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Anti -Corruption Policy of DM11® [IT Risk Protection]

Last Update: October 2023

1. Introduction

DM11® [IT Risk Protection] is committed to the highest standards of integrity, ethics and transparency in all its operations and activities. Corruption is unacceptable and harmful to society, the economy and reputation of the company. This anti -corruption policy establishes guidelines and procedures to prevent, detect and combat corruption in all its forms.

2. Definitions

2.1. Corruption: Any illegal or unethical act involving misuse of power, influence, bribery, extortion, bribes, influence trafficking, nepotism, clientelism or any form of improper advantage to obtain personal benefits or for the company.

2.2. Interested stakeholders: all employees, shareholders, customers, suppliers, business partners and any person or entity who has a relationship with DM11®.

3. Commitments

3.1. Respect for the Law: DM11® is committed to complying with all applicable anti-corruption laws and regulations in Brazil, as well as international laws, when applicable.

3.2. Financial Transparency: We will maintain precise, transparent and complete financial records that accurately reflect the company’s transactions and activities.

3.3. Broaking and bribery prohibition: we do not tolerate bribery, bribes or any improper payment to civil servants, customers, suppliers or other stakeholders.

3.4. Ethical Contracting: We guarantee that our hiring processes are fair and transparent, without undue favoritism of relatives or friends of employees.

4. Training and Awareness

DM11® will provide regular anti -corruption training for all stakeholders and stakeholders, ensuring that they understand the ethical and legal implications of corruption.

5. Complaints and investigation

DM11® will establish a confidential and accessible complaint channel for all stakeholders and stakeholders to report suspicions of corruption.
All complaints will be dealt with confidentially and investigated impartially and appropriately.

6. Consequences

Infringement of this anti -corruption policy may result in disciplinary actions, including dismissal of employees and termination of contracts with suppliers or business partners.
If corruption is identified and involving illegal activities, DM11® will cooperate with the competent authorities.

7. Review and Update

This anti -corruption policy will be reviewed periodically to ensure its effectiveness and adaptation to changes in anti -corruption laws and regulations.

DM11® reaffirms its commitment to promote a culture of integrity and ethics, combating corruption in all its forms and contributing to a fair and transparent business environment in Brazil.