Governance that sustains trust in every decision.
LakeX operates at the frontier between autonomous AI and the factory floor — where the cost of an error is physical. We treat governance and integrity as infrastructure, not formality. Here are the principles, the structure and the full body of policies that guide how we act, decide and account.
The pillars that guide the company
Our governance is the set of commitments we apply every day — especially where AI takes part in decisions with real consequences.
Integrity first
Zero tolerance for corruption, fraud and undeclared conflict of interest.
Transparency and accountability
Relevant decisions are recordable and auditable. Nothing off the books.
Human in the loop
Where an error has physical or legal cost, the final decision stays human.
Data protection
LGPD by design: minimization, purpose, security and clarity on data and model ownership.
Voice and non-retaliation
A confidential channel gives voice to whoever spots a deviation, with real whistleblower protection.
Continuous improvement
Risks are classified by severity, monitored and reviewed; policies evolve.
How the body of policies is organized
The Code of Ethics is the cornerstone; the Integrity Program organizes the eight pillars of Decree 11,129/2022; the other policies detail specific risk fronts — all pointing to the Integrity Channel.
Cornerstone
The Code of Ethics sets the behavior standard.
Umbrella
The Integrity Program organizes the eight legal pillars.
Thematic policies
Anti-corruption, gifts, public officials, governance and channel.
Integrity Channel
The whole set converges to the confidential channel.
Policies for reading and download
All documents below are PDFs. They are institutional drafts undergoing legal validation.
Code of Ethics and Conduct
The program's cornerstone. Values, behavior standards, conflict of interest and the integrity commitment expected from everyone.
Compliance and Integrity Program
The umbrella organizing the eight pillars of Decree 11,129/2022: leadership, policies, controls, risk, training, channel, investigation and monitoring.
Anti-Corruption and Anti-Bribery Policy
Zero tolerance for active and passive corruption (Law 12,846/2013). Facilitation payments, third parties, donations and maximum rigor with public officials.
Gifts, Entertainment and Hospitality
What is acceptable in business courtesies, what requires prior approval and what is always prohibited — reinforced rule for public officials.
Annex — Gift Thresholds (Calibration)
Proposed value limits, anti-splitting aggregate caps, approval flow and the gift register template.
Relationship with Public Officials
Governs contact with the public sector — sales, tenders, inspections — with interaction logging and a ban on undue advantage.
Compliance and Corporate Governance
Authority levels, risk matrix, AI governance (human-in-the-loop), LGPD and OT security, data and model ownership, third parties and reversibility.
Ethics and Whistleblowing Channel
Establishes the confidential channel: what and how to report, whistleblower protection, non-retaliation and the investigation flow with deadlines.