POLICIES
MIP’s Compliance Management Policy expresses our way of being and acting.
Affirming the company’s commitment to continuously improve its Compliance management processes and disseminate the Compliance practice at all levels.
Ensuring compliance with the Compliance System, the Code of Ethics and Conduct, internal norms, rules and procedures and all applicable laws and regulations, with the Compliance System Administrator having autonomy and independence to act.
MANAGEMENT
MIP’s Compliance Management Policy expresses our way of being and acting. Affirming the company’s commitment to continuously improve its Compliance management processes and disseminate the Compliance practice at all levels.
Ensuring compliance with the Compliance System, the Code of Ethics and Conduct, internal norms, rules and procedures and all applicable laws and regulations, with the Compliance System Administrator having autonomy and independence to act.
PEOPLE
Disseminate the practice of the Compliance System at all levels of the organization, incorporating it into procedures and processes.
INTERESTED PARTS
Maintain a Compliance System that is an instrument for managing relationships in accordance with the standards required by the Compliance management standard and the like. In a succinct, clear and objective manner, emphasizing the obligation of all our employees and third parties to conduct their activities in an ethical, reliable and honest manner.
POLICY OF RELATIONSHIP WITH PUBLIC ADMINISTRATION
MIP is committed to promoting integrity in the business environment, both public and private, acts in compliance with the Anti-Corruption Law and other applicable regulation.
As a result, it defined the Policy below, which aims to reaffirm the integrity and transparent posture of MIP Egenharia in its relationship with the Public Autharities and the adherence of the conduct of its employees to current legislation, the company´s rules and procedures and to the MIP Code of Ethics and Conduct.
This Policy also aims to prevent the occurrence of some risk situations, especially with regard to those provided for in Anti-Corruption Law No. 12,846/2013, which may facilitate or disguise the offering of undue advantages to a public agent, or contribute to the occurrence of practices and corruption in bids and contracts.
Based on these terms, this Policy establishes guidelines that should guide ethical conduct in the relationship with Public Agents and people related to them.
DEFINITIONS
This Policy covers all MIP employees, at any hierarchical level, and all its suppliers, service providers and intermediary agents.
For purposes of this Policy, some terms should be understood as follows:
Public Agent: whoever exercises a public function, temporarily or permanently, with or without remuneration, by election, appointment, designation, hiring or any form of investiture or bond, mandate, position, employment or public function. It is equivalent to a public agent who works for a company providing a service contracted or associated with the execution of typical activity of the Public Administration.
Conflict of Interest: occurs when an interest or personal advantage may interfere with the necessary exemption from judgment or correct execution of the employee’s work, conflicting with the interests of the company or with the role that he/she performs within MIP.
Granting or receiving gifts and/or gifts: gifts and/or gifts constitute a kindness and cordiality between the parties involved in the commercial relationship. Its receipt or concession by MIP employees must observe the internal rules of the Compliance System and must under no circumstances aim at obtaining benefits, advantages, influences or retribution. The criteria for granting or receiving gifts and/or presents are defined in MIP’s Code of Ethics and Conduct.
General Guidelines
At MIP, all forms of fraud and corruption, are prohibited in all its forms, active or passive, whether through acts or omissions, or through the creation and/or maintenance of irregularity, favoring or fraudulent situations. In this way, all employees, suppliers and any other persons who represent the interests of MIP during their relationship with a Public Agent or a third party related to him, they are PROHIBITED from:
- Use the position, function or influence arising from your work at MIP with the aim of obtaining personal advantages, facilities or any other form of favoritism or illegitimate benefit for yourself or for third parties.
- Establishing a dishonest and lacking integrity relationship with a Public Agent or a third party related to him.
- Accepting or offering gifts and/or gifts to Public Agents in order to obtain benefits, advantages, influence or retribution.
- In any way to defraud, manipulate or illegally interfere in private and/or public competitions and tenders.
- During the process of obtaining licenses, authorizations and permissions, offer undue advantages to public agents, or even respond to requests from these agents, with the aim of benefiting the company.
- During an inspection, offering undue advantages or giving in to requests from a public agent, with the aim of influencing the outcome of the inspection.
- Hire former public agents in order to facilitate easy access to bodies or authorities or obtain privileged information
- Hiring people linked to public agents (family members, partners, etc.), with the aim of covering up the payment of an undue advantage.
Disciplinary investigations and measures
When detecting signs of the occurrence of harmful acts against the Public Administration, the MIP initiates an internal investigation, which will serve as a basis for taking the appropriate measures.
If, after the investigation, it is found that conduct has occurred that violates the rules of this Policy, disciplinary measures will be taken, which will be applied without prejudice to other applicable measures in accordance with the legislation in force.
Any employee, third party or partner who violates any provision of this Policy will be subject to the disciplinary measures provided for in MIP’s Code of Ethics and Conduct.
