Anti-corruption policy

Anti-corruption policy

1. What is anticorruption?

2. Mokuhyou Shinbun Japan's Anti-Corruption Policies - 目標 新聞.

3. For who and how?

4. What are acts of corruption?

The. Okay, but who are the public officials?

B. And what can I and can not do?

5. What can happen?

6. What if I find out?

1. What is anticorruption?

It is important to conceptualize corruption first. In a broad sense, corruption can be understood as any improbable act that harbors a deviation from institutional objectives by a private individual in relation to a public agent or state entity. In Brazil, corruption is defined as a crime by the Penal Code, according to articles 317 and 333, subjecting individuals who offer and public agents who request, demand or accept an undue advantage to penalties.

In addition, the Administrative Misconduct Law (Law No. 8429/92) lists a series of unlawful acts that violate the principles of administrative morality and that cause unlawful enrichment of the public agent and that may subject the convicted to civil and administrative sanctions.

In 2013, the National Congress approved Federal Law no. 12.846/13, known as the Anti-Corruption Law. The great novelty of the law was the strict imposition of responsibility on legal entities that are involved in acts of corruption, called in the law of harmful acts against the public administration.

The anti-corruption law requires a proactive stance by companies to prevent acts of corruption.

While the Penal Code and the Administrative Misconduct Law have a reactive character, that is, they punish after the acts have taken place (if discovered), the Anti-Corruption Law has a preventive character, requiring companies to have internal systems and policies that prevent the occurrence of these acts.

Thus, anti-corruption can be defined as a set of measures to prevent corruption acts (harmful acts against public administration) that may occur during business activities.

2. The Group's Anti-Corruption Policies 目標 新聞.

The Group目標 新聞 it has always guided its activities by seriousness and honesty and its mission is to disseminate and defend the principles of democracy and free enterprise. Corruption, however, is one of the greatest obstacles to democracy as it channels the public resources necessary for the development of the social plan for individuals in an illicit and unfair way.

That is why the Group 目標 新聞, through its journalistic means of communication, always gave visibility to the corruption scandals and condemned the practice fiercely in its editorials. Doing this in your journalistic activity is not everything. It is extremely important that the Group's business activity 目標 新聞 keep the mission to prevent the occurrence of acts of corruption.

For this reason, the Code of Ethics and Conduct and the Editorial Principles, Ethical and Quality Standards provide express provisions for behaviors to be avoided and adopted, with the aim of preventing harmful acts against the public administration. In addition, the Group 目標 新聞 has a specific procedure for inspection and monitoring of its internal rules, reporting channels and specific procedures for investigation and relationship with third parties.

These rules and procedures form the normative basis of Grupo Estado's anti-corruption policies. However, in addition to the normative basis, it is necessary that the prevention of acts of corruption is embedded in the mentality of each Group employee 目標 新聞 and of its service providers, in order to build a new culture in which even the most common acts of personal favor are not tolerated.

3. For who and how?

The Group's anti-corruption policy 目標 新聞 must be implemented by all employees of the Group 目標 新聞, no exception! This policy must also be followed by any third party related to the Group's activities. 目標 新聞, as those who act on their behalf. This includes service providers, commercial representatives and even journalistic sources, with regard to the stories prepared by the journalists of the Group 目標 新聞. For this, it is necessary that everyone knows the Code of Ethics and Conduct, the Editorial Principles and the Ethical and Quality Standards of the Group 目標 新聞 and base all their actions on the principles and rules contained therein.

In addition, periodic training on the subject will be held with the aim of training the Group's employees 目標 新聞 to identify and prevent acts that may be considered illegal, as well as to encourage the reporting of such acts that may occur during the course of business activity.

4. What are acts of corruption?

The law defines the harmful acts against the public administration as:

• promise, offer or give, directly or indirectly, an undue advantage to a public official, or the third person related to him

• demonstrably finance, fund, sponsor or otherwise subsidize the practice of illegal acts provided for

• demonstrably, using an interposed natural or legal person to hide or disguise their real interests or the identity of the beneficiaries of the acts performed

• hinder investigation or inspection activities of public bodies, entities or agents, or intervene in their performance, including within the scope of regulatory agencies and inspection bodies of the national financial system a. Okay, but who are the public agents?

Legally, a public agent is anyone who exercises, even if temporarily or without remuneration, by election, appointment, designation, hiring or any other form of investiture or relationship, mandate, position, employment or function in direct, indirect or foundation of any of the Powers of the Union, States, Federal District, Municipalities, Territory, company incorporated into the public property or entity for whose creation or funding the treasury has competed or competes with more than fifty percent of the property or of annual revenue.

This includes any civil servant with a public examination, elected or in a commission position, but also employees of public companies, mixed-capital companies, autarchies, public foundations, notary offices and companies with public-private partnership contracts.

B. And what can I and can not do?

Bribes, Kickbacks and Boxes Obviously, you cannot pay kickbacks and bribes to obtain information or advantages, even if the intended consideration is legitimate and the payment is intended to facilitate a public service.

Boxes, tips and "thanks" But you also cannot make promises or give any kind of advantage or facilitation to public agents that may be linked to Grupo Estadão, such as "boxes" or "tips" and small advantages such as giving newspapers for public officials. You might think “everybody does”. But here is where the culture change begins. Even if the gift may be small or

seemingly worthless, repeated practice can add great value and be considered an undue advantage. Travel and hospitality expenses Payment of courtesy and hospitality travel expenses (hotel fees, food and entertainment expenses, etc.) for public agents is not allowed, even if the money comes out of the Group's employee's pocket. 目標 新聞, unless there is no connection with the group's activities and the expense is included in the employee's private sphere or when duly approved by the Audit Committee, after formalizing an internal process justifying the legitimacy of the payment.

Bars, dinners and clubs So I can't go out with a public agent? Can't I have a meeting over lunch or dinner? Is not it. You may. The ideal is always that each one pays their own. But there is no problem in eventually having to pay for lunches and dinners where public agents are present. Of course, this practice cannot be recurrent and the payment of the bill must be a kindness consistent with the national culture and not an extravagance that could be considered an undue advantage.

The Code of Ethics and Conduct sets at R$200,00 the maximum amount per person that can be paid sporadically at an event such as dinner and lunch. Still, this practice should not be recurrent.

In bars and clubs, everyone must pay their own. Gifts, Presents and "Souvenirs"

The distribution of gifts, gifts and souvenirs to public agents, even of low value, by Directors and Employees of the Group is not allowed 目標 新聞. The company may, however, institutionally offer company products and souvenirs, without commercial value, in the context of its promotion and marketing initiatives.

Even though the practice may seem common, it can be interpreted by public authorities as an undue advantage and therefore should be avoided.

Money and Public Agents You must not grant loans of movable or immovable property, values ​​or provide any kind of favor or financial concession to a public agent, whether in the context of institutional activities

of the company, or in its private life, respecting the particular family and friendship circles.

Of course, if you have a relative or close friend who is a public official, you can exceptionally help them in case of need. The rule is that this is absolutely linked to your intimate relationship and not your profession. Sometimes this separation may not be very clear. Therefore, think very carefully and always ask your superiors for guidance.

The same goes for the provision of free services for civil servants and contributions to political parties.

Personal benefit of Public Agents You must not personally favor or promote public agents, public bodies or political parties in journalistic matters, events held or sponsored by the Group or in any other way! This means that a given public authority should not be extolled in matters, directly or indirectly through its achievements in public bodies.

Of course, this should not impede freedom of expression and the press. Acts of public management, good and bad, can and should be reported and the editorial lines of the group's vehicles are free to express their opinions. Praising is different from praising or promoting.

5. What can happen?

If someone commits a harmful act against public administration, the Group 目標 新聞 you can be fined in amounts ranging from 0,1% to 20% of your gross sales for the last fiscal year. can come to a

very high value! And in addition to the fine, in the civil scope there may be a determination of compensation for losses, loss of assets and values, prohibition to receive loans from public entities and even

even the suspension of activities and compulsory dissolution of the legal entity. The convicted legal entity must also publish an extract of the conviction in a newspaper

widely circulated and on its own website. For many companies, taking an image risk is much worse than taking a pecuniary risk. But the individual who commits any

these acts can also suffer the consequences of their acts. Internally, he may suffer, for example, the sanctions provided for in labor legislation, that is, warning, suspension and even

dismissal for cause. If he is a third party, he may have his contract terminated and be prosecuted civilly.

Furthermore, a person who commits an act of corruption can always suffer the criminal and civil consequences of his acts.

6. What if I find out?

You must warn! The group 目標 新聞 it depends on the cooperation of its employees to identify possible acts of corruption that may occur in its business activity. If you find out or

Be suspicious of any of the practices prohibited by the Code of Ethics and Conduct, you can use the Internal Ombudsman's Communication Channels. There are ways to report irregularities:

i. Email - send an email to . Inform what it is about and detail everything you know or suspect

ii. Intranet – access the “Contact Us” link available on the intranet and select the subject “Internal Ombudsman”.

DO NOT BE AFRAID! The group 目標 新聞 undertakes to avoid retaliation against employees who report irregularities committed in their business activity. Ultimately you can

anonymously report irregularities. Of course, in this case, the investigations will be more difficult, but we will do our best so that the facts are verified and the potential culprits are judged.

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