- Introduction
- Objectives & scope
- Definitions
- Core prohibitions
- Relations with public officials
- Third parties & partners
- Donations & sponsorships
- Accurate books & records
- Training & compliance
- Reporting channel
- Sanctions & enforcement
- Review & governance
Art. 1 Introduction
Committed to the highest standards of integrity, transparency, and accountability, Data Riders developed this Anti-Corruption Policy to reinforce the commitment of all employees, directors, consultants, partners, and third parties acting on behalf of the company. Our objective is to ensure ethical conduct and promote practices that deter any form of corruption, bribery, or improper advantage.
Art. 2 Objectives & scope
- Establish guidelines to prevent, detect, address, and remediate corruption, bribery, and similar conduct.
- Define the obligation to report suspicious behavior and the secure channels to do so.
- Apply to all organizational levels, employees, leadership, consultants, partners, suppliers, and any third party acting on behalf of Data Riders.
- Align with governance requirements under TSM (Towards Sustainable Mining) and The Copper Mark.
Art. 3 Definitions
Offering, promising, or giving anything of value to a public or private official to influence a decision and obtain an improper advantage, or accepting such an offer.
A specific form of corruption involving the exchange of money or benefits to secure a favorable outcome.
Small payments intended to expedite routine procedures, strictly prohibited regardless of amount.
Concealing the origin of illegally obtained money by converting it into legitimate assets.
Any situation in which personal or third-party interests compromise the impartiality of decisions made on behalf of Data Riders.
Art. 4 Core prohibitions
- Offering, promising, giving, or receiving any improper benefit, money, gifts, or favors to influence decisions or gain an advantage.
- Making facilitation payments of any kind, size, or jurisdiction.
- Using third parties (intermediaries, agents, consultants, suppliers) to circumvent this policy.
- Engaging in practices that could be perceived as bribery, kickbacks, or conflicts of interest.
- Participating in money laundering schemes or transactions of suspicious origin.
Art. 5 Relations with public officials
Interactions with public officials, regulators, and state-owned enterprises require additional caution. Always follow the rules of the relevant jurisdiction, formally record interactions, and consult Compliance before offering or accepting any hospitality or gifts. Our Gifts & Hospitality commitment applies fully to public sector interactions.
Art. 6 Third parties & partners
- Conduct integrity due diligence prior to engaging agents, partners, or suppliers acting on behalf of Data Riders.
- Include anti-corruption clauses and audit rights in contracts.
- Require partners to adopt standards consistent with this policy and the Data Riders Code of Ethics.
- Terminate relationships when confirmed violations are identified.
Art. 7 Donations, sponsorships & political contributions
- Donations and sponsorships must be approved in writing by leadership, supported by transparent documentation, and comply with applicable law.
- Data Riders does not make political contributions of any kind, directly or indirectly, in its corporate name.
- Employees' personal political activity is respected, but must not be confused with the company's institutional position.
Art. 8 Accurate books & records
All financial and operational transactions must be recorded accurately, promptly, and with supporting documentation. Records must enable traceability and support internal and external audits to verify the legitimacy of each transaction.
Art. 9 Training & compliance
- Internal training sessions and awareness campaigns on this policy and applicable law take place periodically.
- Resources are allocated for training, audits, and internal investigations.
- New employees and partners undergo anti-corruption onboarding and sign an acknowledgment of this policy.
Art. 10 Reporting channel & investigations
Suspected corruption, bribery, or any policy violation must be reported immediately. Email hi@datariders.com.br with the subject "Anti-Corruption, Report". An independent team handles each report confidentially and with protection against retaliation. When warranted, reports are referred to the competent authorities.
Art. 11 Sanctions & enforcement
Violations may result in suspension, termination for cause, contract termination with partners/suppliers, civil and criminal liability under applicable law (including the Lei Anticorrupção 12.846/2013 and the Código Penal), and notification to the authorities where appropriate.
Art. 12 Review & governance
This policy is reviewed periodically to keep pace with governance best practices and certifications such as TSM and The Copper Mark. Leadership is responsible for promoting an anti-corruption culture and allocating the resources required to sustain it.