LAST UPDATED: JULY 2026
DM11 holds itself to the highest standards of integrity, ethics and transparency across all of its operations. Corruption is unacceptable, it harms society and the economy, and it destroys reputation. This policy sets out the guidelines we use to prevent, detect and address corruption in all its forms.
This policy applies to DM11's partners, officers, employees, interns and service providers, as well as to suppliers, business partners and representatives acting on the company's behalf.
It complements DM11's Code of Ethics and Conduct and should be read together with it.
Corruption means any unlawful or unethical act involving the misuse of power or influence, including bribery, extortion, kickbacks, influence peddling, nepotism, patronage or any other improper advantage obtained for personal or company benefit.
Stakeholders means all employees, partners, clients, suppliers, business partners and any person or entity that has a relationship with DM11.
Public official includes civil servants, employees and officers of public bodies and state-controlled entities, whether Brazilian or foreign, and anyone exercising a public function, even temporarily.
Compliance with the law. We comply with the anti-corruption laws and regulations applicable in Brazil, including Law No. 12,846/2013, known as the Brazilian Anti-Corruption Law, which holds companies strictly liable for corrupt acts against domestic or foreign public administration, and with any foreign laws applicable to the operations in which we take part.
Prohibition of bribery and kickbacks. We do not tolerate bribery, kickbacks, facilitation payments or any form of improper payment to public officials, clients, suppliers or other stakeholders, whether made directly or through third parties.
Financial transparency. We maintain accurate, complete and auditable accounting and financial records that faithfully reflect the company's transactions and activities. There are no off-book funds or parallel records.
Ethical hiring and procurement. Our hiring and procurement processes are conducted fairly and transparently, with no improper favoritism toward relatives or close contacts of our people.
No employee or third party acting on DM11's behalf may promise, offer or give, directly or indirectly, an improper advantage to a public official or to a person connected to them, in order to influence any act or decision, obtain an advantage or direct business.
Interactions with public officials must be documented and conducted by authorized personnel. Travel expenses, hospitality or courtesies involving public officials are not acceptable where they could influence, or appear to influence, a decision. When in doubt, employees ask before acting.
DM11 provides periodic integrity and anti-corruption training to its people, so that they understand the ethical and legal implications of corruption and can recognize warning signs.
Suppliers and business partners are informed of this policy when they are engaged and are expected to adhere to its principles.
DM11 maintains a confidential channel, accessible to employees and stakeholders, for reporting suspected corruption. Reports may be identified or anonymous and are referred to the Ethics Committee.
All reports are handled confidentially and investigated impartially. We do not allow retaliation against anyone who reports a concern in good faith or cooperates with an investigation.
Reports may be sent to etica@dm11.com.br. Questions about this policy may be sent to contato@dm11.com.br.
Breaching this policy exposes the responsible party to disciplinary action, which may include termination of employment or termination of contracts with suppliers and business partners.
Where the conduct investigated amounts to an unlawful act, DM11 cooperates with the competent authorities and takes the legal measures available to it.
This policy is reviewed periodically to ensure it remains effective and aligned with changes in anti-corruption legislation.
DM11 reaffirms its commitment to a culture of integrity and to a fair and transparent business environment in Brazil.