Donations and sponsorship policy
1 OBJECTIVE
This procedure aims to establish guidelines for managing processes related to granting donations and sponsorships.
1.1 Scope
This document applies to AMAGGI’s business units in Brazil.
1.2 Alterations
– Wording change for better understanding.
– Service flow of the D&P process.
– Updated the definition of sponsorship
– Updated the definition of donation
– Added the item “Basic Principles for Donation and Sponsorship”.
2 DEFINITIONS, TERMINOLOGY AND ACRONYMS
For the purposes of this document, on the subject at the Company, the following are conceptualized as:
Sponsorship: Any contribution (financial or not) to third parties in exchange for some type of benefit (counterpart) that adds value to AMAGGI’s positioning. Counterparts can be, for example, brand exposure, insertion of promotional material in the portfolio of event participants, and assignment of a space to receive customers, among others.
Donation: Any contribution (financial or otherwise) to third parties when there is no benefit in return (compensation). They can be, for example, cultural, social, environmental or sports projects without compensation.
Private Social Investment: It is the planned voluntary use of private resources in projects of public interest. At AMAGGI, private social investments are carried out, not only but preferably, by the André and Lucia Maggi Foundation, through its programs and projects.
Proposal: It is the document presented by the interested party to AMAGGI, containing information for assessing the suitability, granting sponsorship or donation, the policy of donations and sponsorships, and assessing the relevance and impact of the proposal and AMAGGI’s interest in it. When necessary, the proposal must be delivered with all the items determined by AMAGGI, including the project.
Fixed Asset: Tangible assets held for use in the production or supply of goods and/or services, for rent to others, or for administrative purposes, which are expected to be used for more than one period. (Source: CPC 27 Fixed Assets).
3. BASIC PRINCIPLES FOR DONATION AND SPONSORSHIP
It is everyone’s duty to comply with the basic principles in approaching Donations and Sponsorships. These are:
▪ No benefit can be granted to obtain an undue advantage;
▪ Current legislation needs to be fully complied with;
▪ The donation of resources to political parties, political campaigns and/or candidates for political office with company resources is prohibited, according to the legislation in force;
▪ It cannot generate any negative perception that may affect the image of the company or of administrators and employees;
▪ It must be properly accounted for and faithfully represent reality.
Donations or Sponsorships, directly or indirectly, to the Government should only be made if they are in line with social, environmental, educational, and humanitarian purposes, in accordance with AMAGGI’s guidelines, including, but not limited to:
➔ Promotion of community well-being;
➔ Social, educational and environmental protection development; and/or
➔ Contribution to the development of communities, cities, and regions, preferably in places where AMAGGI
operates.
Note: Sponsorship proposals or donations from religious institutions can be benefited or sponsored, as long as they are through structured projects of a cultural, social, health, education, environmental, sports or other nature.
Support that is linked to religious festivities or of a specifically religious nature is prohibited.
3.1 Proposals for sponsorship or donations will not be approved if made by:
• Applicants who do not possess good tax and credit standing.
4. SELECTION OF SPONSORSHIP OR DONATION PROPOSALS
• Proposals must be evaluated based on technical criteria that include, among other aspects, the applicant’s credibility and managerial capacity, suitability, expected results and alignment with AMAGGI’s concept of donation and sponsorship.
4.1 Donation Request
• All Donation requests must be registered in AMAGGI’s internal system (except for intercompany that follow accounting procedures) and approved by the Director of the requesting area;
• The Social Investment area will analyze the merits of the donation and may approve or disapprove of the flow. If approved, it will be sent to the Compliance department;
• The Compliance department will then review the compliance of the beneficiary/recipient according to the internal Integrity Due Diligence procedure. If approved, the process will be completed. If disapproved and the applicant so wishes, it will be forwarded to another director to analyze and approve or not the process as a whole.
4.2 Sponsorship Request
• All Sponsorship requests must be registered in AMAGGI’s internal system and approved by the Director of the requesting area;
• The Corporate Communications area will analyze the merits of the sponsorship and may approve or reject the flow. If approved, it will be sent to the Compliance department;
• The Compliance department will then review the compliance of the beneficiary/recipient according to the internal Integrity Due Diligence procedure. If approved, the process will be completed. If disapproved and the applicant so wishes, it will be forwarded to another director to analyze and approve or not the process as a whole.
5. GRANTING SPONSORSHIP WITH OR WITHOUT INCENTIVES
The Corporate Communications area must guide the internal areas interested in sponsoring projects for individuals or companies, providing technical information about the processes and requirements for sponsorship analysis, and ensuring the application of this Policy.
5.1 Sponsorship Proposal with Incentives
AMAGGI may sponsor projects as long as the items above in this policy are met, framed in legislation or federal, state and municipal incentive funds that allow tax deduction by the supporting company. Proposals may be sent by the end of October of each year to allow analysis by AMAGGI until December of the same year, when there is confirmation of the availability, or not, of resources for projects encouraged.
5.2 Sponsorship Proposal without Incentives
AMAGGI may sponsor projects as long as the items above in this policy are met. Proposed sponsorship requests without incentives must follow the guidelines in item 4.2. Registering the request at least 30 (thirty) days in advance of the project start date is recommended to allow time for analysis. Some examples of sponsorship classified as non-incentive are: fairs or agricultural congresses, symposiums, and events related to AMAGGI’s activities.
5.3 Accountability
5.3.1 The evidence and rendering of accounts must be attached to the Company’s internal system within 45 (forty-five) days after the expected conclusion of the request;
5.3.2 Under no circumstances may the applicant apply the financial resources to Objects other than the one agreed in the Sponsorship Agreement;
5.3.3. Proof of expenses incurred prior to the signature of the contractual instrument will not be accepted;
5.3.4 Proof of expenses incurred prior to the signature of the contractual instrument will not be accepted;
5.3.5 For sponsorship with tax incentives, the applicant must provide financial proof to the public agency that approved the project within the period established by law. Once a proof has been provided to the public body, the applicant must also render accounts to AMAGGI according to the criteria described in item 5.3.1;
5.3.6 Failure to use the investment made by AMAGGI in the project for the intended purpose will result in the sanctions provided for in the sponsorship contract, as well as specific sanctions from Organs and public bodies to which the project was approved for fundraising;
5.3.7 The process will only be considered closed via the system by the Compliance area after analyzing the evidence of effective proof of donation or sponsorship;
Note.: If the applicant identifies that, for reasons beyond their control, they will need a period longer than 45 days to present the rendering of accounts, they must send the request to change the deadline and the justification to compliance@amaggi.com.br of such need for evaluation by the Compliance department.
6. GRANTING OF GOODS DONATIONS AND/OR FINANCIAL RESOURCES
6.1 Donations may be characterized as:
6.1.1 Material goods: Characterized by furniture, equipment, vehicles, books, use and consumption, tools, among others, that no longer meet the company’s needs but that are in good condition and that can be donated to other organizations. Preference will be given to third-sector organizations aligned with the André and Lucia Maggi Foundation.
6.1.2 Donation of perishable and non-perishable food: For this type of donation, it is necessary for the donor unit to safeguard the quality of the donated food (expiry date, conservation status, etc.). In addition, the process of purchasing and acquiring them must be respected by the most appropriate cost center and ledger account for the purpose of controlling external donations.
6.1.3 Financial resources: The request for financial resources will be made through the means described earlier in this norm. Its approval will depend on the resources allocated by the area/unit and on the correct internal procedure for making the donation.
6.2 Fixed Assets Donation
Consult DE-0095 Fixed Assets Management Policy.
6.3 Accountability
For all cases of donations, when applicable, a Donation Receipt must be issued and signed between the parties, which contains the necessary tax data for AMAGGI’s accountability and tax entry.
The beneficiary institution may also forward other documents it deems relevant to the rendering of accounts, whether it be the entity’s own receipt, proof of bank transfer, institutional report, or photos, among others.
7. RESPONSIBILITIES, EXCEPTIONALITIES AND GENERAL PROVISIONS
All employees are individually responsible for ensuring compliance with this document in conjunction with AMAGGI’s Code of Ethics and current legislation and regulations.
Any non-compliance with the guidelines described herein must be reported through AMAGGI’s Confidential Channel on 0800 647 0004 or on the website https://canalconfidencial.com.br/amaggi.
It is the responsibility of immediate managers to ensure that their team receives the necessary guidance to meet the requirements in this document.
8. REFERENCES
• AMAGGI’s Code of Ethics
• PG-0001 Integrity Policy
• DE-0095 Fixed Assets Management Policy
• Direct Action of Unconstitutionality (ADI) 4650, which resulted in the declaration of unconstitutionality of the financing of political parties and electoral campaigns by legal entities.
• Federal Law No. 12,846/2013, known as the Anti-Corruption Law, which provides for the administrative and civil liability of legal entities for the practice of acts against the public administration.
