Compliance and Conduct Policy
1. Introduction
This Geonoma Compliance and Conduct Policy aims to establish the expected behaviors of the Geonoma community. This document reflects Geonoma’s public commitment to the highest standards of honesty and integrity, as well as adherence to anti-corruption, anti-bribery, and other fraud prevention regulations in all its operations and relationships.
2. Scope
The rules and principles set forth in this Policy apply to Geonoma, including its presidents, board members, directors, committee members, and employees, regardless of position or function, as well as service providers, suppliers, clients, business partners, consortium members, and anyone who maintains commercial relations or acts on its behalf.
3. Our Commitment
Geonoma is committed daily to ethical and integral business practices in compliance with the law, wherever it operates worldwide. Furthermore, Geonoma is guided by respect for people, striving to promote a healthy and collaborative environment. To this end, we support the principle of open dialogue and cooperation with society, clients, shareholders, and employees.
The Geonoma community declares its commitment to:
- Compliance with anti-corruption and anti-bribery laws, decrees, and regulations, including but not limited to:
- Law No. 12,846/13 (Anti-Corruption Law);
- Decree No. 8,420/15;
- Law No. 12,683/12 (Anti-Money Laundering Law);
- Law No. 12,529/11 (Competition Defense Law); and
- Law No. 8,666/93 (Public Procurement Law).
- Zero tolerance for corrupt, fraudulent, coercive, extortive, collusive, and obstructive practices, whether active or passive, at the national and transnational levels;
- Ensuring that board members, partners, administrators, employees, and business partners comply with applicable legislation, as well as policies and processes, ensuring that the highest standards of integrity, legality, ethics, and transparency are upheld during their activities and those performed by third parties on their behalf;
- Providing human and material resources for the full and effective functioning of Geonoma’s Compliance Program;
- Ensuring that no administrator, business partner, or employee is penalized through retaliation, discrimination, or disciplinary action for reporting, in good faith, any violation or suspected violation of this policy or for refusing to participate in violations, even if such refusal results in business loss for the organization;
- Encouraging individuals to report, in good faith, any indications of misconduct, improper requests, or conflicts of interest involving administrators, employees, public agents, or business partners through the appropriate communication channels, without fear of retaliation;
- Raising awareness about the disciplinary consequences of offering, promising, receiving, facilitating, paying, authorizing, or enabling bribes, kickbacks, corruption, and money laundering;
- Conducting confidential investigations and maintaining records of any reported suspicions or violations, ensuring disciplinary action and equal treatment for all employees;
- Maintaining a continuous and updated awareness and training process on policies and procedures, proportionate to the ongoing risk management process;
- Implementing, maintaining, and continuously improving a management system capable of preventing, detecting, and responding to compliance and integrity objectives;
- Respecting all individuals, regardless of hierarchical position, origin, ethnicity, culture, age, social level, physical ability, religion, or sexual orientation, and rejecting any form of discrimination;
- Promoting a relaxed work environment that encourages interpersonal relationships among employees, avoiding authoritarianism and undue hierarchical pressure aimed at function division;
- Creating an open environment where all employees feel comfortable sharing ideas and suggesting improvements to work procedures;
- Ensuring, under applicable law, the right to individual political expression, provided it occurs outside the workplace and working hours and without involving Geonoma’s name or resources;
- Ensuring freedom of expression within the limits permitted by Brazilian law, always based on respect.
4. Conduct Guidelines
Although it is not feasible to address all possible situations, this document establishes behavioral guidelines for some of the most common compliance-related scenarios. In case of doubt, employees or third parties should contact the Communication Channel for advice.
4.1. Meetings with Public Officials
To ensure transparency in its relationships, Geonoma mandates that all institutional or commercial meetings with public officials must be linked to the professional’s schedule and formally recorded in minutes for compliance review and control.
4.2. Gifts, Presents, and Hospitality
Any gift, present, or hospitality must have a legitimate business purpose and must not be perceived as a bribe, payment, influence, or undue advantage.
Authorized actions include:
- Gifts/Presents: Employees may offer and receive, as long as not prohibited by law, institutional/promotional gifts and presents. Gifts refer to symbolic institutional items such as agendas, pens, notebooks, and similar items. Gifts and presents must be limited to R$ 300.00 (three hundred reais) and up to twice a year. Employees may not receive cash gifts, even below R$ 300.00, including bank transfers, checks, or gift cards.
- Hospitality during project execution: Travel, accommodation, meals, and other forms of transportation must be limited to those stipulated in the service contract.
- Meal expenses during institutional representation activities: Meal expense limits must follow Geonoma’s Field Expense Policy, with accountability and traceability linked to institutional and commercial agendas.
4.3. Sponsorships and Donations
Donations and sponsorships by Geonoma, if and when they occur, must be requested in writing, be transparent, and controlled, and only be made to reputable legal entities, institutions, and duly regulated organizations. Donations must undergo compliance verification and due diligence before approval by the Board.
Donations must never be made with the intent to influence decisions or coincide with bidding opportunities and/or service contracts with Geonoma.
4.4. Corruption and Acts Against Public Administration
Geonoma strictly prohibits:
- Offering, promising, or giving undue advantage to a public agent or a related third party to expedite administrative actions or obtain licenses, permits, or approvals;
- Fraud in public procurement processes;
- Obtaining undue advantages in contract modifications or extensions without legal authorization.
4.6. Anti-Corruption Clause
All legal contracts entered into by Geonoma must include an Anti-Corruption Clause, and it is the responsibility of the contracting department to ensure its inclusion and compliance.
4.7. Confidentiality
Employees and third parties must maintain confidentiality regarding all Confidential Information obtained through their relationship with Geonoma. Such information must not be transmitted, copied, or used for personal or unauthorized purposes.
4.8. Public Communication
Except for Directors, no one is authorized to communicate on behalf of Geonoma with the media or the public. All information requests must be directed to the Presidency.
4.9. Data Protection
Geonoma adheres to Law No. 13,709/2018 (Brazilian Data Protection Law) and implements best practices in personal data protection, including prior consent when legally required and secure data storage.
4.10. Conflict of Interest
Any situation that may constitute a conflict of interest must be reported to Geonoma’s Presidency.
6. Violations of the Compliance and Conduct Policy
Violations must be reported immediately to the Communication Channel and will be rigorously addressed. Any violations by third parties will be considered a contractual breach subject to termination.
7. Communication Channel
Geonoma provides a direct communication channel for employees, third parties, partners, and suppliers to report any conduct violating this Policy.
Reports can be submitted via:
- Website: https://geonoma.eco/compliance
- Email: compliance@geonoma.eco