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Integrity and Anti-Corruption Compliance Program

This is an English translation provided for reference. In case of any discrepancy, the original Portuguese version prevails.

1. Introduction and Scope

Foco na Solução Ltda establishes this Integrity Program as the central pillar of its corporate governance. This program applies to all partners, employees and interns and, where applicable, to its business partners and suppliers. Our goal is to ensure that all of the consultancy's activities are carried out honestly and in strict compliance with Law No. 12,846/2013 (the Brazilian Anti-Corruption Law) and Decree No. 11,129/2022.

2. Commitment of Senior Management

The leadership of Foco na Solução publicly declares its commitment to a culture of integrity. We firmly reject any practice of active or passive corruption, bid rigging or obtaining undue advantages. Our leaders act consistently with these principles, setting an example and actively encouraging upright conduct in all business.

3. Third-Party Monitoring (Due Diligence)

To mitigate risks, Foco na Solução constantly monitors its partners and suppliers through due diligence processes. We assess the ethical reputation of CRM software, payment hubs and service providers before any integration or hiring. We do not maintain business relationships with entities that have a proven history of harmful practices or lack of transparency.

4. Management of Sponsorships and Donations

Sponsorships or donations by Foco na Solução are governed by technical and ethical criteria:

  • Donations to political candidates or parties are prohibited.
  • Event sponsorships must have a clear institutional purpose and be formalized by contract.
  • No donation may be used as a means to conceal the payment of undue advantages to public or private agents.

5. Management and Audit System

We use the Vhsys and Asaas systems to ensure that 100% of the financial flow is auditable. This digitalization allows invoices to be checked, payments to be traced and financial fraud and money laundering to be prevented.

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