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It is with great pleasure that BRAZIL IRON establishes this instrument. Guided by the importance of preserving ethical work and seeking to establish a culture that understands and respects the business environment and the society in which it operates.
Therefore, this Code of Ethics and Conduct (CEC) was written to establish the rules, conduct, and processes that must be followed by all those who are involved in any capacity with BRAZIL IRON.
Furthermore, this CEC is founded on the following core principles:
Therefore, in all relationships, whether with clients or business partners, BRAZIL IRON employees must uphold the aforementioned principles, as these are the pillars of the entire organization.
The following are the definitions of the terms used in this document:
3.1 Integrity Program Coordination
The Integrity Program will be coordinated by an independent body, which will have sufficient human and economic resources for its proper
operation.
Its obligations include:
3.2 Ethics Committee
The Ethics Committee will be responsible for:
The Ethics Committee will be composed of:
All Committee members will serve a 1-year term. Representatives will be chosen through voting or drawing, and if necessary, may undergo training to serve on the Committee.
The Ethics Committee will meet monthly, or extraordinarily when deemed necessary by any committee member.
4.1 Anti-corruption
Corruption is defined as the act of giving, offering, or promising any type of undue advantage to a public official or related third party1. This conduct is illegal and can result in criminal liability for both the person who offers and who accepts the illicit advantage, as well as civil and administrative liability for the company in whose interest or benefit this act was performed.
Therefore, any and all acts of corruption are strongly discouraged and condemned by BRAZIL IRON. It is important to note that BRAZIL IRON understands that the business environment should be conducted in the most ethical and transparent way possible, so that any attempt at favoritism, whether through offering values or through gifts or presents, are not practices accepted by BRAZIL IRON.
Furthermore, the mere proposition or promise of advantages is already in complete disagreement with the values defended by BRAZIL IRON, so that all employees have the duty to contact the integrity program coordination to report possible infractions they observe.
On the other hand, indecorous requests for undue advantages are part of the business world reality. In these moments, BRAZIL IRON employees are expected to maintain their ethical posture at all times, acting as follows:
Moreover, other measures can be taken to prevent these proposals from occurring, such as:
4.2 Conflict of Interest
A conflict of interest situation materializes when there is a clear clash between the personal interest of the employee and the clear and specific interest of BRAZIL IRON. In other words, when interests are found to be competing, we are facing a conflict of interest situation.
This is a complex situation with numerous examples. However, to simplify, we can summarize the conflict of interest to gain. That is, whenever due to their position or due to being a member of BRAZIL IRON, the employee obtains any type of gain, whether financial or not, that goes against the interest of BRAZIL IRON, we are facing a conflict of interest.
This conflict can also occur in cases of personal relationships within the company. The creation of bonds and intimate relationships between employees is not rejected. However, depending on the situation, we must observe these relationships more closely. We will use some examples to better elucidate this situation:
Moreover, if any employee becomes aware of any of these conducts, they should file a complaint.
5.1 Third-party Service Contract
According to national legislation, any illegal act by any third party providing services to BRAZIL IRON that is in the company’s interest or benefits it makes the company equally liable. Therefore, it matters little whether the illegal act was committed at the company’s command.
Thus, the relationship with third parties is a risk relationship that must be closely monitored.
As already expressed above, BRAZIL IRON does not condone the acceptance or offering of any type of advantage to achieve certain ends. Furthermore, whenever it is necessary to hire any third party, prior due diligence must be conducted to determine what risk that particular service provider poses and whether or not the contract with them should be signed.
5.2 Harassment
In principle, it should be mentioned that any type of harassment is repudiated within BRAZIL IRON, whether sexual or moral. Furthermore, interpersonal relationships within the company’s limits must always be conducted in the most transparent and professional way possible.
It is important to emphasize that all BRAZIL IRON employees have the duty to report acts they consider as harassment conduct, regardless of the hierarchy of the parties involved. For this purpose, the procedure described in item 13 should be used.
6.1 Preservation of Competition
Competition is essential for the proper functioning of the market, therefore, it is necessary to preserve it. For this purpose, it is necessary that the relationship with competitors and with competition in general always be as fair as possible.
Furthermore, since BRAZIL IRON is a mining company, greater attention to competition is necessary.
Regarding the market in which it operates, BRAZIL IRON as well as all its employees, must refrain from making any interference in the values or products offered in BRAZIL IRON that result in anti-competitive conduct.
Similarly, it may not under any circumstances promote any type of meeting, congress, seminar, or any type of social event with its partners to combine or regulate the terms and values of products offered in the application.
If BRAZIL IRON notices any type of conduct by its partners that, through BRAZIL IRON, is creating damage to competition, it must take necessary measures to remedy the damages caused, and may ban partners who are discovered having such conduct. Furthermore, if necessary, it may cooperate with the responsible agency.
BRAZIL IRON expects and trusts that its employees will always act ethically and following the principles set forth here.
Furthermore, it informs that it respects and accepts the political convictions of each of its employees. However, it informs that its employees are not authorized to express supposed political convictions of BRAZIL IRON, or even to make donations on behalf of BRAZIL IRON to political parties or candidates. Finally, any type of informative, social media posting, or any communication, wherever it may be, by whatever means, of supposed convictions or support for politicians or political parties by the company is forbidden.
It should be noted that employees may still make donations or express their ideologies or political preferences, but should always do so in their own name.
Furthermore, employees may not speak on behalf of BRAZIL IRON at any time unless expressly authorized by the responsible department. Depending on the message to be transmitted, the responsible department will determine how the communication should be made.
Finally, BRAZIL IRON informs that it expects from its employees the most inclusive and respectful conduct possible, not tolerating in any way any type of prejudice.
If any employee notices that another employee is acting in a way that does not follow the precepts described above, they should report to the company through the complaint channel.
8.1 Confidentiality
The main product of BRAZIL IRON is directly related to its digital platform. In this, it is necessary that its users, partners, and deliverers inform BRAZIL IRON some of their personal data, which are perfectly discriminated in its Privacy Policy.
Therefore, it is necessary that BRAZIL IRON employees are aware of the confidentiality intrinsic to their activity.
For this purpose, whenever a new employee who works directly or indirectly with these personal data is hired, they will sign a privacy and personal data protection addendum. This will provide for the period for which confidentiality will be necessary, as well as to whom it extends. Furthermore, the term must contain that the employee commits to not transfer the data under any circumstances to people outside the project in which they work.
Finally, all personal data will be treated according to the Privacy Policy and stored according to the Information Security Policy, all documents are available on BRAZIL IRON‘s website.
8.2 Access Policy
Whenever accessing BRAZIL IRON‘s virtual environment, the employee will necessarily use an account created by the company for the employee. Furthermore, the account created and used for system access is personal and non-transferable, with the employee being responsible for all acts performed in their account.
Furthermore, if due to a cyber attack, the employee finds that their account is being used by another person, they must necessarily and immediately inform the responsible sector so that it can take the necessary measures. In these cases, once the invasion is proven, the employee will be exempt from responsibility.
9.1 Gifts and presents
Within BRAZIL IRON, offering and receiving gifts or presents is lawful, provided it is done sporadically, appropriately, legally and reasonably. However, the intention of offering or accepting the gift or present may never influence the decision-making of any business.
Therefore, BRAZIL IRON employees must always adopt the most conservative and transparent posture possible, especially when dealing with public agents.
Regarding public agents, it is only permitted to offer and receive gifts or presents after prior approval from the Integrity Committee and provided they are up to the symbolic value of R$ 100.00 (one hundred reais). Receiving or offering a higher value and using the gift with the intention of influencing any decision is strictly prohibited, constituting a violation of the Integrity Program, subject to disciplinary measures.
To better exemplify, it is unacceptable to offer or receive gifts or presents in the following situations:
When in doubt, employees may contact the Integrity Committee, or not offer or politely refuse the gift or present.
9.2 Hospitality
Accommodations, tickets, meals and occasional drinks, event tickets, among others are acceptable provided the limits established in the previous topic are respected and provided they are not offered or given to public agents.
9.3 Donation
Company donations to philanthropic institutions are permitted, however, in these cases it will be necessary to follow some steps.
Furthermore, depending on the amount, it will also be necessary for the institution to open its accounting books and records for due diligence.
Finally, donations must always be based solely on their social impact, with the maximum transparency possible, depending on the situation.
Communication and training are the responsibility of the integrity program coordinator. To this end, the coordinator may use all means of communication to always highlight the integrity program. This communication must be constant, for better internalization of the culture to be disseminated by the company.
Furthermore, for communication the coordinator may use dynamics or any educational method capable of disseminating the integrity culture documented in this CEC.
Moreover, training will be formulated to cover the largest number of people possible, regardless of their positions and background. Additionally, training must be conducted at least semi-annually. Depending on the deliberation of the Integrity Program Coordinator, training may occur more frequently.
The reporting channel, an essential instrument of the integrity program, has as its social function to receive reports brought by employees, users, partners, suppliers or any other third parties. All reports brought must refer to measures contrary to the guidelines established in this CEC and committed by employees or third parties associated with it.
It is also essential that good-faith whistleblowers have their identity protected. On the other hand, whenever a report is made, the whistleblower will receive a protocol number through which they can track the progress of the report.
After investigating the report, the integrity program coordinator will deliver to the ethics committee a report on the complaint and its respective conclusions, within the timeframe and terms of item 3.1. Then, the committee must decide how to proceed regarding the violation, applying, when necessary, disciplinary measures.
For the application of disciplinary measures, the committee must always observe the principles of reasonableness and proportionality. The impact of that particular conduct on the company must also be observed. Finally, it will be analyzed whether the employee is a repeat offender or not, whether in that violation or in others also related to this document. Furthermore, the decision to be made must be substantiated, and must be included in the report of the judgment of the complaint.
Furthermore, penalties must follow the following list, but not be restricted to it:
1 Law 12.846/2013, article 5, I.
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