SECTION IX – OMBUDSMAN
3.21. In order to guarantee the integrity of its operations, the Firm will make an ombudsman’s office available, the purpose of which will be direct and confidential communication between third parties, whether known to the Firm or not, and the Firm, in order to manage any adversity that may arise in the communication and relationship between the aforementioned parties.
3.21.1 The ombudsman can be contacted via the Firm’s website, informing the communicator of:
a) Full name (optional);
b) Company to which they belong (optional);
c) Contact telephone number or e-mail address (optional);
d) A full and detailed description of the complaint, with names, dates, facts and the possibility of attaching documents (mandatory).
3.21.2 The ombudsman will be responsible for:
a) Receive, assess and forward complaints;
b) Provide guidance to communicators, third parties, whether known to the Firm or not, on the Firm’s procedures and regulations;
c) Checking that internal processes are being complied with as previously established;
d) Promoting and resolving suggestions and complaints received in an analytical and objective manner, improving the Firm and mitigating any and all existing adversities;
e) Draw up periodic reports on the demands received and the actions taken to resolve them; and
f) Treating any and all information received in a confidential manner, maintaining the privacy of the communicators.
3.21.2.1 Demands sent to the ombudsman’s office must be made in a clear and objective manner, accompanied, if possible, by the necessary documents for effective and complete analysis.
3.21.2.2 The ombudsman’s office is considered an independent and autonomous body, responsible for capturing, processing, analyzing and responding to demands received, as well as being responsible for maintaining the transparency and confidentiality of the information received and processed.
3.21.3. The ombudsman’s office will operate as follows:
1. Upon receiving a complaint, the Office will forward it to the Office Leader 3, if the complaint is not related to the Office, or, if it is, to the Board of Directors;
2. The Leader or the Executive Board, depending on the case, will draw up a report on the complaint and send it to the Board of Directors; and
3. The Board of Directors shall conduct the investigations and respond to the complaint, in accordance with these Rules.
3.21.3.1 The Board of Directors shall have up to 5 (five) working days to respond to the demand received, except that, in the event of complexity, the resolution of the occurrence may be subject to a deadline extension, without prejudice to informing the communicator.
3.22. It is hereby established that any and all demands received, when found to be untrue, may be subject to all appropriate measures, both to repair the damage caused and to punish the person(s) responsible, following a decision by the Board of Directors.