SECTION IX – OMBUDSMAN
3.21. To ensure the integrity of its operations, the Firm shall provide an Ombudsman, whose objective is to establish a direct and confidential communication channel between third parties—whether known to the Firm or not—and the Firm itself, in order to manage any and all issues that may arise in the course of such relationships.
3.21.1. The Ombudsman may be contacted through the Firm’s website, and the person submitting a report must provide the following information:
- (a) Full name (optional);
- (b) Company or entity (optional);
- (c) Phone number or email address (optional);
- (d) A complete and detailed description of the report, including names, dates, facts, and—where applicable—attached supporting documents (mandatory).
3.21.2. The responsibilities of the Ombudsman include:
- (a) Receiving, evaluating, and forwarding the reports submitted;
- (b) Guiding individuals—whether or not known to the Firm—regarding the Firm’s procedures and regulations;
- (c) Verifying whether internal procedures are being properly followed;
- (d) Objectively and analytically resolving complaints and suggestions, fostering continuous improvement within the Firm and mitigating any existing issues;
- (e) Preparing periodic reports on the reports received and the measures taken;
- (f) Treating all information received with strict confidentiality and preserving the privacy of the individuals involved.
3.21.2.1. Submissions to the Ombudsman must be clear and objective and, whenever possible, accompanied by the relevant documentation necessary for a complete and effective assessment.
3.21.2.2. The Ombudsman is considered an independent and autonomous body, responsible for receiving, analyzing, processing, and responding to the submissions received, and for ensuring transparency and confidentiality in the treatment of information.
3.21.3. The Ombudsman’s procedures shall follow this workflow:
- Upon receiving a report, the Ombudsman will forward it to the Office Leader if the matter is not related to the Firm; otherwise, it will be forwarded directly to the Executive Board;
- The Office Leader or the Executive Board, as applicable, will prepare a preliminary analysis and forward it to the Board of Directors;
- The Board of Directors will then investigate and respond to the report, in accordance with these internal regulations.
3.21.3.1. The Board of Directors will have up to five (5) business days to respond to the submission. In cases of greater complexity, this period may be extended, with the communicator being duly informed.
3.22. It is hereby established that any and all submissions found to be intentionally false or misleading may result in appropriate legal and disciplinary measures, including compensation for damages and sanctions against the responsible party(ies), subject to a final decision by the Board of Directors.