Compliance Program

FUNDMED Code of Ethics and Conduct

To publicize a FUNDMED ethical and integrity culture, the FUNDMED Code of Ethics and Conduct was released to allow access to the public and to reinforce the FUNDMED Governance commitment to the Compliance Program.

This document defines guidelines for Ethics and Conduct that must be contained in FUNDMED’s activities, regardless of the function or position it occupies, all persons associated in some level to FUNDMED are subject to the FUNDMED Code of Ethics and Conduct such as:

– Boards

– Executive Management

– Employees 

– Supported Institutions

– Researches

– Professors

– Fellows

– Students

– Sponsors

– Commercial and Service Partners

– Any Type of Service Provider

– Other People linked to FUNDMED

Anti-Corruption and Money Laundering Policy

To publish guidelines to combat corruption and money laundering, in accordance with Brazilian Law No. 12,846 / 13, FUNDMED approved through its Executive Board an Anti-Corruption and Money Laundering Policy. This Policy defines the behavior and conduct of all persons linked to FUNDMED’s service, negotiation and activities, even if in the name or for the benefit of FUNDMED. Attached to this policy is the Declaration of a Politically Exposed Person and Conflict of Interest, a registration made for all members of the FUNDMED Governance in order to reduce the risks of compliance.

Ethics and Compliance Communication Channel

FUNDMED has an Ethics and Conduct Communication Channel for questions and complaints about the conduct and ethics of each and every person linked to its activities. The Ethics and Conduct Communication Channel is a service managed by the Ouvidor Digital company, which guarantees the integrity and confidentiality of communications. The FUNDMED Compliance is responsible for taking the necessary measures to analyze and deal with the reported situations.

Compliance Committee

The Compliance Committee promotes FUNDMED’s culture of ethics and integrity. This body has the objective of defining the actions and activities for forming a compliance culture at FUNDMED. It is also responsible for analyzing the supporting documentation for inappropriate and/or illicit conduct that is communicated on the FUNDMED’s Ethics and Compliance Communication Channell,  making decisions on the best solutions and risk mitigations for handling reports. The Committee will have the minimum of personal data of the informers and defaulters persons, decreasing the personality in the conduct of decision making. In order to take administrative measures resulting from the analysis of the reports, the Compliance Committee will use the rules of the Consequences and Anti-Retaliation Standard, resolving discrepancies of different consequences for cases of the same themes.