GOL, in its relationships, bases itself on principles that underpin an organizational culture focused on valuing people, acting in accordance with our internal procedures and regulations, and constantly seeking development. Regarding internal Compliance guidelines, the Company defines its performance expectations through clear and transparent internal policies and procedures, and disseminates them to all those to whom they apply.
The Company is committed to maintaining high standards of Corporate Governance; therefore, the Ethics Committee has the support of Senior Leadership to promote a culture of ethics and compliance with applicable laws in its daily operations at all levels of the Company.
GOL has a comprehensive and transparent Code of Ethics that seeks to provide guidance on matters related to Ethics and Values that govern the Company's activities. This code is applicable to all members of the company, that is, both employees at all hierarchical levels and members of the Statutory Committees, the Fiscal Council, the Board of Directors, and its shareholders, in the exercise of their functions or duties.
GOL expects these principles to be followed by all its business partners. Compliance with the Code demonstrates a commitment to professionalism and transparency in all our actions at work.
GOL prioritizes relationships with third parties who conduct their activities in accordance with ethical principles similar to its own. Therefore, all third parties must follow the Code of Conduct for Third Parties during their relationship with the Company.
These guidelines aim to formalize GOL's firm commitment to acting ethically and to publicly express its repudiation of corruption of any kind. Commitment to ethical conduct and compliance mechanisms to inhibit and punish misconduct is essential for third parties to maintain partnerships with GOL.
We are against corruption in all its forms and strive to ensure the highest level of integrity and ethics in our activities. To clarify its commitments, concepts, and main related risks, GOL has an Anti-Corruption Policy, in addition to others, as detailed below. In its Anti-Corruption Policy, the Company reiterates the prohibition of bribery and other acts harmful to Public Administration, such as damaging the competitive nature of any bidding process, obstructing or hindering investigations or audits by Public Officials, or using third parties to conceal its true interests in its dealings with public bodies.
GOL, being a Brazilian company with shares listed in the United States, is subject to the Brazilian Anti-Corruption Law (Law 12.846/13) and the American Foreign Corrupt Practices Act (FCPA), whose prohibited acts are described in the Anti-Corruption Policy.
GOL maintains the highest level of integrity and transparency in its relationships with representatives of Public Agencies. Therefore, to guide our employees in their interactions with these professionals, we have a Policy for Interaction with Public Officials.
In its interactions with Public Officials, GOL adopts a position of strict compliance with the law and reinforces the guidelines established in this Policy.
GOL's Gifts, Presents and Hospitality Policy aims to define the conditions for offering/receiving courtesies within its business relationships, explaining concepts, defining limits, highlighting points of attention and giving practical examples. Courtesies may be offered/received within the scope of business relationships, observing GOL's internal policies and procedures, and provided that they are not or do not appear to be undue advantages. In general, GOL employees may receive gifts, presents or hospitality when these courtesies:
Do not appear to influence the recipient of the courtesy, i.e., do not seem to be an exchange of favors;
Are not of excessive value, such as exceeding 1/3 of the minimum wage;
Are not offered excessively frequently;
Are not in cash or other means easily convertible into cash;
Are not or do not appear to be inappropriate.
GOL conducts its activities in a transparent, safe, and responsible manner, free from conflicts of interest and consistent with its Values.
The Conflict of Interest Policy defines guidelines to avoid situations of conflict of interest, that is, situations in which the private interests of an individual or someone related to them may override the interests of the Company. In this context, it is expected that both GOL employees and any third party will report any potential conflict of interest situations they identify, so that these situations can be reassessed and the related risks mitigated.
We believe in a fair and transparent market, which is why we have a Related Party Transactions Policy aimed at providing transparency to these types of transactions. Related Parties are individuals or entities with whom the Company has a specific relationship that allows them to negotiate on conditions that are not independent, as other partners negotiate, due to, for example, their corporate relationships.
To support this objective, GOL requires its suppliers, business partners, or other third parties to inform us if they are aware of being a Related Party of GOL before entering into a commercial relationship.
Because GOL prefers to engage with third parties who conduct their activities according to ethical principles similar to its own, it performs a prior analysis (Due Diligence) of its potential suppliers, representatives, business partners, and other counterparties with whom it conducts business.
This procedure is carried out through research and analysis of information and documents aimed at identifying risks related to corruption and ethical-reputational issues arising from the execution of contracts, partnerships, or other types of associations.