Guiding Principles

Our success rests on the contributions of the directors, officers and employees of UIB companies around the world, who develop and implement plans and actions to achieve the goals set by the group from time to time. In doing so, UIB directors, officers, and employees are required at all times to respect international and national laws and observe the highest standards of integrity in the conduct of the Group’s businesses.

UIB Brasil have adopted these Guiding Principles as an expression of the core values described above.

Integrity

Ethical Behaviour
UIB Brasil will always act in an ethically correct way.

Compliance with the Law
UIB Brasil seeks always to comply with the law in all places where it is present or transacts business. UIB Brasil has a zero tolerance policy towards:–

corrupt behaviour of any kind;
bribery;
economic and financial crime of all kinds; and
fraud (including tax evasion)

in any shape or form, and in particular no one connected with UIB Brasil may offer or accept bribes, or be involved, or facilitate, tax evasion.

Dealings with Regulators and Other Public Administration
UIB Brasil makes full, fair, accurate, timely, and understandable disclosure in reports and documents filed with regulators and all other public authorities throughout the world, as well as in all other public communications.

Transparency of Information
UIB Brasil views transparency as an essential element of UIBN’s relationship with stakeholders, and accordingly UIB Brasil is strongly committed to the production and retention of, accurate and complete information and records, both paper based and all other kinds of record (such as emails).

Business Partners

Client Care
UIBN’s first and foremost concern are its clients. Clients are the focus of everything that UIB Brasil does. The client’s interests always come first.

Client Relations and Service Quality
UIB Brasil responds to ever changing client needs and requirements with speed and care.

Gifts and Entertainment
UIB Brasil while always acting ethically, base all commercial decisions exclusively on commercial criteria. UIB Brasil directors, officers, and employees providing or receiving third party gifts and entertainment when representing UIB Brasil are expected to exercise good judgement in each case, taking into account pertinent circumstances. All expenditure for gifts and entertainment provided by UIB Brasil must be promptly, fully, and fairly recorded in UIB Brasil’s books and records.

Conflicts of Interest
UIB Brasil’s directors, officers, and employees must avoid any actual or apparent conflict between their own personal interests and the interests of UIB Brasil. Companies in UIB Brasil have systems and controls in place to help avoid and deal with any conflict between the interests of UIB Brasil and those of clients, and also as between the interests of multiple UIB Brasil clients should they conflict.

Anti-Money Laundering; Anti-Terrorist Financing; Sanctions
UIB Brasil complies with applicable national and international laws, rules and regulations to prevent, detect and report money laundering and to ensure that UIB Brasil is not involved in financing terrorism. UIB Brasil has processes in place to apply all sanctions rules that apply to UIB Brasil (including when they are linked to deterring terrorist financing).

Antitrust (Competition)
UIB Brasil and its directors, officers, and employees must comply at all times with the antitrust and competition laws of each country or group of countries which are applicable to UIB Brasil’s businesses.

Data Protection
UIB Brasil and their directors, officers, and employees must observe all laws and regulations for the protection of client and personal data applicable to UIB Brasil’s businesses around the group.

Human Resources

Equal Employment Opportunity
UIB Brasil seeks to attract, develop and retain a diverse workforce by providing an inclusive and supportive working environment, and guarantees each UIB Brasil employee equal opportunities to develop without discrimination in all aspects of the employment relationship, including recruitment, hiring, work assignment, work-time allocation, working conditions, training, professional development, promotion, transfer, dismissal, wage and salary administration, and selection for training. UIB Brasil seeks at all times to treat employees fairly and consistently.

Discrimination
UIB Brasil has a policy of zero toleration of any kind of direct or indirect discrimination, including because of race or ethnic origin, gender, beliefs (including religion), politics, sexual orientation, age or disability.

Harassment
UIB Brasil prohibits all forms of harassment in any UIB Brasil workplace, including any form of harassment by or towards employees, clients, suppliers and visitors.

Modern Slavery and Human Trafficking

UIB Brasil has a zero tolerance towards modern slavery and human trafficking, and expects UIB Brasil employees, and those UIB Brasil deals with, to uphold UIB Brasil’s high values.

UIB Brasil is fully committed to ensuring that there is no modern slavery or human trafficking in its supply chains, and that everyone’s fundamental rights are respected.

Privacy
Each UIB Brasil company respects the privacy of the individuals it deals with, in particular that of its employees (but also clients and others), and has procedures in place to comply with all applicable privacy, confidentiality and data protection laws relating to the protection of personal data.

Whistleblowing
Where an individual discovers information which he or she believes shows serious malpractice or wrongdoing within UIB Brasil, it is UIB Brasil’s policy that the information should be disclosed internally without fear of reprisal.

Alcohol and Drug Use
Except where pre-authorised by senior management either to entertain business partners or for staff functions, and then only in limited quantities, UIB Brasil does not permit alcohol to be consumed on UIB Brasil premises. The misuse of legitimate drugs, or with the exception above the use, possession, distribution or sale of alcoholic beverages, or illicit or un-prescribed controlled drugs on UIB Brasil business or premises, is strictly prohibited.

Security
UIB Brasil strives at all times:

to provide all employees, and all others who visit UIB Brasil premises – including third parties who may work with UIB Brasil – with a secure work environment; and
to secure its assets (including its IT systems) from improper interference or use.

Holding Office
UIB Brasil restricts directors, officers and employees from holding office in non-affiliated, for-profit organisations, and prohibits any director, officer or employee from accepting any such office which would, or might, involve a conflict of interest with, or interfere with, the discharge of the director’s, officer’s or employee’s duties to UIB Brasil.

Office in a non-affiliated, for-profit organisation is therefore subject to review and approval by UIB Brasil management.

Company and Third Party Assets

UIB Brasil Assets
UIB Brasil requires its directors, officers, and employees to protect UIB Brasil’s tangible and intangible assets and use them efficiently to advance UIB Brasil’s interests.

Third Party Assets
UIB Brasil’s directors, officers, and employees are required to respect the ownership rights, and intellectual property rights, of third parties.

Bassem Kabban, Chairman, UIB International Ltd
February 2021