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ANTI-BRIBERY, ANTI-CORRUPTION AND COMPLIANCE POLICY

This Policy establishes the guidelines and standards of conduct to prevent, detect, and remedy any acts of corruption, bribery, or fraud in the conduct of Felpro's activities.
 

This document applies fully to all employees, directors, board members, as well as third parties, suppliers, consultants, and commercial partners acting on behalf of or for the benefit of our organization.  


This Policy is managed, interpreted, and executed in strict attendance with the Brazilian legal framework for tackling corruption, as well as the best international compliance practices and guidelines. This document is based, in particular, on the following legal statutes:

  • Federal Law No. 12,846/2013 (Brazilian Anti-Corruption Law): Provides for the strict administrative and civil liability of legal entities for the commission of harmful acts against public administration, whether national or foreign. The organization declares full compliance with the precepts of administrative probity codified therein.

  • Federal Decree No. 11,129/2022: Regulates Law No. 12,846/2013, establishing the parameters for evaluating integrity mechanisms, auditing, incentives for reporting irregularities, and the effective enforcement of codes of ethics and conduct within the legal entity.

  • Decree-Law No. 2,848/1940 (Brazilian Penal Code): Notably regarding crimes against Public Administration, including, but not limited to, active corruption (Art. 333) and traffic of influence (Art. 332).

  • Federal Law No. 8,429/1992 (Administrative Improbity Law): As applicable to sanctions enforced on private agents who induce, contribute to, or benefit from acts of improbity committed by public agents.

  • International Legislation (Comparative Practices): In alignment with global governance and international trade transaction standards, this policy observes the general principles of the Foreign Corrupt Practices Act (FCPA - USA) and the UK Bribery Act (United Kingdom), applying their guidelines for preventing transnational bribery whenever there is a connection to international operations.

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Felpro adopts a zero-tolerance policy toward any unlawful practice. The following are expressly prohibited:

  • Bribery and Kickbacks: Offering, promising, authorizing, giving, soliciting, or accepting, directly or indirectly, any undue advantage, pecuniary or otherwise, to public officials or private sector representatives, with the intent of obtaining a competitive advantage or influencing decisions.

  • Facilitation Payments: Making small-value payments to public officials to accelerate or guarantee the execution of routine actions or government services to which the company is entitled.

  • Gifts, Presents, and Hospitality: Offering or accepting courtesies that could be interpreted as an attempt at bribery. Only institutional gifts of nominal value, distributed generally, and that do not generate any obligation of reciprocity are permitted.

  • Donations and Sponsorships: Making political donations on behalf of the company or directing sponsorships and philanthropic donations as a means to disguise improper payments.

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All commercial and financial transactions must be recorded accurately, completely, and transparently in the company's accounting books. Maintaining off-the-books accounts or funds or the issuance of tax invoices that do not reflect the actual nature of the executed operation is strictly forbidden.

The violation of the guidelines in this Policy constitutes a serious offense. Non-compliance by employees will result in the application of appropriate disciplinary measures, which may include termination for just cause, without prejudice to the civil and criminal sanctions provided by law.

 

Reporting Channel and Whistleblower Protection
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We provide an exclusive and secure channel for receiving reports regarding any suspected violations of this Policy, ethical deviations, or legal non-compliance.

  • Service Channel: Contato@felpro.com.br

  • Guarantee of Anonymity: Reports can be made anonymously or with identification, and the confidentiality of the information and the identity of the whistleblower will be strictly protected.

  • Non-Retaliation: The company strictly prohibits any form of retaliation, punishment, or disciplinary action against anyone who, in good faith, reports a suspicion or cooperates with an internal investigation.

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Version 1.0 — Updated July 2026. Approved by Felpro’s Executive Board. All rights reserved.

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