LEGAL INDEX / 004  ·  HOME / ANTI-CORRUPTION PRACTICES

Anti-Corruption Practices.

Specific rules to prevent, identify and fight any form of corruption and bribery, ensuring compliance with Law No. 12,846/2013 (Brazilian Anti-Corruption Law).

A zero-tolerance policy applied to all WDA STUDIO MIDIAS INTERATIVAS LTDA collaborators and partners.

LEGAL / DEFINITIONS

Applied terminology.

Corruption: the act of offering, promising, giving, accepting or requesting any undue advantage to influence the action of a person in a position of trust.

Bribery: the offer or acceptance of any payment, gift, favor or advantage to obtain or grant undue benefits or privileges.

Zero-Tolerance Policy: any employee or collaborator involved in such practices will be subject to severe disciplinary measures, including dismissal for cause and communication to the competent authorities.

LEGAL / SPECIFIC RULES

Seven operational pillars.

/ 4.1GIFTS
Gifts & Hospitality
It is prohibited to offer, give, request or accept gifts, hospitality or any other benefit that may influence, or be perceived as capable of influencing, business decisions. Modest gifts and occasional hospitality may be accepted or offered when they do not exceed a reasonable value and cannot be interpreted as bribery.
Applies to everyone
/ 4.2POLITICAL
Political Contributions
Any political contribution on behalf of WDA ag must be approved by senior management and comply with applicable law. Employees are prohibited from using company resources to make personal political contributions.
Approval required
/ 4.3DONATIONS
Donations & Sponsorships
All donations and sponsorships must be transparent, properly recorded and approved by senior management. Donations or sponsorships that may be interpreted as an attempt to influence business decisions or obtain undue advantages are prohibited.
Full transparency
/ 4.4THIRD PARTIES
Hiring Third Parties
Before hiring any third party, including suppliers, consultants or partners, due diligence must be performed to ensure that they are not involved in corrupt practices. All third-party contracts must include anti-corruption clauses.
Due diligence
/ 4.5TRAINING
Training & Awareness
All employees and administrators must participate in periodic training on anti-corruption and anti-bribery practices. The company must promote continuous awareness of the importance of compliance with anti-corruption laws.
Active cadence
/ 4.6CHANNEL
Reporting Channels
WDA ag provides secure and confidential reporting channels so employees, partners and third parties can report suspected corrupt practices. All reports will be investigated impartially and rigorously, with protection against retaliation.
Confidential & impartial
/ 4.7AUDIT
Audits & Monitoring
Regular internal audits are conducted to ensure compliance with anti-corruption policies. Continuous monitoring systems are implemented to identify and mitigate corruption and bribery risks.
Continuous

LEGAL / RESPONSIBILITIES

Who is responsible.

01
Senior Management
Ensure implementation of and compliance with anti-corruption policies, promoting a culture of integrity and transparency throughout the organization.
02
Legal Department
Provide support in interpreting anti-corruption laws and conducting report investigations, ensuring the appropriate legal process.
03
All Employees
Strictly comply with these rules and report any suspected violation of anti-corruption policies. Responsibility is collective.

LEGAL / CONCLUSION

Integrity as practice.

WDA ag reaffirms its commitment to ethics, integrity and legal compliance.

These specific rules on anti-corruption and anti-bribery practices are an essential part of our mission to conduct business honestly and transparently, contributing to a fairer and more trustworthy business environment.

Report suspicions with confidence.

Secure and confidential channel. Protection against retaliation is guaranteed.

agencia@wda.ag