Investigations Bureau

“Line 12c: The organization has a written conflict of interest policy and board members affirm their compliance annually.”

“Line 15: The organization follows a conflict-free well-documented process to determine the compensation of officers and key employees. This process includes the following elements: Independent Review: Compensation arrangements are reviewed and approved by disinterested members of the Compensation and Conflict of Interest Committee or the Board of Directors. Any individual with a conflict of interest recuses themselves from discussion and voting. In 2022 Andrew David Fishman recused himself from compensation discussions involving himself and another officer. Use of Comparability Data: The organization reviews compensation levels for similar positions at comparable nonprofit organizations considering scope of responsibilities and geographic location. For positions based in Brazil compensation determinations also consider local market conditions and salary norms including adjustments based on the IPCA inflation index. Contemporaneous Documentation: Compensation decisions are documented in written resolutions or meeting minutes noting the terms approved date of approval board or committee members present comparability data reviewed and any actions taken regarding potential conflicts of interest. Review Frequency: Officer and key employee compensation is reviewed annually or when material changes in duties or compensation are proposed. In 2022 compensation for three officers Andrew David Fishman Rafael Fagundes Pinto and Maria Ceclia de Oliveira Rosa was approved in a written consent resolution of the Compensation and Conflict of Interest Committee and ratified by the full Board. Compensation was determined to be reasonable and in the best interests of the organization.”