Anti-corruption/Copyright Policy

Anti-corruption Declaration:

HEDGE SOCIAL and its administrators do not practice, authorize or tolerate any act considered as forbidden or improper by anti-corruption and money-laundry legislation, what includes all enforced Brazilian legislation on the subject, as well as the U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery Act, the USA PATRIOT Act, OFAC regulations, or anti-corruption and money-laundry legislation and regulations from any other jurisdiction. HEDGE SOCIAL hereby represents, warrants and agrees that:

(i) in the course of any contract, one will permanently conduct the supplied services in full compliance to the law;

(ii) in the course of any contract – or in any time – no OFFICIAL AGENT [1] or immediate relative of Official Agents have any financial interest or advantage on and/or from any service provided by HEDGE SOCIAL, direct or indirectly, neither as shareholder, partner, owner, nor from any other connection;

(iii) HEDGE SOCIAL did not and will not provide, direct or indirectly, any payment, fee, donation in cash or any other financial way, goods or valuable gifts to the benefit of any Official Agent and-or direct relative.

HEDGE SOCIAL’s Partners are professionally trained in anti-corruption and money-laundry matters and are available to submit themselves to special trainings provided by the CLIENTS. HEDGE SOCIAL Partners warrant the formal commitment of any associate consultant to the full accomplishment of this Policy.

Copyrights

Reports, presentations and other products of the supplied services under contract are CONTRACTING PART’s exclusive properties, being HEDGE SOCIAL and its representatives forbidden to divulge their contents, under any circumstance, without formal written authorization by the CLIENT. The only exceptions, in which the copyright remains with HEDGE SOCIAL refer to:

(i) didactical and training materials, including didactic texts, brochures and books, class presentations, pedagogic methodologies and similar.

(ii) templates, models and other methodological products that are suitable to be applied to more than one client/service, including audit-charts, score-cards, check-list models, matrixes and other tools, proprietary algorithms for quali-quantitative data/information treatment, and similar.

HEDGE SOCIAL renounces to any authorship of the Clients’ proprietary data included in reports, presentations or any other materials produced under contract, conceding to the CONTRACTING PART the full allowance to the full or partial use of the products, according to the Client’s interest and will.

Confidentiality

HEDGE SOCIAL and its representatives involved in the services commit themselves, totally and under the penalties of the Law, to keep total confidentiality on all information disclosed by the CONTRACTING PART, or on any other information and data obtained and-or produced during the execution of the contracted services.

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[1] For all purposes of the Policy, “Official Agent” shall be defined as any authority, managerial person, employee or person whose acts are made on behalf of: (i) any agency, department, institute, foundation or any other institution belonging totally or partially by the Government (including, with no limitation, any entity controlled or supported by foreign governments); (ii) any public international organization; (iii) any political party, and or their representatives; and (iv) any candidate running for any political position, by election or nomination.