1. Our commitment
TACJR Participações Ltda. (“Veracana”) does not tolerate bribery or corruption in any form, by anyone, anywhere.
This policy reflects Brazil’s Clean Company Act (Lei nº 12.846/2013) and the anti-corruption laws of the countries where we do business, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act where they apply.
2. What is prohibited
Directly or through third parties, no one acting for Veracana may:
- offer, promise, give, request or accept anything of value to improperly influence a decision. This applies to public officials, customs and port staff, inspectors, bank staff and employees of buyers or suppliers;
- make facilitation payments to speed up routine actions such as customs clearance, loading or document issuance;
- use agents, brokers or consultants to do indirectly what we cannot do directly;
- falsify or hide any payment in our books and records.
3. Gifts and hospitality
Modest gifts and hospitality are acceptable only if they are:
- reasonable;
- transparent;
- not given to influence a decision;
- recorded.
We never give gifts to public officials.
4. Third parties
Agents, brokers and service providers are screened before engagement. They are paid only:
- for documented, legitimate services;
- at market rates;
- into accounts in their own name;
- with contracts that require compliance with this policy.
5. Accurate records
All transactions are recorded completely and accurately. No off-book accounts are permitted.
6. Reporting
Concerns can be raised in confidence at quotes@veracanatrades.com. We do not tolerate retaliation against anyone who reports in good faith.
7. Consequences
Breaches lead to:
- disciplinary action for employees;
- termination for business partners;
- referral to the authorities where appropriate.