Anti-Corruption Policy


The purpose of this document is to reinforce and standardize the commitment of Profits Consultoria e Soluções Tecnológicas Ltda, or Profits Consulting, as referred to below in this document, to maintain the highest standards of integrity, ethics and governance in the conduct of its business by establishing guidelines for combating corruption both in relation to public institutions and private companies.

It also aims to ensure that Profits Consulting’s partners, administrators, employees and third parties comply with the requirements of Brazilian legislation, in particular, but not limited to the Anti-Corruption Law (Federal Law No. 12,846/13), Decree No. 8,420/15 and other regulations applicable laws, such as the Foreign Corrupt Practices Act (FCPA) and the United Kingdom Bribery Act.

This document corroborates the guidelines and standards of the Profits Consulting Code of Ethics and, therefore, both must be followed in their entirety, aiming to prevent, mitigate and remedy any corruption risks.


This document covers all legal representatives, partners, administrators, employees of all hierarchical levels, subsidiaries, all third parties, suppliers, subcontractors, consultants, service providers, customers and any other association.


For the purposes of this document, the terms below are understood as follows:

  • Administrators: directors and partners;
  • Public Agents: those who exercise public functions, temporarily or permanently, with or without remuneration, by election, appointment, designation, hiring or any other form. This category also includes mixed companies;
  • Government Authority: any body, entity, authority, agency, autarchy, foundation, commission, council or Brazilian or foreign governmental department, from any sphere of its respective government or any party contracted, directly or indirectly, by the public power;
  • Gifts: items with no commercial value or with market value, with the intention of giving another party, such as money, gifts, travel, entertainment, offers, among others;
  • Collaborator: any natural person, such as employees and interns, who provide services of a non-continuous nature, that is, recurring and routine, to Profits Consulting, under its dependency and salary;
  • Competitors: companies operating in markets and economic segments of Profits Consulting;
  • Conflict of interests: any situation that represents a conflict between the personal interests of an internal part of the company, which may, in a concrete or apparent way, compromise, influence or stimulate, in an improper or improper way, the performance of the functions of the same, to the detriment of of the interests of Profits Consulting;
  • Corruption: the act of giving, promising, offering, authorizing, requesting or receiving in exchange, directly or indirectly, for oneself or another party, an undue advantage, whether pecuniary or otherwise, for any other party to take away , act or fail to act in accordance with the law, ethics, morals, good customs, appropriate practices or good faith. There is no tolerance for such acts;
  • Family members: parents, spouses, children, siblings, grandparents, in-laws and first cousins;
  • Intermediary: any person, natural or legal, other than the final recipient or the originator, who acts in such a way as to conceal his destination;
  • Third parties: any natural or legal person who is not an internal part of Profits Consulting, such as administrators and collaborators, even if they temporarily help in the performance of its activities, such as partners, representatives, suppliers, consultants, service providers and service and the like.

Rules and Guidelines

Profits Consulting does not allow or tolerate any acts or practices of corruption, bribery, payment or receipt of bribes, whether with public, mixed or private parties, national or foreign, based on Brazilian and international laws.

It is also considered, under the terms of this policy, attempted acts, even if not completed, on an equal basis with consummated acts.

All parties involved must unrestrictedly value ethics and transparency in the conduct of all their activities, performing them professionally and with integrity, always aiming at the best interest of the company, regardless of any advantage offered by other individuals.

The parties involved are committed to always guiding others to strictly follow this policy.

Conflict of Interests

All parties to Profits Consulting must act in order to prevent, prevent and remedy situations that may cause or suggest conflicts of interest in relations between any party, internal or external.

In order to mitigate potential conflicts of interest, Profits Consulting instructs its administrators and collaborators to inform the conditions in which their family members or close people hold positions or public functions in entities, autarchies or public bodies with which they may or may not interact in the performance of its activities, which must be done in advance, in accordance with good practices.


All internal parties at Profits Consulting are prohibited from accepting, offering or suggesting any type of advantage, such as gifts, to any other party, whether public, mixed or private, in order to influence or encourage their decisions or obtain their own benefit or for the company.

Other Guidelines

Regarding participation in biddings, Profits Consulting is subject to and will comply with the legal provisions of the Bidding Law (Brazilian Law No. 8,666/13), State-Owned Companies Law (Brazilian Law No. 13,303/16), the Anti-Corruption Law, the rules of the bidding in question and the contractual clauses signed with the bidder.

Any evidence or suspicion of illegal actions, such as, however, not limited to: money laundering, kickbacks, gifts, facilitation or political participation must be immediately informed to Profits Consulting via the email channel


Any and all communication relating to this document or topics mentioned in it must be communicated to Profits Consulting through the email channel