Compliance Procedures:
A copy of the Code will be made available to all ITBrahma representatives upon beginning service with the Company and representatives will be expected to read and understand the Code. The Code also will be accessible electronically. ITBrahma representatives may be required on a periodic basis to submit a written acknowledgement to the effect that they have read and understand this Code, and understand their obligations to abide by it and to report any violations. Any general questions regarding the Code may be presented to managers or the Human Resources Department. Questions regarding specific guidelines in this Code should be addressed to the Human Resource Department, the Legal Department or the persons or departments identified in the guideline at issue. Any revisions or updates to this Code will be published and appropriately distributed.
The Chief Compliance Officer shall take all necessary steps to monitor and investigate violations of this Code and, where appropriate, impose and enforce disciplinary measures. Representatives are expected to cooperate fully, truthfully and candidly with all Company investigations into potential violations of this Code or any Company policies, practices, or applicable laws. ITBrahma management shall periodically report to the Board of Directors, or a committee thereof, regarding its compliance efforts, including investigations, violations of the Code and discipline imposed.
Reporting Concerns and Violations
All employees are required to recognize the critical importance of legal compliance and the Company's commitment to ethical conduct. Any employee having information, knowledge or suspicion of any actual or contemplated action which is, or appears to be, in violation of this Code, any other Company policy or any applicable law or regulation, is required to report the matter promptly. Failure to report a violation of this Code or any applicable law or regulation may be considered a violation in itself. In most instances, an employee should report such conduct to his or her manager. If the employee does not feel comfortable raising the issue to his or her manager, the employee can contact the Chief Compliance Officer or the Legal Department. Any manager receiving a report must promptly notify the substance of such report to the Chief Compliance Officer. In addition, employees may anonymously report suspected violations of this Code, any other Company policy or practice, or any applicable law, rule or regulation, including, but not limited to, those involving accounting, internal accounting controls, or auditing matters, by calling the ITBrahma Ethics and Compliance Line at 080-42676000. It is against ITBrahma policy to retaliate against any individual based upon their reporting in good faith of an actual or perceived violation of this Code.
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