aim of promoting and strengthening the CAMARB brand and strengthening communication with its users, suppliers, similar entities and society;

c) They cannot compromise the autonomy, neutrality or impartiality of CAMARB;

d) They cannot, under any circumstances, be perceived, interpreted or characterized as bribery, payment, compensation or an undue attempt to exert influence or obtain undue advantage;

e) There must be no content or promotion of illegal, obscene, pejorative, offensive, discriminatory, religious, partisan, or human rights-based themes or that, in any way, harm the values, reputation and image of CAMARB or may lead to negative media;

f) It must be carried out by or for suitable people and entities.

 

3.1.1. When necessary, at the request of the Chairman of the Board, the suitability assessment may be carried out through integrity due diligence.

 

3.2. General Prohibitions. CAMARB's participation in the Activities covered by this Policy will be prohibited when they involve: 

 

a) Organizations and individuals that have a history of involvement in acts of corruption, fraud, commission of crimes or other risk factors;

b) Payments in kind to bidders or third parties;

c) Political parties, candidates for public office or political campaigns;

d) Situations that may have a political-partisan or personal nature; and

e) Religious institutions or sects.  

 

3.3. General Procedures. CAMARB's participation or involvement in these Activities must comply with the following procedures: 

 

a) Detailed proposal: proposals must contain the relevant and necessary information so that CAMARB can assess whether or not it is appropriate to participate in the aforementioned Activities; 

 

b) Disbursement: When applicable, financial resources will be transferred only after (i) approval of the proposal and applicable documentation and (ii) signature of the respective contract; and 

 

c) Accountability: Whenever deemed necessary to prove the correct allocation of resources, CAMARB must request the presentation of: (i) photographs, videos and posts of the Activities (when applicable); (ii) a copy of the product resulting from the Activity (if any); (iii) copies of promotional materials; and (iv) other documents that prove the performance of the Activities, in accordance with the approved conditions.

 

3.4. Activities involving the Public Administration. CAMARB will only carry out Activities involving the participation of public agencies when:

 

a) There is an official act, as the case may be, such as a procedure for expressing interest, public call, invitation, in writing, in an official document of the body, containing, at least: objective of the project, value, activities developed, work plan, deadlines, schedules, responsible person and location; and

b) The Activity is carried out in accordance with the relevant public law rules applicable to each case.

 

 

4.1. Specific Criteria for Institutional Support and Sponsorship (“Projects”)

 

4.1.1. Theme: The Project should address arbitration, mediation, dispute board and/or other extrajudicial forms of conflict prevention and resolution.

 

4.1.2. Gender Equity: the Project must have at least 1/3 (one third) female participation in the scientific program with a speaking role.

 

4.1.3. Priority agendas: 

 

a) Valorization of extrajudicial means and dissemination of extrajudicial solutions for conflict prevention and resolution: projects that stimulate and encourage arbitration, mediation, dispute board and other extrajudicial forms, and strengthen their ethical principles;

 

b) Diversity: Projects that value and encourage diversity of gender, race, age, regional origin, sexual orientation and the inclusion of people with disabilities (PWD);

 

c) Market: Projects that address topics relevant to the business market and converge with CAMARB's area of activity, such as agribusiness, business contracts, administrative contracts, corporate operations, mining law, energy, infrastructure, company recovery and restructuring, etc.;

 

d) Sustainability: Projects that commit to promoting environmental awareness, efficient resource management and the reduction of greenhouse gas emissions in their execution, through the implementation of sustainable and less aggressive measures to the environment.

 

4.1.4. Compensation for Institutional Support. When requesting Institutional Support for courses, a place and/or discount may be offered to CAMARB collaborators as compensation, which will be considered for granting support. Furthermore, the partner must display the CAMARB logo in the Project's promotional material. 

 

4.1.5. Brand Use: The Project must use the CAMARB logo, under the terms indicated in the CAMARB Brand Usage Manual.

 

4.2. Specific Criteria for Donations

 

CAMARB does not make donations and is prohibited from:

 

a) Make or receive donations to or from (i) political parties, candidates for public office or political campaigns; (ii) public agents; or (iii) that may be characterized as political-partisan or personalistic in nature or that violate current legislation;

b) Make or receive donations to or from educational institutions, health institutions and non-profit organizations that have any direct or indirect connection with political candidates, political parties or any political associations;

c) Make or receive donations to or from professionals and parties involved, directly or indirectly, in arbitration, mediation or dispute board procedures conducted by the Chamber.

 

4.3. Specific criteria for participation in Events

 

4.3.1. If CAMARB is granted courtesy registrations or invitations to participate in events, the appointment of the CAMARB representative at the event will follow the following order of preference:

 

a) Chairman of the Board;

b) Vice-President appointed by the President of the Board of Directors;

c) Secretary-General.

 

4.3.2. Payment of expenses necessary for the participation of the CAMARB representative designated for the event is authorized, subject to the financial limits and criteria practiced by CAMARB. 

 

4.3.3. The granting of additional courtesies for mere participation in an event does not include the payment of expenses related to the participation of Board members in the respective event, with the recipient being responsible for bearing the remaining costs to guarantee their participation.

 

4.4. Specific Criteria for Gifts and Giveaways

 

4.4.1. Criteria: A gift or prize may be offered or received by/to an Employee, provided that the following conditions are met: 

 

a) Be an item or advantage with no commercial value or with a market value of up to R$100 (one hundred reais);

b) Be part of the marketing strategy of CAMARB or the Third Party, distributed as a courtesy, advertising or regular publicity;

c) It is offered broadly and generally to everyone with an institutional relationship, and is therefore not intended exclusively for a specific person or sector.

 

4.4.2. The offering or receipt of gifts and presents should not be done with the intent to obtain undue advantage. Any gift or present should only be offered or accepted if it is appropriate, reasonable for promotional purposes, consistent with local practice, and in accordance with the law. If there is any doubt about the appropriateness and wisdom of any gift or present, the individual should consult the Institutional Vice President and/or the Ethics and Integrity Committee.

 

4.5. Specific Criteria for Hospitality 

 

4.5.1. Criteria: Hospitality may be granted or accepted, provided that:

 

a) Are directly related to the institutional interests and legitimate purposes of CAMARB, in appropriate circumstances of professional interaction;

b) There is no risk of being characterized as bribery, payment, compensation or undue attempt to exert influence or obtain an advantage;

c) Do not pose a risk to the integrity and image of CAMARB;

d) Hospitality items have a value compatible with: (i) the standards adopted by CAMARB in similar activities; and/or (ii) with the hospitality offered to other participants under the same conditions; 

e) do not constitute personal benefit.

 

 

5.1. Activity proposals received or sent by CAMARB will be evaluated by the Institutional Vice-President and submitted to the President of the Board for approval.

 

 

6.1. 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.

 

 

7.1. 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.

 

7.2. Whenever necessary, the interested party may report or report through the CAMARB Reporting Channel:

 

a) Email: ouvidoria@camarb.com.br

b) Telephone: 31 3308-9437

c) Website: www.camarb.com.br 

 

7.3. Approval and review control