Compliance Policies

Updated on November 6th 2025

Blueccone maintains compliance policies aligned with Brazilian Law No. 12,846/2013 and Decree No. 11,129/2022 (integrity programs), the LGPD, the FCPA, the UK Bribery Act, and ISO standards ISO 37001 (anti-bribery) and ISO 37301 (compliance management).

Summary of our compliance policies.

Code of Conduct and Ethics

Professional behavior, respect, inclusion, non-harassment, asset protection, and responsible communication.

Anti-corruption and Anti-fraud

Prohibits direct and indirect bribery, facilitation payments, off-the-books practices, and fraud; requires due diligence, accurate accounting records, and internal controls — aligned with Law No. 12,846/2013, the FCPA, and the UK Bribery Act.

Gifts, Hospitality, and Entertainment

Monetary limits, prior approvals, mandatory recording, and prohibition of inappropriate items, especially when involving the public sector.

Privacy and Data Protection (LGPD/GDPR)

Legal bases, data minimization, purpose limitation, security measures, data subject rights, and the role of the DPO/privacy officer.

Conflicts of Interest

Identification, disclosure, and mitigation; prohibitions on decision-making involving personal benefit.

Competition and Antitrust

No sharing of sensitive pricing information with competitors; no bid rigging; caution in trade associations and market events.

Intellectual Property and Content

Use of licensed sources (fonts, images, videos), trademarks, and software in accordance with contracts; guidelines for generative AI (respect for copyright and confidential information).

Global Trade, Sanctions, and Export Controls

Screening against restricted party lists and international sanctions; refusal of non-compliant transactions. (Based on publicly available global trade materials.)

Information Security

Information classification, least-privilege access, encryption, incident response, and business continuity.

Records Management and Retention

Minimum retention periods and secure disposal, considering legal and contractual obligations.

Internal Investigations and Discipline

Fair, confidential, and non-retaliatory processes; proportionate corrective actions.

Governance and Continuous Improvement

Annual policy reviews;
Audits and control testing;
Effectiveness indicators (for example: training completion, incidents, response times, remediation), in line with ISO 37301.