Whistleblowing Channel

The Whistleblowing Channel of FAS Advogados, in cooperation with CMS, is part of the firm’s internal governance and compliance mechanisms.

Its purpose is to enable the receipt and proper handling of communications related to facts that may constitute:

• Violation of applicable legislation
• Breach of the Code of Ethics and Conduct
• Failure to comply with internal rules and policies
• Commission of an administrative, disciplinary, or criminal offense
• Conduct incompatible with the ethical principles governing the firm’s activities

The Channel applies to partners, lawyers, employees, and third parties acting in connection with FAS, regardless of the nature of their relationship. It may also be used by third parties who maintain or have maintained a professional relationship with the firm.

Professionals affiliated with FAS Advogados must report, preferably through this Channel, any situations that may constitute irregularities or conduct not in compliance with applicable ethical and regulatory standards.

The report may include, among other situations:

• Moral or sexual harassment
• Discrimination
• Conflict of interest
• Corruption or fraud
• Breach of confidentiality or improper use of information
• Non-compliance with internal policies

Reports must be submitted through the Whistleblowing website (button above).

1. Reporting Format

The reporting individual may choose between:

• Identified report: providing their contact details for possible follow-up, or
• Anonymous report: in which case identification will not be required.

In the case of an anonymous report, the reporting individual may choose to monitor the report exclusively through the portal or to register an email address and/or telephone number solely for the purpose of receiving notifications, without such information being shared with the internal Whistleblowing Committee.

2. Completion of the Form

The whistleblower must complete the electronic form with the highest possible level of detail, indicating:

• The nature of the occurrence
• The individuals involved, where applicable
• The location and circumstances of the facts
• Any other information relevant to the assessment

Documents or evidence that may contribute to the investigation may be attached.

3. Protocol and Follow-up

After submission of the report, the system will generate a tracking code, which must be retained by the whistleblower.

By means of this code, it will be possible to check the status of the report in the specific section of the portal.

If an email address or telephone number has been registered, the system may send update notifications. Detailed information regarding the report will not be sent through these channels.

Communications received are initially processed by an independent and specialized company, ensuring the confidentiality of the information and its subsequent referral to the FAS Advogados Whistleblowing Committee for analysis and handling.

Reports will be subject to a preliminary assessment.

Where sufficient elements are identified, internal investigative procedures may be initiated, conducted in observance of:

• The presumption of innocence
• The right to adversarial proceedings and full defense
• The confidentiality of information
• The proportionality of the measures adopted
• Decisions resulting from the investigation fall exclusively within the authority of the firm’s Whistleblowing Committee.

If indications of relevant criminal or administrative offenses are identified, appropriate measures may be taken before the competent authorities.

FAS Advogados ensures the confidentiality of the information received.

Any form of retaliation against a whistleblower acting in good faith will not be tolerated. Reports must be made responsibly and in good faith, in accordance with the ethical principles governing professional conduct.

The processing of personal data within the scope of the Whistleblowing Channel shall comply with Law No. 13,709/2018 (Brazilian General Data Protection Law – LGPD) and other applicable regulations.

Personal data will be processed to the extent necessary for the proper assessment and, where applicable, investigation of the reported facts, with the adoption of appropriate technical and organizational measures to ensure their security and confidentiality.

Contact information for reporting complaints.

55 0800 887 1830
[email protected]