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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 and to encourage all employees to 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 in the countries where the company operates.
green4T’s Board of Directors requires the company to operate with integrity and within the law, conduct its activities according to ethical values and principles, uphold honesty, and prevent misconduct in its business operations.
The program is managed by an independent Compliance and Internal Audit Department, which works to uphold the Code of Ethical Conduct, the Anti-Corruption Policy, and the organization’s other policies. It assesses risks and controls, identifies misconduct, and carries out communication and training initiatives to ensure that employees and third-party intermediaries understand and follow these guidelines. The program is overseen by a four-member Ethics and Integrity Committee that meets quarterly.
We also provide compliance training as required, conduct audits and monitoring activities, and recommend corrective or disciplinary action to the Ethics and Integrity Committee when violations or misconduct involving employees or third parties acting on behalf of green4T are 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 has active contracts with federal, state, and municipal government entities, as well as 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
green4T is a member of Instituto Ethos and shares its mission of conducting business in a socially responsible manner. The company is also a signatory to the Integrity and Anti-Corruption Pact under the “Empresa Limpa” seal. Through this commitment, we pledge to raise awareness of the Brazilian Anti-Corruption Law (Law No. 12,846/13) among employees, stakeholders, and society at large and to comply fully with the law in support of legal compliance and transparency.
Pro-Ethics Company 2021
In 2021, green4T received the Pro-Ethics Company 2021 recognition from Brazil’s Ministry of Transparency, Oversight and Comptroller General of the Union (CGU). The recognition highlighted 67 companies—out of 327 applicants and 195 evaluated by a committee—for their commitment to ethics and business integrity and for implementing measures to prevent, detect, and remediate corruption and fraud.
ISO 37001 Anti-Bribery Certification
green4T is certified to ISO 37001:2017, the Anti-Bribery Management Systems standard, which recognizes companies and organizations committed to preventing unlawful practices through a culture of integrity, transparency, and compliance with applicable laws and regulations.
The benefits of this certification include reducing the risk of bribery, demonstrating the implementation of an integrity program, strengthening stakeholder confidence in the organization’s business practices, and providing a competitive advantage by demonstrating best practices in ethics and bribery risk management.
