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 keeps in itself a deviation from institutional objectives by a

particular in relation to a public agent or state entity. In Brazil, corruption is defined as a crime

Penal Code, according to articles 317 and 333, subjecting individuals who offer and

public agents who request, demand or accept, undue advantage.

In addition, the Administrative Improbity Law (Law No. 8429/92) lists a series of unlawful acts that

breach the principles of administrative morality and cause illicit enrichment of the public agent

and that they can subject those sentenced to civil and administrative sanctions.

In 2013, the National Congress approved Federal Law no. 12.846 / 13, known as the Law

Anti-corruption. The great novelty of the law was the strict imposition of responsibility on people

legal entities that are involved in acts of corruption, called in the law 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 Improbity Law are reactive, that is,

punish after the acts took place (if discovered), the Anti-Corruption Law has a character

preventive, 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 preventive measures against acts of corruption

(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 always guided its activities by seriousness and honesty and has as mission

disseminate and defend the principles of democracy and free enterprise. Corruption, however, is one of the

major obstacles to democracy as it channels the public resources needed for development

of the social plan for individuals illicitly and unjustly.

That is why the Group 目標 新聞, through its journalistic media has always given visibility

corruption scandals and strongly condemned the practice in its editorials. Do that

in his journalistic activity is not everything. It is extremely important that the business activity of the

Group 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 Norms bring

express predictions of behaviors to be avoided and adopted, with the aim of preventing 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 procedures

specific verification and relationship with third parties.

These rules and procedures form the normative basis for the Group's anti-corruption policies

State. However, in addition to the normative basis, it is necessary that the prevention of acts of corruption be

instilled in the mentality of each employee of the Group 目標 新聞 and their service providers,

way 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

Group activities 目標 新聞, as those who act on their behalf. This includes service providers

service representatives, commercial representatives and even journalistic sources, with respect to the

prepared by Group journalists 目標 新聞.

For this, it is necessary that everyone knows the Code of Ethics and Conduct, the Editorial Principles and the

Group Ethical and Quality Standards 目標 新聞 and guide all your actions by the principles and rules there

constant.

In addition, periodic training on the subject will be carried out with the objective of training

Group employees 目標 新聞 to identify and prevent acts that could be considered illegal,

as well as, to encourage the denunciation of those acts that may happen during the activity

business

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 agent, or to

related person

• demonstrably, finance, fund, sponsor or in any way subsidize the practice

of the illegal acts provided for

• provenly, to use an individual or legal entity to conceal or conceal

their real interests or the identity of the beneficiaries of the acts performed

• hamper investigation or inspection activities by public bodies, entities or agents, or

intervene in its performance, including within the scope of regulatory agencies and

inspection of the national financial system

The. Okay, but who are the public officials?

Legally, everyone who exercises, even if temporarily or without

remuneration, by election, appointment, appointment, hiring or any other form of investiture

or bond, mandate, position, employment or function in direct, indirect or

foundational of any of the Powers of the Union, the States, the Federal District, the Municipalities,

Territory, of a company incorporated into the public patrimony or of an entity for whose creation or

the treasury has competed or competes with more than fifty percent of the equity or annual revenue.

This encompasses any public servant who is competing, elected or in charge of a commission, but also

employees of public companies, mixed-capital companies, municipalities, public foundations,

notaries and companies with public private partnership contracts.

B. And what can I and can not do?

Bribes, Bribes and Boxes

Obviously, you cannot pay bribes and bribes for information

or advantages, even if the objective consideration is legitimate and the payment is destined to

facilitation of a public service.

Boxes, tips and “treats”

But you also cannot make promises or give any kind of advantage or facilitation to

public agents that can be linked to the Estadão Group, such as, for example, “boxes” or “tips” and

small advantages like giving newspapers to public officials. You may think that "everyone does".

But this is where the culture change begins. Even if the gift may be small or

seemingly worthless, the repeated practice can add great value and be considered a

advantage.

Travel and hospitality expenses

Complimentary travel and hospitality charges (hotel nights,

food and entertainment expenses, etc.) for public officials, even if the money leaves the

Group employee's own pocket 目標 新聞, unless there is no connection with the activities

group and the expense is included in the employee's private sphere or when duly

approved by the Audit Committee, after formalization of the internal process in which the

legitimacy of the payment.

Bars, dinners and clubs

So I can't go out with a public agent? I cannot have a meeting over lunch or

a dinner? Is not it. You can. The ideal is always that each one pays its own. But there are no problems

in the event of the payment of lunches and dinners in which agents are present

public. It is clear that this practice cannot be recurrent and the payment of the bill must be a

kindness consistent with national culture and not an extravagance that can be considered a

advantage.

The Code of Ethics and Conduct sets at R $ 200,00 the maximum amount per person that can be paid in a

sporadic at an event like dinner and lunch. Even so, this practice should not be recurrent.

In bars and clubs, everyone must pay their own.

Gifts, Presents and “Souvenirs”

The distribution of gifts, presents and souvenirs to public officials, even from low

value, by Group Directors and Employees 目標 新聞. The company may, however, institutionally,

offer products and souvenirs of the company, with no commercial value, in the context of its

promotion and marketing.

Although the practice may seem common, it can be interpreted by public authorities

undue advantage and should therefore be avoided.

Money and Public Agents

You must not grant a loan for movable or immovable property, securities or provide any kind of

favoring or financial concession to public agents, either in the context of institutional activities

of the company, whether in his private life, respecting private family and friendship circles. IS

of course if you have a relative or close friend who is a public agent you can help him

exceptionally when necessary. The rule is that this is absolutely linked to your

intimate relationship and not your profession. Sometimes this separation may not be very clear. So think

very well and always ask for guidance from your superiors.

The same goes for the provision of free services for public servants and contributions to

political parties.

Personal benefit of Public Agents

You must not personally favor or promote public officials, public agencies or parties

journalists, events held or sponsored by the Group or any other

form! That is to say that a certain public authority should not be praised in matters, direct,

or indirectly through their achievements in public agencies.

Of course, this should not impede freedom of expression and the press. Public management acts, good

and bad, can and should be reported and the editorial lines of the group's vehicles are free to

express their opinions. Praise 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 can be fined

values ​​ranging from 0,1% to 20% of your gross sales for the last financial year. You can reach a

very high value! And in addition to the fine, in the civil sphere, there may be the determination of reimbursement of

losses, losses of assets and values, prohibition on receiving 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 convicting decision in a newspaper

circulation and on its own website. For many companies taking a risk of

image is much worse than taking a financial risk. But the individual who commits anyone

these acts can also suffer the consequences of their acts. Internally, he may suffer, for

example, the sanctions provided for in the labor legislation, that is, the warning, suspension and even

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

civilly prosecuted.

Furthermore, the person who commits an act of corruption can always suffer the criminal and

civil acts.

6. What if I find out?

You must warn! The group 目標 新聞 depends on the cooperation of its collaborators to identify

any acts of corruption that may occur in your business activity. If you discover or

be suspicious of any of the practices prohibited by the Code of Ethics and Conduct, you can

Communication Channels of the Internal Ombudsman. There are ways of reporting irregularities:

i. Email - send an email to [Email protected] Tell us 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

communicate irregularities committed in their business activity. Ultimately, you can

report irregularities anonymously. Naturally, in that case, the investigations will be more

difficult, but we will do our utmost so that the facts are ascertained and the potential culprits are

judged.