- Introduction
- Objectives & scope
- Key definitions
- General guidelines
- Interactions with public officials
- Responsibilities
- Training & communication
- Reporting channel
- Consequences of non-compliance
- Reviews & updates
Art. 1 Introduction
Committed to integrity, transparency, and professionalism, Data Riders establishes this policy to guide and regulate the offering and receiving of promotional items, gifts, and hospitality across all its activities. This policy is an extension of our commitments outlined in the Code of Ethics and Conduct and the Anti-Corruption Policy, ensuring that our commercial and institutional relationships remain free from any conflict of interest or suspicion of bribery.
Art. 2 Objectives & scope
- Establish criteria for offering and receiving promotional items, gifts, and hospitality.
- Prevent conflicts of interest, the appearance of improper advantage, and any influence on impartial decisions.
- Apply to all employees, leadership, consultants, partners, suppliers, and third parties acting on behalf of Data Riders.
- Cover commercial, institutional, and public sector relationships.
Art. 3 Key definitions
Item of nominal or promotional value, usually displaying the giver's logo, provided freely and without expectation of reciprocity.
Item of higher individual value offered outside a nominal context, subject to additional scrutiny.
Meals, travel, lodging, events, or entertainment offered in the context of a professional relationship.
Any individual holding a public role, including state-owned enterprise employees, regulators, and members of public commissions.
Value that does not influence decisions, typically promotional items of modest and publicly known cost.
Art. 4 General guidelines
- Promotional items and hospitality may only be offered or accepted when of nominal value, occasional nature, and aligned with legitimate business purposes.
- Consult leadership or Compliance before accepting or offering gifts/hospitality whenever there is a risk of misinterpretation.
- Gifts exceeding nominal value must be reported to immediate leadership, who will decide on acceptance, refusal, return, or sharing, in accordance with Compliance guidance.
- Excessive gifts or hospitality may need to be refused, returned, or shared internally.
- Avoid gifts or hospitality during sensitive periods, negotiations, contract renewals, bidding processes, audits, or similar situations.
If in doubt, seek guidance from your manager, director, or Compliance channel before offering or accepting. Documenting the inquiry protects both you and the company.
Art. 5 Interactions with public officials
- Never offer cash, gift cards, or cash equivalents to public officials.
- Do not offer hospitality disproportionate to the official event (for example, travel, lodging, or entertainment exceeding applicable rules).
- Do not use intermediaries, consultants, or third parties to deliver gifts or hospitality to public officials.
Comply with the specific rules of each jurisdiction and public agency. Where a public agency has zero-tolerance policies, they apply in full.
Art. 6 Responsibilities
- Each employee and partner is responsible for reading, understanding, and applying this policy.
- Leadership validates offers and receipts outside nominal parameters and escalates to Compliance when necessary.
- Compliance keeps the policy up to date, conducts training, manages the reporting channel, and investigates cases.
Art. 7 Training & communication
Data Riders provides regular ethics and compliance training covering gifts and hospitality rules, integrating public sector specifics and industry standards such as TSM and The Copper Mark.
Art. 8 Reporting channel & investigation
Any suspected violation of this policy must be reported immediately through the company's reporting channel. Whistleblowers are protected against retaliation. Write to hi@datariders.com.br with the subject line "Gifts & Hospitality, Report".
Art. 9 Consequences of non-compliance
Violations may trigger disciplinary actions proportionate to the offense, warnings, suspension, termination for cause, contract termination with partners and suppliers, and, where applicable, notification of authorities and initiation of civil or criminal proceedings.
Art. 10 Reviews & updates
This policy is periodically reviewed to incorporate legal updates and governance best practices, aligned with TSM and The Copper Mark standards.