Fundação Brasileira para o Desenvolvimento Sustentável
  • Environmental Assets
    Projects and studies on sustainable development by means of the conscious use of natural resources.
  • Sustainable Agriculture
    Projects and interface between different actors to
    create reliable and sustainable agriculture.
  • Urban Sustainability
    Projects which seek to address the sustainability of large urban centers in the medium and long term.

The Foundation

FBDS' Operational Procedures - Rio de Janeiro, January 4, 2021

Ethical Guidelines and Code of Conduct


This document presents FBDS's Ethical Guidelines and Code of Conduct (the "Guidelines"). It was prepared based on several similar documents publicly available1 combined with our own values. The Guidelines are not meant to be comprehensive but rather to set minimum standards that we expect the organisation, its executives, employees, collaborators, and subcontractors to be bound to.

To achieve its mission FBDS is supported by several grantors from around the world. These Guidelines also contains the rules of conduct for the persons involved in implementing and managing all aspects of the grants as they perform their work for, or on behalf of, the grantor.



FBDS's Ethical Principles derive from universal values such as respect, justice, loyalty, reliability, truthfulness, and the notion that one should treat others as oneself would like to be treated.



FBDS is not-for-profit, nongovernmental, organized, independent, self-governing, and voluntary organization.

Mission and Activities

FBDS's mission ("To promote the use of market mechanism to facilitate compliance with social and environmental laws") is what it hopes to accomplish and is the purpose for which the organisation exists. It is the foundation and the frame of reference for all our activities and organisational planning. We utilise the resources made available to the organisation in an effective and efficient manner towards the accomplishment of its stated purpose and counteract any abuse in the use of these resources towards people in vulnerable situations.

Transparency and Accountability

FBDS strives for openness and honesty internally and towards its staff, donors, partners, suppliers, collaborators, and the public.

Truthfulness, Legality, Anti-bribery and Fraud

FBDS will be honest and truthful in its dealings with its donors, project beneficiaries, staff, membership, partner organizations, subcontractors, government, and the public in general, and will respect and encourage respect to the laws of any jurisdiction in which it is active. FBDS repudiates corruption and bribery at all levels as well as fraud and the misuse of aid funds - refer to FBDS's Anti-Bribery and Corruption Policy.

Human Rights and Dignity

FBDS supports the Universal Declaration of Human Rights2 and believes that its activity should be carried out without discrimination based on race, gender, social status, sexual orientation, disability, religious or political affiliation, etc., see Equality Policy.

Furthermore, FBDS believes that children and vulnerable adults should be protected from physical or sexual or emotional abuse and neglect, refer to FBDS'sSafeguarding Policy.


Please refer to FBDS's Environmental Policy.

Employee Relations

FBDS also supports the ILO Declaration on Fundamental Principles and Rights at Work3 and repudiates any form of sexual abuse, sexual exploitation and harassment.

Duty to Act

FBDS's executives, employees, and collaborators are bound to this Guidelines while acting on behalf of the organisation and are encouraged to promote the Guidelines in their day-to-day activities as well as to inform the appropriate channel (refer to FBDS'sWhistle-Blowing Policy) any apparent or actual deviation from it within the organisation or with our suppliers, collaborators, partners, etc. FBDS will ensure the appropriate follow-up procedures if deviations occur.

These Guidelines are part of the FBDS's employees' conditions for employment as well as an integral part of consultants and collaborators contracts. Violations of these guidelines may result in warning, consideration of dismissal/termination/exclusion, or to handing over of the case to the relevant authorities.


FBDS understands that the development of ethical guidelines are an inclusive and ongoing process and will provide periodic training to develop and strengthen its ethical competence and awareness at all levels.

Anti-Bribery and Corruption Policy


The board and staff members of FBDS are committed to a zero-tolerance policy on bribery and corruption in any form, recognising that bribery is contrary to fundamental values of integrity, transparency and accountability and undermines organisational effectiveness.


The Board is responsible for overseeing the policy and bribery and corruption risks or incidents are a standing item on Board meeting agendas, to be dealt with at each Board meeting.


FBDS understands corruption as an abuse of power and/or position for advantage. We recognise its serious negative effects on individuals and society as a whole and as such, are committed to combating it.

A bribe is understood by FBDS as the offering, promising, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organisation's activities. This includes offers or gifts for friends and family as well as for the individual and includes "facilitation fees".

Risk Assessment

Incidents of bribery and corruption include, among others, the following:

  • Official processes, such as obtaining a visa, permit or registration document. Officials may request a "facilitation fee" or other informal payment. In particular, customs and immigration: officials may demand extra payments to allow a person to travel
  • Relationships with clients. Examples may include:

    • Requests by clients to participate in or lead on proposals in return for favours
    • Requests by clients to intercede with third parties in return for favours
    • Requests by clients to ignore evidence of bribery or corrupt practice in their work
  • Consultants and service delivery. Examples may include:

    • Requests for special consideration in choosing a consultant/service delivery provider
    • Offers of favours for accepting inflated prices or other unfavourable contract options
  • In all the above cases, FBDS staff members may face conflicts of interest. FBDS's conflict of interest policy is attached here and all staff members should adhere to it.

Possible risks in relation to such incidents include:

General context: FBDS works around the world and as such our staff, consultants or part are encouraged to be vigilant of the risks of receiving or offering bribes or other corrupt practices. This can pose a threat to the organisations and the people who work for them directly, themselves, and also to FBDS, which has a responsibility to prevent bribery.

FBDS's own procedures: In addition to its relationships with various clients, areas in which FBDS could be vulnerable include recruitment, procurement, transactions with the authorities and the development of work in a new region or country where we are less familiar with the context. These are addressed in existing policies, but attention must be paid in risk reviews that the procedures are up to date, appropriate and put in practice.

Consequences for FBDS: The organisation could be subject to prosecution under Brazil law if it does not ensure that it acts against corruption cases. There could also be serious impacts on FBDS's reputation if it is perceived as accepting, condoning or turning a blind eye to corruption.

Details on risks are included in FBDS's risk register and kept up to date by the FBDS's management team. The Board should review the risk register at each meeting.


FBDS has the following instruments in place to reduce the risk of corruption occurring:

  1. Protection of staff members against corruption risks:

    • Ensuring that all staff members are fully informed about the anti-bribery and corruption policy and procedures as well as the conflict of interest policy and are able to put them into practice.
    • Providing regular learning sessions to support staff in responding to corruption incidents and developing appropriate strategies to deal with particular situations as they arise.
    • Ensuring that all staff members, when on FBDS business, have papers and permissions in order and carry a document stating FBDS's zero tolerance stance Ensuring that all clients and contractors are fully informed about FBDS's zero tolerance of corruption.
  2. Due diligence

    FBDS undertakes to carry out a bribery and corruption risk assessment when it enters a contracting relationship with another entity and a due diligence assessment against that risk, including verifying whether the entity has and puts into practice its own anti-bribery policies. This will be repeated at periodic intervals.
  3. Dealing with corruption incidents

    The procedures in dealing with incidents of corruption are as follows:

    1. If a staff member encounters a direct or implicit request for a bribe or favour or an offer of a bribe or favour:
      • Say "no": In all cases, except if a person's health or security are at risk, the response to any attempt at bribery or corruption should be to refuse and to reiterate FBDS's policy of zero tolerance.
      • Internal report: Any bribery incident needs to be reported internally. Incidents should be reported to your line manager and, if it is serious, to the team as a whole. (Serious incidents are those in which the person attempting corruption does not accept the "no" immediately, when someone's health or security is put at risk, or when attempts to corrupt occur more than once by the same individual or institution). All incidents should be recorded on the relevant page in the risk register.
      • Investigation: Any serious case of corruption should be investigated. This applies when a staff member has been at risk and so has had to comply with a demand or when a staff member has managed to resist a demand but has suffered delay, disruption, abuse or inconvenience as a result. It also applies when one or more staff members report incidents with the same individual or institution, i.e. when it appears that there is a pattern of corrupt practice occurring.

        The investigation should involve the line manager and at least one other member of the FBDS team, who will interview the person or people concerned within a maximum of two weeks of the incident being reported and support them to analyse the incident. The team produces a short written report that is then immediately shared with the Board. The report must include analysis of how and why the incident occurred and make recommendations as to how procedures can be strengthened so that a staff member is not put in that situation again. The investigation interview should also include a check on the staff member's welfare and identification of their support needs around any trauma or distress resulting from the incident.

        If the investigation team has the impression that the staff member was willingly complicit with the corruption incident, then the procedures outlined in 3.3 below will apply.
      • Inform others: Information about incidents in which a staff member has been threatened or at risk or when there appears to be an institutionalised pattern of corruption should be shared with other actors: clients, donors, partners and other collaborating organisations and individuals. As much information as is compatible with the continued safety of the staff member and of other parties affected by but not complicit in the corruption that might be at risk should be divulged so that others can also take action in response.

        Whenever it is possible without endangering staff members or clients, FBDS should also report the incident to the relevant authorities in order to enter the incident on the official record and to stimulate action against corruption. FBDS recognises that this is not always possible: the authorities can sometimes be complicit in the corruption themselves.

        Options such as whistleblowing hotlines should be explored as reporting mechanisms if this is the case.
    2. If a staff member identifies corrupt practice on the part of a client, contractor or other party with whom FBDS is associated

      This may include evidence or suspicion of a range of issues that could include, among others, financial mismanagement, trafficking influence, bribery and nepotism. If a staff member has identified such practice in a client, contractor or other organisation, they should immediately report it to their line manager and the rest of the team. FBDS should then investigate the reported incident, with a view to confirming whether corruption has taken place and if so, what the circumstances were.

      If the investigation identifies that corruption has taken place, a short report should be written and recorded on the risk register. Following identification of an incident, FBDS must take action. The exact response will depend on the particular circumstances and the severity of the case, but it could include:

      • Confronting them directly with the incident and, if they acknowledge it, discussing with them how to avoid such incidents in the future. (This is only appropriate for one-off incidents in exceptional circumstances).
      • If it is an individual, reporting them to their line manager or senior management in their organization.
      • Supporting the organisation to come up with appropriate procedures and responses to prevent such an incident happening again.
      • Ending collaboration or support agreements with the organisation concerned.
      • In the most serious cases, reporting the incident to the authorities or relevant institutions. Context must be borne in mind when exploring this option: it could expose the person, organisation and people associated with them to extremely serious consequences.
      • In the most serious cases, reporting the incident to other organisations or individuals that work with the individual/organisation, to warn them of the risks.
      • If the incident includes the complicity of a Brazilian organisation or an international organisation engaged in any commercial activity in Brazil, FBDS should also report it to the competent authority, unless to do so would expose someone to serious threats to their health or security. If the latter is the case, FBDS should ensure that it has documented the incident and has explored all possible avenues to report and tackle the incident.
    3. If a staff member identifies corrupt practices on the part of a colleague

      This may include evidence or suspicion of a range of issues that could include, among others, financial mismanagement, trafficking influence, bribery and nepotism. If a staff member has identified such practice in a colleague, they should immediately report it in confidence to their line manager or to a Board member. FBDS should then immediately investigate the reported incident, with a view to confirming whether corruption has taken place and if so, what the circumstances were.

      If the investigating team identify that corruption has taken place, immediate action must follow, using the appropriate disciplinary procedures. The consequences for the staff member, depending on the severity of the incident and the circumstances, could range from suspension to dismissal to criminal prosecution. Records of the incident and the responses will be kept in FBDS's confidential personnel records.

      If the incident concerns senior management or the board, the staff member may also choose to report it to an external competent authority.

Dissemination and communication

FBDS's zero tolerance statement should be cited into contracts, memoranda of understanding and other contractual arrangements.

FBDS will support its collaborators and partners (if feasible and realistic) to look at their own anti-corruption practice and to develop their own appropriate responses to incidents of bribery and corruption.

Monitoring and evaluation

All reported incidents are included in the risk register document.

The risk register and corruption incidents are frequent features of management team meeting agendas.

The Board reviews the risk register at regular intervals and reviews responses when relevant. Once a year, the President of the Board of Trustees reviews all corruption incidents that occurred during the year and reports on these to the Board. If patterns emerge that demonstrate that risks need to be re-evaluated, this is done so.

Collective action

FBDS commits to sharing information on bribery and corruption with other organisations with a view to combating it wherever it occurs.

Conflict of Interest Policy

FBDS recognises that many potential conflicts of interest arise as a result of its work. Through the application of our policy on conflict of interest, we attempt to identify and manage conflicts that do arise systematically. We also undertake to monitor the implementation of this policy to ensure that conflicts of interest do not compromise the integrity and objectivity of our work.

Conflict of interest is addressed at two levels:

  • Individual employees, collaborators, and subcontractors;
  • FBDS as a whole.

Individual conflicts of interest


  • A requirement for proper management of conflict of interest by each member of staff, including notifying FBDS directors of any potential conflicts, is included in the terms of employment which forms part of every contract.


  • All subcontractors are required to assure the proper management of conflict of interest, including notifying FBDS directors of any potential conflicts.

FBDS conflicts of interest

As part of the project planning process, before accepting the terms of reference for an individual contract, the project manager considers any potential conflicts of interest. In particular, consideration must be given to potential conflicts arising from:

  • Past, on-going or future work with the same client;
  • Past, on-going or future work with a different client;
  • The declared interests of the project team and any other staff likely to be involved in the project.

If any potential conflict is identified:

  • A director and/or senior manager must be informed;
  • Measures to remove or manage the potential conflict must be identified;
  • The identified measures must be implemented.

If, after the implementation of the identified measures, a potential conflict is likely to remain which could affect FBDS's ability to deliver the terms of reference, FBDS will formally notify the client before accepting the contract.

Whistle-Blowing Policy


This document presents FBDS's Whistle-Blowing Policy (the "Policy"). It was prepared based on several similar documents publicly available combined with our own concerns4.

Employees, collaborators, and subcontractors are often the first to realize that there may be something seriously wrong within an organisation. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organisation. They may also fear harassment or victimization. In these circumstances, it may be easier to ignore the concern rather than report what may just be a suspicion of malpractice.

This policy aims at encouraging employees, collaborators, and subcontractors to feel confident in raising serious concerns and to protect them from possible internal reprisals or victimization if they have a reasonable belief that they have made any disclosure in good faith.

Reporting responsibility

We encourage employees, collaborators, and subcontractors to raise any serious concerns that they have about any aspect of service provision or the conduct of its board members, executives, employees, collaborators, and subcontractors of the organisation or others acting on behalf of the organisation.

Examples of concerns may be related to: fraud, corruption, bribery, unauthorized use of public funds of grants, blackmail, criminal offences and breach of law, endangering the heath or the safety of an individual, endangering the environment, sexual of physical abuse, unethical conduct, etc., for more information refer to FBDS'sAnti-Bribery and Corruption Policy.

Harassment or victimization

We as an organisation recognize that the decision to report a concern can be a difficult one to make. If what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer, grantor, and those for whom you are providing the service.

The management will not tolerate any harassment or victimization (including informal pressures) and will take appropriate action to protect you when you raise a concern in good faith.

All concerns will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At the appropriate time, however, you may need to come forward as a witness.

Anonymous complaints may be made through correspondence sent to the Chairman of the Board of Trustees and/or Vice-Chairman of the Board of Trustees and/or Executive Director, who will take the necessary measures to investigate the facts that have occurred.

Untrue allegations

If you make an allegation in good faith, but it is not confirmed by the investigation, no action will be taken against you. If, however, you make an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against you.

How to raise a concern

As a first step, you should normally raise concerns with your immediate manager. This depends, however, on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice.

FBDS's President of the Board of Trustees has overall responsibility for the maintenance and operation of this policy. He will maintain the records of concerns raised and the outcome and will report as necessary to the board.

If you do intend to raise the matter outside the Organisation, you should take into account the disclosure of confidential information.

Concerns may be raised verbally or in writing. Staff who wish to make a written report are invited to use the following format:

  • The background and history of the concern (giving relevant dates).
  • The reason why you are particularly concerned about the situation.

How will the organisation respond

The organisation will respond to your concerns. Do not forget that testing out your concerns is not the same as either accepting or rejecting them.

Where appropriate, the matters raised may:

  • Be investigated by management, internal audit, Grievance Procedure disciplinary process.
  • Be referred to an external auditor.
  • Form the subject of an independent inquiry.
  • Be referred to the police.

Grievance Procedure


It is the aim of FBDS to create a positive working environment for all its employees. It is therefore FBDS's policy to ensure that employees with a grievance relating to the employment can use this procedure to resolve issues as quickly and as fairly as possible.


Grievances are concerns, problems or complaints raised by a staff member in relation to issues such as their working conditions, line management, relationship with colleagues or behaviour of colleagues. In many cases, these problems can be addressed and resolved informally through ongoing working relationships and we always encourage staff to raise any problem informally with your line manager or entity director before invoking a formal grievance procedure. However, where informal discussions do not resolve the problem, or the matter is of a serious nature and it is inappropriate to address informally then it is important that we have an efficient and effective formal grievance mechanism that aims to address and resolve the issue. Refer to FBDS's Safeguarding Policy.

Formal Grievance Procedure

All grievances will be dealt with sensitively and with due respect for the privacy of any individuals involved. All employees should treat as confidential any information and communication in connection with any part of the grievance process unless and until there is agreement from all affected parties to share it.

The formal grievances process should normally be concluded within one month of the grievance being raised. FBDS will use its best effort to resolve the grievance as speedily as possible and adhere to the timescale given above wherever possible. However, where this is not possible due to the need for further investigation or lack of availability of witnesses or staff involved in the process, time extensions may be necessary. Any additional time requirement will be explained clearly to the staff member who raised the grievance.

ResponsibilitiesThe administration of FBDS will ensure that the application of this procedure is implemented fairly and consistently. To ensure consistency, where possible a Director of FBDS will be involved at all stages of the grievance process and document the whole process. He will also make sure that any action agreed is implemented, monitored and reviewed.

Grievance submission
A formal grievance must be put it in writing and submitted to one of the following:

  • The President of the Board of Trustees: this is the normal process and should be followed where the grievance does not involve the President of the Board of Trustees.
  • the Executive Director: this is the process that should be followed where the grievance relates - directly or indirectly - to the President of the Board of Trustees.

When raising a grievance, employees should include the following information:

  1. indicate that it is a formal grievance;
  2. detail any relevant facts, dates and names or individuals involved;
  3. provide information on any informal discussions that have already taken place or action that has already been taken to try to resolve the issue;
  4. where possible, indicate their preferred resolution.

Grievance acknowledgement

Where the grievance is submitted, receipt acknowledgement of grievance should be issued in writing.

Preliminary Review meeting

Within days of receipt of a grievance, a preliminary review meeting amongst the relevant FBDS management, either physically or via a video conference, should be organised to discuss the approach to investigating and resolving the grievance.


In some cases, it may be necessary for an investigation to be carried out into the grievance. The investigation should be led by the individual who receives the grievance, supported relevant FBDS management. It may involve taking statements from employees or any relevant witnesses or reviewing relevant documents.

Grievance Meeting

Following receipt of a grievance letter, the individual who receives the grievance will invite the employee to attend a formal grievance meeting, which can take place physically or via a video conference, normally within 10 working days, or as soon as possible. The employee has the right to be accompanied by a colleague to the formal meeting provided they make a reasonable and timely request.

The following individuals will normally attend the Grievance meeting:

  • the employee who raised the grievance;
  • the Executive Director;
  • the President of the Board of Trustees or, if the grievance relates to the President of the Board of Trustees, one or more FBDS Board members (if needed or requested);
  • An external HR expert (if needed).

During the meeting the employee is given the opportunity to explain their grievance and how they think it should be resolved. The outcome of any investigation is shared and discussed. Options of how to resolve the issue in a mutually acceptable way are discussed and, if possible, agreed.

If a final decision cannot be made at the time of the formal meeting, the individual who received the grievance should tell the employee when they might reasonably expect a decision and what action they will take to help resolve the issue. If a further grievance meeting is considered appropriate, this will be arranged without unreasonable delay.

Outcome and Agreed Action

The outcome of the grievance meeting can be communicated verbally if a decision is made at that time, but will always be confirmed in writing within a reasonable period of the grievance meeting (or final grievance meeting where more than one meeting has taken place). The employee should be notified of their right to appeal against the outcome.

Disciplinary Policy

Statement of Policy

The aim of the FBDS Disciplinary Policy is to help and encourage employees to improve, achieve and maintain standards of conduct, attendance and job performance. It also enables management to deal effectively with those employees who do not comply with the Organisation's code of conduct, attendance and performance in the workplace. Equally, the policy and procedure are designed in a manner which is non-discriminatory and which is fair, consistent and effective. It must also be applied in a timely manner and without undue delay.

All Managers have a responsibility for ensuring that employees are made aware of the Disciplinary Policy and Procedure. All employees are to be informed of the standards of conduct and work performance expected of them and Managers should ensure that these standards are fully understood by those who work to them.

Matters relating to or arising under the Disciplinary Policy and Procedure must be treated as confidential at all times. Failure to do so may itself constitute grounds for initiating disciplinary action.

Key Principles

At each stage of the Disciplinary Procedure attached to this policy, the employee has a right to be accompanied by an work colleague. The employee will also be informed in writing of:

  • The nature of the complaint or allegation against them; and
  • The stage at which the matter is being considered.

The employee will also be reminded that they will be given a full opportunity to state their case and if action is taken, what improvement is required. They will also be reminded of their right of appeal.

Managers whose responsibilities require them to participate in or hold disciplinary meetings will be given appropriate training to enable them to undertake their role effectively and dispassionately.

Employees should make every effort to attend meetings or interviews relating to the application of the Disciplinary Procedure. If the employee fails to attend such meetings more than once without compelling reasons, then meetings may be held in the employee's absence. Where this measure is invoked, the employee will be informed of this in writing.

Those responsible for making arrangements under the Disciplinary Policy and Procedure must ensure that any necessary, reasonable adjustments required by the employer or other attending have been addressed. This may relate to disability or to the requirements of religious beliefs.

Should an employee have an objection to the person or persons appointed to investigate or hold meetings in connection with the disciplinary matter they must raise this objection in writing, clearly stating the reasons to the Executive Director. Such objection must be made within two working days of the notification about the matter under investigation being brought to their attention.

The nature of the disciplinary action taken will be determined according to the nature and seriousness of the alleged misconduct and a dispassionate assessment of the facts based on the balance of probabilities. The Organisation's Disciplinary Policy and Procedure will not apply to any employee who is in their period of probation.

Data relating to the application of this Policy and Procedure will be held and/or destroyed in accordance with the provisions of current data protection regulations.

In accordance with the current equality legislation, this procedure will not discriminate, either directly or indirectly, on the grounds of gender, race, colour, ethnic or national origin, sexual orientation, marital status, religion or belief, age, trade union membership, disability, offending background or any other personal characteristics.

Equality Policy

Policy Statement

FBDS recognises that discrimination and victimisation is unacceptable and that it is in the interests of the Organisation and its employees to utilise the skills of the total workforce. It is the aim of the Organisation to ensure that no employee or job applicant receives less favourable facilities or treatment (either directly or indirectly) in recruitment or employment on grounds of age, disability, gender / gender reassignment, marriage / civil partnership, pregnancy / maternity, race, religion or belief, sex, or sexual orientation.

Our aim is that our workforce will be truly representative of all sections of society and each employee feels respected and able to give of their best. To that end the purpose of this policy is to provide equality and fairness for all in our employment.

All employees, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.

Our staff will not discriminate directly or indirectly, or harass customers or clients because of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation in the provision of the FBDS's services.

This policy and the associated arrangements shall operate in accordance with statutory requirements and the Brazilian Legal Framework.

Our Commitment

  • To create an environment in which individual differences and the contributions of all our staff are recognised and valued.
  • Every employee is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.
  • Training, development and progression opportunities are available to all staff.
  • To promote equality in the workplace which we believe is good management practice and makes sound business sense.
  • We will review all our employment practices and procedures to ensure fairness.
  • Breaches of our equality policy will be regarded as misconduct and could lead to disciplinary proceedings.

Responsibilities of Management

Responsibility for ensuring the effective implementation and operation of the arrangements will rest with the Executive Director. Managers will ensure that they and their staff operate within this policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination.

Each manager will ensure that:

  • all their staff are aware of the policy and the arrangements, and the reasons for the policy;
  • grievances concerning discrimination are dealt with properly, fairly and as quickly as possible;
  • proper records are maintained.

Responsibilities of Staff

Responsibility for ensuring that there is no unlawful discrimination rests with all staff and the attitudes of staff are crucial to the successful operation of fair employment practices. In particular, all members of staff should:

  • comply with the policy and arrangements;
  • not discriminate in their day to day activities or induce others to do so;
  • not victimise, harass or intimidate other staff or groups who have, or are perceived to have one of the protected characteristics.
  • ensure no individual is discriminated against or harassed because of their association with another individual who has a protected characteristic.
  • inform their manager if they become aware of any discriminatory practice.

Third Parties

Third-party harassment occurs where a FBDS employee is harassed, and the harassment is related to a protected characteristic, by third parties such as clients or customers. FBDS will not tolerate such actions against its staff, and the employee concerned should inform their manager/supervisor at once that this has occurred. FBDS will fully investigate and take all reasonable steps to ensure such harassment does not happen again.

Equality Training

Regular briefing sessions will be held for staff on equality issues. These will be repeated as necessary. Equality information is also included in induction programmes.


FBDS deems it appropriate to state its intention not to discriminate and assumes that this will be translated into practice consistently across the organisation as a whole. There will also be regular assessments to measure the extent to which recruitment to first appointment, internal promotion and access to training/development opportunities affect equal opportunities for all groups.

We will maintain information on staff who have been involved in certain key policies: Disciplinary, Grievance and Bullying & Harassment. The information collected for monitoring purposes will be treated as confidential and it will not be used for any other purpose.


Employees have a right to pursue a complaint concerning discrimination or victimisation via the Organisation Grievance or Harassment Procedures. Discrimination and victimisation will be treated as disciplinary offences and they will be dealt with under the Organisation Disciplinary Procedure.

Safeguarding Policy

Scope of this Policy

Safeguarding is term with a broad definition. We adopt the following definition: our objective is to protect the rights of all people who FBDS interacts with to live in safety, free from abuse and neglect. This applies equally to all people, regardless of gender, sexuality, religion, disability, ethnic origin or age.

FBDS has a suite of policies and internal documents that exist to ensure that we safeguard those who we come in to contact with, including FBDS Ethical Policy, Health and Safety, Anti-Fraud and Corruption Policy, the FBDS Terms of Employment, Code of Conduct, Grievance Procedure and Whistle-blowing Procedure.

This policy is therefore focused primarily on our approach to keeping people safe from bullying, harassment, sexual exploitation and abuse. It should be read alongside the broader suite of policies listed above.


At FBDS we will not tolerate any representative of FBDS, whether our employee, consultant, contractor or partner carrying out any form of bullying, harassment, sexual exploitation and abuse.

In particular, we commit to:

  • Create a safe and trusted working environment which safeguards anyone FBDS has contact with, including beneficiaries and staff
  • Ensure our culture is one where all those who we work with, and all those who work for us feel empowered to insist on non-discriminatory and respectful behaviour from each other
  • Ensure that there are safe and trusted channels through which people can raise any issues of concern
  • Ensure all concerns and allegations are responded to in a timely and appropriate manner
  • Ensure all staff and managers are familiar with organisational policies relating to safeguarding, and understand their responsibilities via the induction and training
  • Take robust action if problems arise in the observation of this policy and relevant employment and criminal laws
  • Ensure our consultant, contractor and partner are aware of safeguarding standards that FBDS expect on them
  • Be transparent with our partners about any issues we face

Policy Guidance

All FBDS staff and representatives should:

  • Act in accordance with the requirements of the FBDS Code of Conduct and take responsibility for their own actions.
  • Treat all those they come in to contact with on behalf of FBDS with dignity and respect, and to refrain from any behaviour that falls within the definitions of bullying, harassment, sexual exploitation and abuse, both in and out of the workplace, such as on business trips, events or work related social functions.
  • Consider whether their words or conduct could be offensive. Even unintentional harassment or bullying is unacceptable.
  • Not have any sexual contact with children under the age of 18 (or older if local law specifies), or engage in sexual relationships with staff, partners or any beneficiaries of FBDS projects or programmes of FBDS through an abuse of a position of power (including line management relationships, and funding relationships).
  • Report in line with this policy any instances or suspicions of inappropriate behaviour they experience or witness by FBDS employees, contractors, clients or partners, unless disclosed to them confidentially by a victim who does not wish them to disclose.
  • Disclose any instances or suspicions of inappropriate behaviour that involve a child (under 18 years unless older in any applicable jurisdiction) or a vulnerable adult.

Managers should be made aware of any consensual relationships they may develop with other FBDS colleagues over whom staff hold a position of power (e.g. direct reports or within chain of line management) and ensure that no abuse of power or conflict of interest is allowed to occur.

Safe Programming

Where projects or programmes will work directly with communities or individuals we will ensure FBDS staff and representatives observe the requirements of Code of Conduct to minimize the risk of unintended harm, and we will ensure that mechanisms exist and are publicized to enable those we work with to raise and concerns and provide any feedback they wish to. If a specific project or programme is undertaken that will involve direct work with vulnerable adults or children specific measures for that project or programme will be designed to ensure that risk is appropriately managed.

Procedure to raise and handle complaints and concerns

  • Anyone can raise a concern or make a complaint to FBDS about something they have experienced or witnessed. It is possible to make a complaint verbally or in writing.
  • People external to FBDS can raise an issue by writing into any management level FBDS personnel.
  • Internally, issues can be raised through the usual line management chain, directly at a more senior level if appropriate. The current process is set out in Grievance Procedure.
  • FBDS is committed to responding to all concerns raised, and to ensuring that those raising complaints have confidence in and control over how complaints are investigated and handled. The only exception to this is where a concern is raised about a vulnerable adult or child's treatment, where an investigation will always be undertaken, and confidentiality of those raising a concern cannot be guaranteed.
  • FBDS is committed to ensuring that no employee who raises a genuine issue under this policy will be subject to victimization or be disadvantaged in any way.
  • All the complaints will be dealt with sensitively and with due respect for the privacy of any individuals involved. Any employee who is found to have contravened FBDS's expectations about their conduct will be subject to disciplinary action that may result in dismissal. Contractors may have their relationship with FBDS terminated. Partners will be expected to take appropriate action against their own staff, and any ongoing relationship with the partner cannot involve any individuals found to have breached expectations.
  • Any instances of criminal misconduct (dependent on the laws of that specific jurisdiction) will be reported to the relevant authorities, subject to the consent of the victim. The only exception to this is where an incident involves a vulnerable adult or a child, where incidents or suspicions must always be reported to relevant authorities.
  • FBDS is committed to meeting its legal, statutory and contractual obligations of reporting safeguarding issues. When safeguarding issues occur relevant donors and regulators will be informed of the outcome of investigations in line with their requirements.


Board of Directors has ultimate responsibility for safeguarding and should always act in the best interests of the beneficiaries and staff, including:

  • developing and reviewing safeguarding policies and procedures; reviewing management of safeguarding issues and risks through a standing agenda item in regular meetings and the risk register update.
  • carrying out thorough and prompt investigation if allegation occurs; taking disciplinary action against staff where there are breaches of code of conduct.
  • reporting safeguarding issues to the relevant donors and regulators in line with the requirements.

Executive Director is responsible for ensuring the application of this procedure is implemented fairly and consistently. He will also focus on recruitment of the qualified people and provide induction and refresher training to staff and management on safeguarding.

Management teams are responsible for ensuring the policy and procedures are operating effectively within their areas of responsibility.

Every member of staff and representative is responsible for implementing the policy and procedures.

Environmental Policy

FBDS aims to understand and minimize the impact on the environment by means of the continuous development and implementation of this policy.

We are especially committed to:

  1. Identify, on continuous basis, the environmental risks of our operations and define activities in order to minimize any negative impact on the environment;
  2. Review and update, on regular basis, our Environmental Policy guide.

Areas at risk to the environment:

The areas below have been identified as those in which there is a risk that our operations may have a negative impact on the environment:

  1. Daily office and operations activities (power, water, garbage, commuting);
  2. Trips (emissions related to transportation, lodgings);
  3. Acquisition of products and services;
  4. Externalities associated with the projects.

Environmental Management Guidelines

  1. Daily office and operations activities

    In FBDS daily operations, we aim to reduce consumption and minimize waste and, whenever possible, reuse or recycle. We will:

    • Monitor and periodically analyze the amount of paper, energy and water being used;
    • Encourage the use of reusable products (packaging, bags, glasses, etc.);
    • Recycle office supplies and equipment whenever possible, including: the waste of paper, cardboard, glass, plastic, cans, printer cartridges and batteries. In case it is not possible to reuse, the products will be properly disposed;
    • Use low-pollution cleaning products whenever possible;
    • Use low solvent inks whenever possible when printing FBDS publications material;
    • Energy efficiency will be taken into account in all purchases of electrical equipment;
    • Actively reduce energy consumption in the office by encouraging lights and electrical equipment to be turned off;
    • Encourage employees and visitors to use public transportation, bicycles or walk to the office, providing clear information about options.
  2. Trips
    • Trips should be organized, in every possible way, in order to minimize domestic and international flights.
    • In regions where there is a good railway infrastructure, trips by train rather than by plane should be considered and encouraged.
    • When booking hotels, preference should be given to those that, within the same price range, comply with international sustainability standards and minimize environmental impacts.
  3. Acquisition of products and services

    As long as the requirements of price, quality and technical specifications are met, FBDS will give preference to:

    • Suppliers that actively seek to minimize environmental impacts in their activities.
    • Products that have minimal environmental impact and that support the sustainable use of natural resources, including locally produced food products and products certified by reliable standards.
    • Products that are FSC certified, in the case of wood-based products such as paper, furniture, printing materials (business cards, brochures, reports, etc.).
  4. Externalities associated with the projects

    As the mission of the FBDS is to promote sustainable development and protection of the environment in all spheres of society and the Brazilian economy, the Foundation is committed to not implementing projects that have negative environmental or social consequences.

Personal Security Policy

FBDS aims to establish and maintain, in every possible way, a working environment and working conditions and practices that do not jeopardize the health and safety of our employees, visitors, contractors and public members.

That includes:

  • providing adequate control of any health and safety risks arising from work activities;
  • providing maintenance of all equipment;
  • ensuring the safe handling and use of equipment;
  • ensuring that all employees receive the information, instructions and training necessary to enable them to safely carry out their work activities;
  • ensuring the prevention of accidents and cases of work-related health problems.


Employees have a duty to act with due care for their own health, safety and well-being as well as the health of their colleagues and other contacts; report all accidents or potentially dangerous situations and comply with the instructions issued on safe work procedures, fire and first aid.

Employees must cooperate with the following actions:

  • Comply with the FBDS health and safety instructions and, in the event of a fire or simulated fire, act accordingly;
  • Make sure that the entrances, exits, stairs and corridors are not blocked in any way that could cause a risk of fire, thus preventing people from leaving the building easily;
  • Cooperate with the line manager on health and safety issues;
  • Do not interfere with anything provided to protect your health and safety;
  • Take reasonable care of your health and safety and the safety of others who may be affected by your actions or omissions;
  • Immediately report all health and safety concerns to the line manager; reporting any accident or injury as soon as it happens to your line manager, and filling out an accident report.

Safety Actions against Fire

Any team member who sees evidence of a fire or other emergency should raise the alarm to indicate evacuation from the facility. In the event of an emergency, leave the premises by the nearest fire outlet and move directly outside the workplace. Employees will not return to the office until they are authorized by the FBDS Director present at the location.

General well-being

To ensure a healthy work environment and keep our workplace safe, FBDS provides:

  • bathrooms and washbasins, with soap and towels or hand dryer;
  • drinking water;
  • a place to store clothes;
  • a place to rest and have meals;
  • good ventilation in the office;
  • a reasonable working temperature in the office;
  • adequate lighting for the work to be done;
  • adequate space, workstations and adequate seats;
  • a clean workplace with suitable waste containers;
  • work facilities and equipment properly maintained;
  • unobstructed floors and traffic routes;
  • windows that can be opened.

Purchasing and Contracting Regulations

Fundação Brasileira para o Desenvolvimento Sustentável - FBDS (Brazilian Foundation for Sustainable Development), a private non-profit legal entity, registered as CNPJ number 40.390.569/ 0001-25, headquartered at Av. Rio Branco nº 81, 14th floor (part), Centro, CEP 20040-004, Rio de Janeiro, RJ and office at Rua Engenheiro Álvaro Niemeyer nº 76, São Conrado, CEP 22610-180, Rio de Janeiro, RJ, establishes and makes public its PURCHASING AND CONTRACTING REGULATION, which becomes effective for the cases of Partnership Terms, Agreements, Contracts and other covenants by this Foundation's initiative.

Chapter I - On The Objetives

Art. 1st - The main objective of this Regulation is to ensure that the purchases and contracts to be carried out by FBDS are the most advantageous for the Foundation and, consequently, for society in general. It also considers efficiency, agility and transparency in its actions and projects.

Chapter II - On The Principles

Art. 2nd - This Regulation aims at ensuring the compliance with the principles of equality, legality, impersonality, morality, publicity, economy, efficiency and objective judgment in the processes of purchasing goods and hiring services of any nature.

Chapter III - On The Aplicability

Art. 3rd - This document establishes the procedures to be adopted by all FBDS Administrators, Managers, Consultants and Administrative Staff for the purchase of any goods and contracting of works and services carried out by this Foundation.

Art. 4th - The rules for purchasing goods and contracting works and services by FBDS partners may be adopted, and their resources are executed within the scope of the respective projects and actions as long as they are compatible with Brazilian laws.

Chapter IV - On The Preliminary Provisions

Art. 5th - Purchasing goods and contracting works and services shall be carried out by means of the selection of suppliers, and this procedure is waived only in the cases provided for in this Regulation.

Single paragraph - FBDS may use pre-selection and registration procedures for possible executors for contracting and negotiating activities to be performed.

Art. 6th - Participation in the selection of suppliers implies full and irreversible acceptance of the terms of the purchase/service order or call notice, of the technical elements and instructions provided by FBDS to interested parties in terms of reference, as well as the compliance with this Regulation and applicable norms.

Art. 7th - When consulting services are hired, payments will only be made upon delivery and due approval of the products by FBDS, separately or jointly with other partners, supporters and / or financiers of the project or action.

§ 1st - In case it is necessary to split the payment amount referring to the consultancy, the full amount shall only be paid upon delivery and approval of the final product, according to terms of reference and corresponding contract.

§ 2nd - Once provided for in the contract, payments for consultancy services shall be conditioned to the equivalent transfer of resources from the partner/contractor/financier of the project or activity.

Art. 8th - On the occasion of the payment, only fiscal or equivalent documents will be accepted.

§ 1st - Priority will be given to hiring Companies.

§ 2nd - In the case of occasional services performed by an Individual, a Payment Receipt must be issued in the form of Recibo de Pagamento Autônomo-RPA (Autonomous Income Receipt).

§ 3rd - Whenever possible, the priority should be for suppliers of goods from local markets where projects and activities are being carried out.

Chapter V - On The Unenforceability And Exemption Of Proposal Selection

Art. 9th - The selection of proposals is unnecessary or unenforceable:

  1. For purchases of goods and contracting of works and services up to the limit specified in Item I of Article 11 of this document;
  2. For the purchase of materials, equipment or goods directly from an exclusive supplier;
  3. For hiring technical services, of singular nature, from professionals or institutions of notable specialization;
  4. For the acquisition, renting or real state leasing intended to accomplish FBDS' objectives or its projects and actions, whose needs of installation and location condition its choice, and the price is compatible with the market value;
  5. When there are no interested parties in the selection of proposals previously carried out and this cannot be repeated without detriment to the schedule of execution of the activities of the projects and actions;
  6. In case of emergency or public calamity, when there is an urgent need to attend to a situation that may cause damage or compromise the safety of people, services and equipment;
  7. In case when the partner, supporter and/or financier has carried out a previous selection process, the result of which approves the technical team indicated by FBDS;
  8. In case of suppliers or service providers who have already had successful previous experiences with FBDS, as long as the prices are compatible with the market value.

Chapter VI - On The Proposal Selection Modalities

Art. 10th - The modalities for the selection of proposals to be presented, observing the limits of values established in Chapter VII of these Regulations below, shall be:

  1. Price Survey - a minimum of 3 (three) budgets will be requested, if available in the market, identifying the date of the survey, name of the supplier, contact, values offered and terms of delivery and payment;
  2. Invitation - a notice call will be produced and sent to at least 3 (three) suppliers, requesting price proposals at least 5 (five) business days in advance, for the purchases of goods, works and services, duly described in the terms of reference;
  3. Competition or bidding for proposals - a notice call for proposals will be produced and published on FBDS website and/or on other relevant and freely accessible means of communication, at least 8 (eight) business days in advance, for the purchase of goods, works and services, duly described in the terms of reference.

§ 1st - For the selection of proposals, regardless of the modality, the best cost/benefit rate for the execution of FBDS activities and projects must be considered.

§ 2nd - The technical qualifications of the supplier, the product/service and the proposed price will be used as selection criteria.

§ 3rd - The disclosure and reception of proposals provided for in the modalities of items I and II may be carried out by means of communications via e-mail or regular mail.

§ 4th - The reception or collection of budgets, as provided for in item I, may be carried out by physical or digital printing of web pages, price catalogs and printed disclosure materials, and/or communications via e-mail or regular mail.

§ 5th - In the cases provided for in item III of this article, on the occasion of publication of the notice call, a Judging Committee composed of at least 3 (three) members chosen by FBDS will be appointed to evaluate the proposals received.

Chapter VII - On The Limits

Art. 11th - The limits for the exemption and for the modalities of the formal purchase and contracting processes are:

  1. Exemption- up to the amount of R$ 30,000.00 (thirty thousand reais) inclusive
  2. Price survey - from R$ 30,000.01 (thirty thousand reais and one cent) up to R$ 60,000.00 (sixty thousand reais) inclusive;
  3. Invitation - from R$ 60,000.01 (sixty thousand reais and one cent) up to R$ 450,000.00 (four hundred and fifty thousand reais) inclusive;
  4. Competition or bidding for proposals - from R$ 450,000.01 (four hundred and fifty thousand reais and one cent).

Single Paragraph - The limits specified in items I to IV of this Article can be adjusted in specific cases, in common agreement with partners, supporters and financiers, regarding projects or actions that so require and the new limits are valid only for those projects or actions.

Chapter VIII - On The Purchasing And Contracting Processes

Art. 12th - The purchasing / contracting processes will consist of the following steps:

  1. Preparation of the Terms of Reference or technical specifications of the services or goods to be acquired by members of the project or action team and submitted to the approval of the project coordinator or administrator;
  2. Forwarding to FBDS Executive Board of, for analysis and approval, considering the relevance of the purchase/contracting and the budgetary limits of the projects or activities and subsequent follow up of the proposal selection process, as described in chapters V and VI in this Regulation;
  3. Purchases of goods and contracting of works and services: a specific contract will be signed with the selected supplier, except for the exemptions described in this Regulation.

§ 1st - The exemption of contract is allowed, at FBDS' discretion, in the case of purchase for immediate and full delivery of the acquired goods, which do not result in future obligations, with full payment made by FBDS after reception. The same can be extended to support and maintenance services, excluding consulting services.

§ 2nd - When the expense is not directly related to a project in execution, the person responsible for the FBDS sector will be entitled to request it.

§ 3rd - In the case of contracts that fit the modality of competition or bidding contest, the selected supplier must prove the tax and labor law regular compliance before signing the respective contract.

§ 4th - FBDS may also, in the regular exercise of its activities and within projects in execution, offer scholarships, survey and data and information collection to be implemented in its projects and activities.

Art. 13th - The notice calling instruments shall ensure to FBDS the right to cancel the selective purchasing/contracting process, prior to the signing of the contract.

Art. 14th - The process must be kept on file at FBDS' headquarters for the period established in the covenant instrument signed with the agency responsible for the transfer of funds, except in cases in which this period is shorter than the periods established in the current legislation, for further investigations, inspections and possible internal or external auditing.

Art. 15th - The project coordinator or administrator in charge for the area/nucleus or FBDS' administrative sector may request an amendment to increase the value initially contracted, and the numbers to be acquired, considering the financial availability in the referred project or action.

§ 1st - The increase in value must be proportional to the additional services provided, execution of the work or number of goods, except in cases of proven increases in the prices of the inputs necessary to achieve the object of the contract.

§ 2nd - FBDS' Chair or Executive Director is the authority in charge of approving any amendments.

Art. 16th - The necessary and essential provisions in any contract to be signed by FBDS are those that establish:

  1. Updated and compliant identification of the contractor, including CNPJ, address, CEP;
  2. In case of hiring a legal entity, updated and compliant identification of the contractor's legal representative, including CPF (tax payer registration number), position, complete home address, with zip code;
  3. Origin of resources for the contract in question;
  4. Possibility of amendment regarding the object, time length or value of the contract, by means of the signature of a Term of Addendum;
  5. The object of the contract, the dates of total or partial delivery of product (s) with the respective identification and its characteristic elements.

    Single Paragraph - In the case of the availability of a term of reference, this must be cited as an integral part of the object of the contract.

  6. Price and payment terms;
  7. Validity period and conditions to start the service, work or supply of the good;
  8. Obligations of the parties;
  9. The indication of the forum to resolve doubts arising from the execution of the object of the contract, establishing the obligation of the previous attempt of an administrative solution.
  10. The parties' option to terminate the instrument, at any time, with the respective conditions, sanctions and clear delimitations of responsibilities, in addition to the stipulation of a minimum advance period for the communication of this intention, which cannot be shorter than 30 (thirty) days;
  11. Intellectual property and authorship of products, no competition and penalties.

Art. 17th - On the following special occasions, an Evaluation Committee will be made up in order to evaluate the proposals presented and decide on the contracting:

  • Acquisitions or contracts above R$ 800,000.00 (eight hundred thousand reais);
  • Acquisitions or contracts in which there is an important qualitative component in the Choice, which goes beyond the quantitative component of the proposals.

The Evaluation Committee will be made up by the following members of FBDS team:

  1. The CEO;
  2. Technical-Scientific Director;
  3. Project manager.

Chapter IX - On The Reception Of Goods Acquired And Services Rendered

Art. 18th - Upon reception of any contracted purchase, work or service, the original fiscal document must be compared with the respective term of reference and/or contract.

Single Paragraph - During the comparison of the fiscal document with the specifications established in the terms of reference and/or contract, the procedure will be the physical checking of the purchase, the contract of the work or service, regarding quality, specification, validity and guarantee, when applicable, quantity and integrity, preferably in the presence of the supplier and/or transporter.

Art. 19th - In case there is a refusal in the act of receiving the purchase, work or service and/or the return of some merchandise, in whole or in part, the person responsible for the reception must immediately inform the project coordinator or FBDS administrative sector, so that the necessary measures can be taken with the supplier regarding the business cancellation and taking steps to stop the payment process that may be in progress.

Chapter X - On The Administrative Resources

Art. 20th - Related to FBDS' acts resulting from the application of these Regulations, a Reconsideration Request will be made to those interested in supplies/service provision, provided that they have formally manifested within the process, in accordance with the text of the instrument by means of which FBDS published the budget request. The deadlines established in the publication act must be considered, respecting the maximum term of 5 (five) working days from the date the claimants acknowledge the act considered irregular or illegal.

Single Paragraph - The Reconsideration Request will be considered by FBDS within a period of up to 15 (fifteen) business days after receiving the aforementioned Reconsideration Request.

Chapter XI - On The Final Provisions

Art. 21st - FBDS will take all necessary measures to avoid conflicts of interest and guarantee competition in the contracting processes provided for in this Regulation.

Art. 22nd - In the event of contracts signed with institutions that require compliance with their own standards, FBDS will check possible conflicts and adopt the most restrictive clauses.

Art. 23rd - The cases omitted in this Regulation will be decided by FBDS Deliberative Council, duly justified.

Fundação Brasileira para o Desenvolvimento Sustentável
Rua Engenheiro Álvaro Niemeyer, 76
CEP 22610-180
Rio de Janeiro - RJ - Brasil
Tel. +55 (21) 3322-4520
Fax +55 (21) 3322-5903
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