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green4T Integrity and Compliance Program
The green4T Integrity and Compliance Program was created to promote a culture of integrity and ethical conduct in business operations, ensuring that all employees act in accordance with the Brazilian Anti-Corruption Law (Law No. 12,846/13), the U.S. Foreign Corrupt Practices Act (FCPA), and any applicable laws or regulations on the subject in the countries where the company operates.
The green4T Board of Directors establishes that our company must act with integrity, operate within the law, conduct its activities based on ethical values and principles, uphold honesty, and prevent the occurrence of irregularities in its business.
This program is led by an independent Compliance and Internal Audit Department, operating in support of the Code of Ethical Conduct, the Anti-Corruption Policy and other organizational policies. It assesses risks and controls, identifies improper actions, and conducts communication and training initiatives to ensure that all employees and third-party intermediaries understand and follow its guidelines. The program is overseen by an Ethics and Integrity Committee, which meets quarterly and is composed of four members.
Accordingly, we conduct timely compliance training, perform audits and monitoring to ensure adherence to the Code of Ethical Conduct and the Anti-Corruption Policy, and recommend corrective or disciplinary actions to the Ethics and Integrity Committee when non-compliance or improper conduct by employees or third parties acting on behalf of green4T is identified.
Code of Ethical Conduct
The Code of Ethical Conduct represents our commitment to the quality of our products and services. Quality must be understood in its fullest sense, encompassing not only what we do, but how we do it.
It is the duty of all members of the company (executives, employees and interns, across all green4T units, subsidiaries and controlled companies in Brazil and abroad) to comply with and enforce the provisions of this Code. Leaders are additionally responsible for promoting and ensuring its adherence within their respective areas of responsibility.
Anti-corruption policy
green4T is committed to conducting its business in a lawful, ethical, transparent and professional manner.
This policy establishes the guidelines, standards and procedures of the anti-corruption program, enabling green4T to act in compliance with the Brazilian Anti-Corruption Law (Law No. 12,846/2013, regulated by Federal Decree No. 8,420/2015), the U.S. Foreign Corrupt Practices Act (FCPA), and any applicable laws or regulations on the subject in the countries where the company operates.
Transparency
green4T currently maintains active contracts with public administration at the federal, state and municipal levels, in addition to contracts with private sector companies.
These contracts are available on the transparency portals of the respective public bodies and entities, reinforcing our commitment to ethics, integrity and transparency in the public sector, and ensuring strict compliance with all legal requirements, particularly the Brazilian Anti-Corruption Law (Law No. 12,846/13), as well as applicable regulations and obligations established by government authorities.
Empresa limpa
riscos de ocorrência de suborno na companhia.
green4T is a member of Instituto Ethos, sharing the mission of managing its business in a socially responsible manner, and is a signatory of the Integrity and Anti-Corruption Pact under the “Empresa Limpa” seal. Through this commitment, we undertake to promote awareness of the Brazilian Anti-Corruption Law (Law No. 12,846/13) among employees, stakeholders and society as a whole, and to ensure its full compliance in favor of legality and transparency.
Pro-Ethics Company 2021
In 2021, we were awarded the Pro-Ethics Company 2021 seal by Brazil’s Ministry of Transparency, Oversight and the Office of the Comptroller General of the Union (CGU). This recognition highlighted the efforts of 67 companies—out of 327 applicants and 195 evaluated by a committee—that are committed to ethics, business integrity, and the implementation of measures aimed at preventing, detecting and remediating acts of corruption and fraud.
ISO 37001 Anti-Bribery Certification
green4T is certified under the ISO 37001:2017 Anti-Bribery standard, which recognizes organizations that support the fight against illicit practices through a culture of integrity, transparency and compliance with applicable laws and regulations. The benefits of this certification include: minimizing the risk of bribery; demonstrating the implementation of an integrity program; increasing stakeholder confidence in the organization’s business; and creating a competitive advantage by showcasing best practices in ethics and risk mitigation related to bribery.
