As part of the Minerva Group’s unwavering commitment to business ethics, a Compliance Model has been implemented within the Group, in order to ensure that all members of the Company act in accordance with applicable regulations and the ethical commitments assumed by the Group.
Grupo Minerva’s commitment to regulatory compliance is clear and transparent, with the aim of guaranteeing the effectiveness of the implemented Model. In this regard, the Board of Directors reaffirms its position of zero tolerance for the commission of illegal or irregular practices that may directly or indirectly benefit the Group.
Based on this commitment to compliance, the parameters of conduct expected of all members of Grupo Minerva are established, requiring them to commit to them, describing the measures adopted to supervise this mandate and the consequences in the event of non-compliance.
All persons employed or who carry out their professional activity within the Minerva Group are imperatively obliged to understand, accept and assume the commitment to observe and comply with the provisions established in this Policy, without exception depending on the rank, position or function they perform within the Group.
All members of Grupo Minerva must report any individual and collective facts, behaviours or activities that occur in the context of the Group’s operations and that may involve non-compliance with the law, this policy and other applicable regulations, as soon as they become aware of them. Communications can help prevent or detect regulatory compliance risks and are therefore essential for the proper functioning of the Compliance Model.
To this end, each Minerva Group company has an Ethics Channel, making available to all its members the following means to carry out communications:
(ref. Ethical Channel – “Confidential and Personal”)
(UHY Fay & Co. is the external responsible for the management of the Ethical Channel of Grupo Minerva)
Grupo Minerva undertakes to avoid any type of retaliation against those professionals who report, in good faith, alleged breaches of the applicable regulations.
Queries and communications received through the Ethics Channel will be analysed independently and confidentially, guaranteeing the anonymity and/or confidentiality of the identity of the informant and the person or persons to whom the communication relates.
(ref. Complaints Channel – “Confidencial e Pessoal”)
(UHY Fay & Co. is an external entity responsible for the management of the Complaints Channel for the Minerva Insights Group).
The inquiries and communications received through the Complaints Channel will be analyzed independently and confidentially, guaranteeing anonymity and/or confidentiality of the identity of the informant and the person or person who is communicating with the person.
