Code of Conduct and Anti-Bribery/Anti-Corruption Policy
WolkenHai is committed to the highest ethical standards and integrity. This Code of Conduct and Anti-Bribery/Anti-Corruption Policy establishes clear guidelines for preventing, detecting, and responding to illicit practices, reinforcing our commitment to legality, transparency, and respect for our clients, partners, and society.
Pillars
1. Unconditional Integrity
All our actions are guided by strong ethical principles, regardless of the context or complexity of the decisions. At WolkenHai, integrity is not a choice — it's a lifelong commitment.
2. Compliance and Transparency
We strictly comply with applicable laws, regulations, and standards in all markets where we operate. We promote transparency in our processes and relationships, ensuring clarity and institutional accountability.
​3. Zero Tolerance for Corruption
We reject any practice of bribery or undue favoritism. Our processes follow strict controls to ensure that all business is conducted legally, fairly, and is auditable.
Code of Conduct and Anti-Bribery/Anti-Corruption Policy
Executive Summary
WolkenHai is committed to the highest standards of ethics and integrity. This Code of Conduct and Anti-Bribery / Anti-Corruption Policy establishes clear guidelines to prevent, detect, and respond to illicit practices, reinforcing our commitment to legality, transparency, and respect for our clients, partners, and society.
1. General Principles of Conduct
All employees, partners, consultants, and representatives of WolkenHai must:
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Act with honesty, integrity, and professionalism in all business relationships.
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Comply with all applicable laws, rules, and regulations in Brazil, the United States, and any other jurisdictions where WolkenHai operates.
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Protect confidential information belonging to the company and its clients.
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Avoid conflicts of interest and practices that could compromise WolkenHai’s reputation.
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Treat everyone with respect, promoting an ethical, diverse, and inclusive work environment.
2. Anti-Bribery and Anti-Corruption Policy
2.1. Prohibition of Bribery and Corruption
It is expressly prohibited to:
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Offer, promise, authorize, or grant any undue advantage to any person, whether in the public or private sector, with the purpose of obtaining favoritism or improper benefit.
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Request or accept any type of payment or benefit that may influence professional decisions.
2.2. Relationship with the Public Sector
Any interaction with public officials must:
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Be transparent and properly documented.
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Comply with applicable legal and ethical standards.
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Receive prior approval from the executive leadership when it involves payments, gifts, or sponsorships.
2.3. Gifts, Tokens, and Hospitality
It is permitted to offer or receive gifts of low symbolic value, provided that:
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There is no intention to influence decisions.
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They comply with local customs and internal policies.
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They do not represent a conflict of interest.
2.4. Donations, Sponsorships, and Political Contributions
WolkenHai does not make political donations or sponsorships aimed at obtaining improper advantages. Philanthropic donations must be authorized by leadership and follow transparency and traceability standards.
2.5. Third-Party Due Diligence
Suppliers and commercial representatives must:
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Undergo a due diligence process prior to engagement.
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Agree to the terms of this policy.
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Be monitored for compliance with anti-corruption practices.
3. Training and Awareness
All WolkenHai employees undergo onboarding that includes specific training on this Code, which is reinforced every six months. Refresher sessions, talks, and internal campaigns promote continuous alignment with our values.
4. Reporting Channel
WolkenHai maintains a secure and confidential channel for reporting any violations:
All reports will be treated confidentially, with no retaliation against individuals who report concerns in good faith.
5. Consequences of Violations
Failure to comply with this Code may result in disciplinary measures, including termination for cause, contract termination, and notification to the appropriate authorities.
6. Review and Updates
This Code will be periodically reviewed to ensure its effectiveness and alignment with applicable laws.