Art. 1 Introduction
Committed to the highest standards of integrity, transparency and responsibility, Data Riders developed this Anti-Corruption Policy to reinforce the commitment of every employee, director, consultant, partner and third party acting on behalf of the company. Our goal is to uphold ethical conduct and promote practices that inhibit any form of corruption, bribery or improper advantage.
Art. 2 Objectives & scope
- Establish guidelines to prevent, detect, handle and remediate corruption, bribery and similar conduct.
- Define the obligation to report suspicious behaviour and the channels available to do so safely.
- Apply to every hierarchy level — employees, leadership, consultants, partners, suppliers and any third party in Data Riders' name.
- Align with TSM (Towards Sustainable Mining) and The Copper Mark governance requirements.
Art. 3 Definitions
Offering, promising or giving anything of value to a public or private agent to influence a decision and obtain an undue advantage — or accepting such offers.
A specific form of corruption, involving the exchange of money or benefits to ensure a favourable outcome.
Small payments intended to speed up routine procedures, strictly prohibited regardless of size.
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 undue benefit — cash, gifts, favours — to influence decisions or obtain 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, kickback or conflict of interest.
- Participating in money-laundering schemes or transactions of suspicious origin.
Art. 5 Dealings with public agents
Interactions with public officials, regulators and state-owned enterprises require extra caution. Always follow the rules of the relevant jurisdiction, record interactions formally and consult Compliance before offering or accepting any courtesy. Our Gifts & Hospitality commitment applies in full to public-sector interactions.
Art. 6 Third parties & partners
- Perform integrity due diligence before contracting agents, partners or suppliers acting on Data Riders' behalf.
- Include anti-corruption clauses and audit rights in contracts.
- Require partners to adopt standards compatible 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 follow applicable law.
- Data Riders does not make political contributions of any kind, directly or indirectly, in its corporate name.
- Personal political activity by employees is respected, but must never be confused with the company's 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 allow internal and external audits to verify the legitimacy of every transaction.
Art. 9 Training & compliance
- Internal training and awareness sessions on this policy and applicable legislation are delivered periodically.
- Resources are allocated for training, audits and internal investigations.
- New hires and partners receive anti-corruption onboarding and sign acknowledgement of this policy.
Art. 10 Reporting & investigations
Suspicions of corruption, bribery or any policy violation must be reported immediately. Write to [email protected] with the subject "Anti-Corruption — Report". An independent team handles every report confidentially, with protection against retaliation. When justified, reports are escalated to competent authorities.
Art. 11 Sanctions & enforcement
Violations may result in suspension, termination for cause, contractual termination with partners/suppliers, civil and criminal prosecution under applicable law (including Brazilian Lei Anticorrupção 12.846/2013 and the Penal Code), and notification to authorities when appropriate.
Art. 12 Review & governance
This policy is reviewed periodically to follow governance best practices and certifications such as TSM and The Copper Mark. Leadership is responsible for promoting an anti-corruption culture and for allocating the resources needed to sustain it.