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INTERNAL POLICY OF
REPORTING CHANNEL
Internal policy of the D´GOLD reporting channel:
1. INTRODUCTION
This document defines guidelines for the functioning of the organizational component of the “reporting channel” and for communicating information or situations that:
a) Indicate signs of illegality, of any nature, related to the institution’s activities;
b) Affect the reputation of controllers holding qualified holdings and members of statutory and contractual bodies.
2. PROVISION OF COMMUNICATION CHANNEL:
AD´gold DTVM, provided the communication channel through which employees, collaborators, customers, users, partners or suppliers can communicate, without the need to identify themselves, situations with signs of illegality of any nature, related to the institution's activities.
3. THE REPUTATION OF CONTROLLERS, DETECTORS OF QUALIFIED PARTICIPATION AND MEMBERS OF STATUTORY AND CONTRACTUAL BODIES
AD´GOLD DTVM must communicate knowledge or access to information about situations or occurrences that may affect the reputation of controllers, holders of qualified holdings and members of statutory and contractual bodies such as:
a) Criminal proceedings or police investigation to which the people mentioned in the previous paragraph or any company of which they are or were, at the time of the events, controllers or administrators are responding;
b) Judicial or administrative process, which is related to the natural financial system;
c) Other similar situations, occurrences or circumstances.
4. REPORTING CHANNEL:
The reporting channel is free and provided at:
(Insert the address of the reporting channel page)
5. REPORTING PERIOD – REPUTATION:
Communications about information or situations that affect the reputation of people indicted in item 3 of this document must be made within ten business days of becoming aware of or accessing the information.
6. CONFIDENTIALITY OF THE REPORTER:
The Reporting Channel, in addition to ensuring confidentiality, provides its employees, customers, partner users and general suppliers with confidentiality in communications and reports.
7. ORGANIZATIONAL TREATMENT COMPONENT:
The Organizational Component must be formed with at least 03 members, 02 statutory directors, and 01 manager, designated by the board (compliance or human resources manager), of the institution who will be responsible for handling complaints, ensuring confidentiality , independence of action, impartiality and impartiality. The procedures for using the communication channel referred to in the caput must be set out in specific regulations and published on the D'GOLD DTVM website, on the internet.
8. MONTHLY REPORT:
The institution's compliance area will prepare a semi-annual report, referencing the base dates of June 30th and December 31st, containing at least the number of reports received according to expectations, the nature, the competent areas, the treatment of the situation, the average term and the measures adopted by the institution. The report must be approved by the board of directors and kept available to the Central Bank of Brazil for a minimum period of five (5) years.
9. CURRENT REGULATIONS:
Resolution N: 4,859 of October 21, 2020.
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