Apresentamos, abaixo, correspondência dirigida ao Sr. Diretor Superintendente da PREVIC, a respeito do “sigilo estratégico” da PREVI.
Rio de Janeiro, 22 de janeiro de 2015.
Ilmo. Sr.
CARLOS ALBERTO DE PAULA
Dd. Diretor Superintendente da PREVIC – Superintendência Nacional de Previdência Complementar
Setor Bancário Norte, Quadra 2, Bloco N, 9º andar.
Brasília/DF
CEP 70040-020
Senhor Diretor-Superintendente,
A AAPBB-Associação dos Aposentados e Pensionistas do Banco do Brasil, organização civil sem fins lucrativos constituída em 01.12.1998, de âmbito nacional, com sede e foro na Av. Rio Branco, nº 185, salas 611 e 612, Centro – Rio de Janeiro – RJ, CEP: 20.040-007, inscrita no CNPJ/MF sob no. 03.642.162/0001-69
OBJETO –
Vem solicitar desse órgão que, na condição de supervisor e fiscalizador do sistema de previdência complementar, determine à PREVI- Caixa de Previdência dos Funcionários do Banco do Brasil, com sede à Praia de Botafogo, 501 – 3º . andar, Rio de Janeiro (RJ) CEP: 22250-040, inscrita no CNPJ sob no. 33.754.482/0001-24 a cessação ou limitação do regime de “sigilo estratégico” adotado extensivamente por aquela entidade, em razão do qual são negadas aos participantes e assistidos informações detalhadas alusivas à contabilidade e às aplicações.
Nosso pedido se ampara na LC-109, que estabelece:
“Art. 3° . – A ação do Estado será exercida com o objetivo de :
:
IV – assegurar aos participantes e assistidos o pleno acesso às informações relativas à gestão de respectivos planos de benefícios;”
Igualmente, nos amparos nas seguintes regulamentações sobre a matéria:
- Resolução CGPC no. 05, de 30-01-2002 – Procedimentos contábeis – Alterada pelas Res. CGPC n° 10, de 2002, 1, de 2003, 13, de 2004, 17, 22, 23, de 2006 e 25, de 2008, 28 de 2009.
RAZÕES –
Com efeito, a PREVI tem se esquivado de responder positivamente a pedidos de informações formuladas por associados (participantes e assistidos) ou por suas associações, sob a alegação de que todas as informações desejadas já constam dos Relatórios Anuais divulgados, o que não corresponde á realidade. As informações que eventualmente fornece em resposta são redundantes e não elucidativas, fazendo retornar as questões ao ponto da partida.
O Conselho Deliberativo – no que é seguido pelo Conselho Fiscal e pelos Diretores – nada divulga de suas atividades nem de suas reuniões, sempre alegando estarem todos os assuntos cobertos pelo “sigilo estratégico” estabelecido pela entidade. Justificaram-se os Conselheiros e Diretores dizendo que, ao tomar posse, são obrigados a firmar “termos de compromisso de confidencialidade”, cuja quebra implicaria na destituição do cargo.
Se assim é, configura-se o estabelecimento de uma chantagem, à qual os representantes dos participantes e assistidos têm sucumbido. Por medo de perderem os cargos remunerados para os quais foram eleitos, abandonam o lado dos seus representados e passam a se alinhar com os conselheiros e diretores designados pelo patrocinador, contrariando o objeto da lei que instituiu a paridade de administração e fiscalização. Na prática, essa atitude anula a representatividade dos participantes e assistidos na gestão do seu fundo de pensão.
Não se sabe quem estipulou tais compromissos de sigilo, que definiu a punição pelo eventual quebra do compromisso de cumprimento nem quais os assuntos abrangidos por tal sigilo dito “estratégico”, isso porque nem sequer os seus termos são dados a conhecer.
No que se refere às aplicações financeiras e investimentos imobiliários, não cabe sigilo permanente. Eventual “sigilo estratégico” só poderia existir antes de feita uma negociação. E, dependendo do caso, até poderia ser natural, desejável e inteiramente compreensível. Entretanto, após completa a transação, essa tem de ser registrada contabilmente e os números que a representam jamais poderiam ser secretos.
É impossível compreender a manutenção de “sigilo estratégico” sobre operações realizadas através de Bolsas de Valores, porque essas se tornam públicas em todos os seus aspectos normais. Quanto às demais operações diretas no mercado – financeiras ou imobiliárias – torna-se ainda mais patente a necessidade de completa informação sobre elas.
Se, em ambos os casos, a necessidade de sigilo permanece indefinidamente, isso sugere a existência de “fatores não regulares” da negociação que a divulgação de seus registros contábeis exporia. Obviamente tal circunstância diz respeitos aos atos dos dirigentes, e não à entidade em si. Isto é, o sigilo seria invocado em nome da conveniência dos dirigentes.
No que se refere às “Despesas”, não é concebível a invocação de “sigilo estratégico” para encobrir seu detalhamento contábil. Ademais, quais “Despesas” podem ser “sigilosas por serem estratégicos”?
Não basta serem informadas pelos seus valores totais, como constam nos “Relatórios Anuais”, sem que se saiba como foram produzidos. A leitura dos Relatórios Anuais da PREVI implica na obrigação de aceitar números globais – resultantes de totalizações – como sendo verdadeiros, inquestionáveis, sem se conhecer como chegou a eles. Os participantes e assistidos têm o direito de conhecer as parcelas que compõem os totais.
A PREVIC, através da Instrução no. 5, estabelece o mínimo de informações contábeis que devem ser prestadas pelas EFPC, com destaques para as contas de “Despesas” (Art.9 e Anexos).
Caso a PREVI queira interpretar que as informações listadas pela PREVIC representam o máximo a que está obrigada, o Art. 20 tira essa dúvida :
“ Art. 20. A observância desta Instrução não exime a
EFPC do cumprimento das demais normas e atos que tratam da prestação de informações”.
CONCLUSÃO –
Assim, resta aos participantes e assistidos com o amparo dessa PREVIC, cujo o objetivo estatutário e motivo de sua criação foi e é, exatamente, o de defender aqueles que constituíram os fundos de pensão com suas contribuições e deles esperam os meios de subsistência que não são favor, mas frutos de seus investimentos que devem ser bem geridos em seu benefício. A boa gestão não comporta mistérios.
E é nesse entendimento que ficamos na expectativa de suas providências, como aqui solicitado, de forma a que possam os participantes e assistidos da PREVI acompanhar “de fato” a gestão do seu fundo de pensão.
Atenciosamente
Ruy Brito de Oliveira Pedrosa Ebenezer W. Araújo Nascimento
Presidente Vice-Presidente de Assuntos Previdenciários
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