Yes. Funep has implemented its Compliance and Integrity Program. The aim of this program is to support the Foundation in its fight against fraud, bribery and corruption, through a model of integrity, transparency and compliance. FUNEP’s integrity program has nine basic pillars :

• Top Management Support
• Risk assessment
• Ethics and Conduct Code
• Internal Controls
• Training and Internal Communication
• Reporting channels
• Internal Investigations
• Due diligence – previous one or due one or previous analysis
• Auditing and Monitoring

Yes. Funep implemented its “SGA” on December 18, 2020 when, after a very rigorous and thorough external audit, it obtained the CERTIFICATION in the ABNT NBR ISO 37001: 2017 Standard, which is based on Law number 12,846 / 2013, known as the Brazilian Anti-Corruption Law, clearly demonstrating that at Funep the work is carried out with ethics and transparency.

Yes. Funep’s Code of Ethics and Conduct can be accessed through this link.

All employees, service providers, product suppliers and business partners (third parties) must comply with Funep’s Code of Ethics and Conduct.

Funep operates based on the principles of legality, impersonality, morality, advertising, economy and efficiency.

Yes. Any violation of the Code of Ethics can be reported on the Ethical Channel through this link.

Any denunciations of the Funep Code of Ethics and Conduct violations or any other violation of the current laws, such as (i) moral or sexual harassment, (ii) conflict of interest, (iii) fraud or misuse of goods and / or products, among others.

All complaints received are guaranteed anonymity and will be dealt with and investigated and, if relevant, appropriate measures will be taken.

No. The Code of Ethics and Conduct guarantees the whistleblower in good faith guarantees that no retaliation will be allowed.

In case of doubt, contact Funep’s Compliance Officer. You can send an email to: compliance@funep.org.br.

Yes. Funep’s Board of Trustees approved the Anti-Bribery Policy. This Policy is intended to guide the attitudes of all those involved, directly or indirectly, with the Foundation, in relation to the practices of corruption and bribery, in addition to our Code of Ethics and Conduct. You can access this policy through this link.

A. The fundamental objectives are:

• Bribery is prohibited
• You must comply with the Code of Ethics and Conduct
• It is necessary to comply with the Brazilian Anti-Corruption Law 12.846/2013, other laws and other subscribed requirements applicable to Funep
• Meet and continuously improve the Anti-Bribery Management System
• Ensure authority and total independence of the Compliance Officer to deal with any matters related to the bribery theme