Effective Date: January 1, 2025
Last Updated: January 1, 2025
At NBR. Company Ltd. (“NBR”), integrity, compliance, and ethics are not optional—they are core to our DNA and embedded into every facet of our operations. This Compliance & Ethics Policy (“Policy”) defines the standards of conduct expected from all employees, contractors, executives, partners, and affiliates who represent or engage with NBR. It ensures that we operate in alignment with global legal frameworks, ethical best practices, and our own uncompromising corporate philosophy.
1. Purpose and Scope
- This Policy applies to all divisions, subsidiaries, and affiliates of NBR worldwide.
- It governs all business conduct, consulting engagements, technology development, financial advisory, and strategic operations.
- Its purpose is to:
- Protect the reputation, integrity, and trust of NBR.
- Ensure compliance with global laws, regulations, and internal directives.
- Establish a clear framework of ethical behavior for all stakeholders.
2. Core Ethical Principles
NBR requires adherence to the following fundamental values:
- Integrity: Always act truthfully, transparently, and honorably.
- Confidentiality: Safeguard all sensitive client, partner, and internal information.
- Compliance: Obey all applicable laws, including anti-bribery, anti-money laundering, competition, labor, and data protection regulations.
- Accountability: Accept responsibility for actions, decisions, and outcomes.
- Respect: Treat all clients, employees, and partners with professionalism, fairness, and dignity.
- Excellence: Commit to quality, precision, and innovation across all services.
3. Legal & Regulatory Compliance
- NBR employees and affiliates must comply with:
- Local and international laws (including anti-corruption, export controls, and tax compliance).
- Industry regulations (financial services, cybersecurity, data protection, and consulting frameworks).
- Client-specific obligations as outlined in contracts or statements of work.
- Violation of legal or regulatory obligations may result in disciplinary action, termination, and referral to law enforcement authorities.
4. Anti-Bribery and Anti-Corruption
- NBR enforces a zero-tolerance policy on bribery and corruption.
- No NBR employee or representative may:
- Offer, give, request, or accept bribes or improper payments.
- Facilitate transactions through unethical inducements or “kickbacks.”
- Use intermediaries, agents, or third parties to disguise improper conduct.
- All business dealings must be transparent, documented, and auditable.
5. Conflicts of Interest
- Employees and affiliates must avoid any situation where personal interests conflict with the interests of NBR or its clients.
- Examples of conflicts include:
- Accepting gifts or favors from vendors or clients beyond nominal value.
- Holding financial interests in competitors, suppliers, or clients without disclosure.
- Using confidential company information for personal gain.
- Any potential conflict must be immediately disclosed to compliance officers.
6. Confidentiality and Information Security
- All proprietary, client, and corporate information must be treated as confidential.
- Unauthorized disclosure, misuse, or negligence regarding sensitive data is strictly prohibited.
- NBR employs cybersecurity and risk intelligence standards aligned with international frameworks (ISO, NIST, CIS).
- Employees are obligated to report any suspected data breach or information leak immediately.
7. Data Protection and Privacy
- NBR complies with data protection regulations such as GDPR (EU), LGPD (Brazil), CCPA (US), and similar global standards.
- Personal data must only be collected, processed, and stored for legitimate business purposes, with explicit consent where required.
- Employees must follow secure handling, encryption, and retention protocols for client and internal data.
8. Fair Competition and Anti-Trust
- NBR competes fairly and does not engage in anti-competitive practices.
- Prohibited behaviors include:
- Price fixing, bid rigging, or collusion with competitors.
- Sharing sensitive client or market data without authorization.
- Abuse of market dominance to restrict fair competition.
9. Workplace Ethics and Conduct
- NBR fosters a culture of inclusivity, respect, and equal opportunity.
- Harassment, discrimination, bullying, or retaliation of any kind is not tolerated.
- Employees must uphold professional behavior in all interactions, both in-person and online.
- NBR supports whistleblower protections—anyone reporting misconduct in good faith will be shielded from retaliation.
10. Financial Integrity
- All financial transactions and reporting must be accurate, transparent, and compliant with accounting standards.
- Fraudulent activities, misrepresentation of expenses, and unauthorized use of company assets are prohibited.
- NBR reserves the right to audit, monitor, and investigate financial activity to ensure compliance.
11. Environmental and Social Responsibility
- NBR commits to sustainability and responsible business practices.
- Environmental impact must be considered in all operations, consulting, and development projects.
- We prioritize energy efficiency, responsible resource use, and corporate social responsibility (CSR) initiatives.
12. Enforcement and Disciplinary Action
- Violations of this Policy may result in:
- Internal disciplinary measures, including termination of employment or contracts.
- Legal action or reporting to relevant authorities.
- Financial restitution in cases of misconduct, fraud, or damages.
- NBR enforces this Policy through audits, compliance reviews, and continuous monitoring.
13. Reporting Violations
- Employees, clients, and partners are encouraged to report any suspected violations of this Policy.
- Reports may be made confidentially via email to compliance@nbr.company.
- NBR will investigate all reports thoroughly and fairly, maintaining strict confidentiality and whistleblower protection.
14. Continuous Improvement
- This Policy will be reviewed regularly to reflect changes in law, regulation, and best practices.
- All employees will undergo periodic training to remain aligned with compliance and ethics standards.
- Feedback from clients, employees, and stakeholders will be integrated into compliance improvement initiatives.
15. Contact Information
For questions regarding compliance, ethics, or reporting concerns, please contact:
NBR. Company Ltd.
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📧 compliance@nbr.company
