Policy on Interaction with Public Agents
GOL maintains the highest level of integrity and transparency in its relations with Government representatives. Thus, to guide our Members in their relations with these professionals, GOL has a Policy on Interaction with Public Agents.
Gifts and Entertainment Policy
GOL's Gifts and Entertainment Policy (“courtesies”) aims to define the conditions for offering/receiving courtesies within its business relationships, explaining concepts, setting boundaries, alerting to points of attention and giving practical examples.
Courtesies may be offered/received in connection with business relationships, subject to GOL's internal policies and procedures and as long as they do not nor appear to be improper advantages.
In general, GOL Members may receive gifts and entertainment when these courtesies:
• Do not appear nor have the purpose of influencing who receives the Courtesy, i.e. they may not appear to be an exchange of favors;
• Are not of excessive value, for example, of more than 1/3 of the minimum wage;
• Are not offered too often;
• Are not in cash or other means easily convertible in cash;
• They are not nor appear to be inappropriate.
Sponsorships and Donations Policy
Sponsorships and donations are the support granted by the Company to initiatives with which GOL identifies. In order for such support to be offered in a transparent manner and to achieve its intended purpose, this policy clearly sets out the guidelines and precautions required when granting such support to third parties.
GOL does not make political donations nor does it allow any third party to make donations in GOL's name and/or interest.
Conflicts of Interest Policy
GOL conducts its activities in a transparent, safe and responsible manner, free from conflicts of interest and consistent with its Values.
The Conflicts of Interest Policy sets out guidelines for avoiding Conflict of Interest situations, i.e. situations in which the private interests of the individual or someone related to them may overlap the interests of the Company.
In this context, it is expected that both GOL Members and any third parties will report any potential conflict of interest situations they identify, so that these situations may be reevaluated and the related risks mitigated.
Policy on Transactions with Related Parties
GOL believes in a fair and transparent market, and therefore has a Policy on Transactions with Related Parties, which aims to provide transparency to such transactions.
Related Parties are the persons or entities with whom the Company has a particular relationship that enables them to negotiate under conditions other than independence, as conditions of negotiation applicable to other parties, by virtue, for example, of their corporate relationships.
To support this objective, GOL requires its suppliers, business partners or other third parties to inform if they become aware of being a Related Party of GOL prior to the conclusion of the business relationship.
Third Party Due Diligence
Due to GOL’s preference to engage with third parties who conduct its activities in accordance with similar ethical principles, GOL conducts Due Diligences on its potential suppliers, representatives, business partners and other at risk counterparties with which it conducts business.
This is done through research and analysis of information and documents aimed at identifying risks related to corruption and ethical-reputational issues arising from the conclusion of contracts, partnerships or other types of associations.