Anti-Corruption Policy

Advocacia Lunardelli is aware of Law # 12.846/13 (Anti-Corruption Law), regulated by Decree # 8.420/15 and other applicable anti-corruption laws (“FCPA” – “Foreign Corrupt Practices Act”, of 1977 and its amendments), thus declaring that:

  1. It acts with transparency and respect in all its interactions with the public sector and repudiates the practice of corruption or bribery, actively or passively, for acts, omissions, creation or maintenance of situations of favoritism through facilitation payments or otherwise of irregularity;
  2. Undertakes not to offer, promise or give, directly or indirectly, anything of value, with the purpose of obtaining undue advantage or influencing the conduct of a public official or government official, not limited to payment in cash, this understanding may include gifts, meals, transportation and travel, hospitality expenses, job offers, business opportunities, among others.
  3. As for the investigation or inspection activity of public bodies, entities or agents, including within the scope of regulatory agencies and inspection bodies, it promises to act with exemption, avoiding any action that, directly or indirectly, has fraudulent, coercive, manipulative or misleading influence.
  4. He informs that no member of his team is or was a public official, employee of a political party or candidate for political office, nor does he have a close relationship with any public official, political party, employee of a political party or candidate for political office.
  5. It further declares that any of its partners, interns, employees and Third Parties was the object of an internal, governmental or regulatory agency investigation involving a case of bribery or corruption, nor was it dismissed or had its service provision discontinued for any of these reasons.
  6. It also clarifies that it does not engage in political party activities, nor does it make donations to candidates or political parties, emphasizing that any initiative by members of its team in this regard will be restricted to their personal activities, outside the work environment and the provision of services.
  7. It declares to have clear, accurate and prepared bookkeeping in accordance with accounting principles and current legislation, supported by documentation adequate to its activities and does not agree with any modification in its accounting and financial records, which have the purpose of fraud or manipulation, preserving its financial information with full responsibility.
  8. It does not employ child or forced labor nor does it agree to such practices by third parties who provide it with products or services, declaring to submit to the dictates of the Universal Declaration of Human Rights and international conventions, treaties or initiatives, such as the Global Compact of the United Nations, for offering guidelines for the promotion of sustainable growth and respect for citizenship.

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