Anti-Bribery Policy

TSA Advogados is not in line with any form of corruption or bribery. TSA Advogados is committed with the compliance with the laws of bribery countering applicable to the organization.

Introduction

Bribery is the offer, promise, donation, acceptance or request of an undue advantage of any value (which may be financial or not), directly or indirectly, and regardless of location(s), in violation to the applicable laws, as an incentive or reward for a person, who is acting or stopping from acting in relation to the development of his/her obligations.

Bribery is a generalized phenomenon. It causes serious social, moral, economic and political concerns, undermines the good governance, makes the development difficult and distorts competition. It erodes justice, undermines human rights and is an obstacle to the relieve of poverty. Bribery also increases the cost of making businesses, introduces uncertainties in the trade transactions, increases the cost of goods and services, decreases the quality of products and services, what can lead to the loss of lives and properties, destroys the confidence in the institutions and interferes in the fair and efficient operation of the markets.

Responsibilities

All collaborators (partners, associated, employees, interns, third parties and business partners) of TSA Advogados and the ones acting on its behalf are responsible for the compliance with all laws of bribery countering in force.

Prohibition of Bribery

TSA Advogados does not allow any form of bribery, we forbid our collaborators to request, accept or give, promise or offer, in a direct or indirect manner, any payment, benefit or something with value to a third party (regardless of being himself/herself/itself, TSA Advogados, its clients and/or a third party) to: influence, in an improper manner, any act or decision; or try to ensure any improper advantage or to favor himself/herself/itself, STA Advogados, its clients and/or a third party; or to ensure an unfair preference in the acquisition of products and services or, in any other way, to obtain or retain the business, including any trade transaction for TSA Advogados, by shadowy means.

Contracting of Correspondents

By contracting correspondents, business partners or other intermediaries that will render services in the name of TSA Advogados, the selection, contracting and due diligences must be executed, taking into consideration the nature of the services and the risks involved.

Prohibition of Facilitation Payments

TSA Advogados forbids all facilitation payments as they are considered bribery. These payments are small, extraofficial and improper remunerations to government´s employees in order to ensure or accelerate a routine or necessary action to which TSA Advogados is legally in charge of. TSA Advogados’ policy regarding the concession of rewards and gifts shall obey the applicable regulation.

Responsibility to Report

All collaborators are responsible for the report of any suspicious of violation or known violation of this Policy, using the channels of report available. It is secured to the personnel the non-retaliation, discrimination or disciplinary action for reports made in good-faith or based on a reasonable conviction of violation or suspicious of violation of the anti-bribery policy of the organization, or for the refusal in participate in the bribery, even if such refusal may result in the loss of a deal to the organization.

Anti-Bribery Compliance Function

The people who exercise the activity of Anti-Bribery Compliance count with full support of the partners and have the authority and independency necessary for the complete exercise of their functions, in order to take care of and enforce the Anti-Bribery Program.

Disciplinary Measures

The people who violate this Policy shall be subject to the pertinent legal and/or disciplinary measures, that shall be set by the competent administrators of TSA Advogados.

Continuous Improvement

TSA Advogados will be continuously in the search for an improvement in the adequacy, sufficiency and efficiency of the anti-bribery management system.

Requirements

To comply with the requirements of the Anti-Bribery Management System.