Code of Conduct
Estimated reading time: 15 minutes
Last update: 02/04/2023
1. Summary and Purpose of the Code
This Code of Conduct and Integrity (“Code of Conduct”) aims, based on the principles, vision, mission and values of Andre Sanches and subsidiaries, affiliates, companies (“Company”, “Company”, “Group”), guide a sustainable, respectful, conscientious and ethical way of acting, as well as guidance on the prevention of conflicts of interest, prohibition of acts of corruption, improbity and fraud related to issues of ethics and integrity.
The Code of Conduct is based on the organization's ethical values and principles. It promotes transparency, disciplines internal and external relations, manages conflicts of interest, protects physical and intellectual assets and consolidates good corporate governance practices. It includes the legal obligations, regulations and internal rules of the Company, so that ethical considerations and those related to organizational identity and culture influence management.
With this Code, the Company aims to prevent misconduct, promoting the dissemination of guidelines and educational activities, without prejudice to the application of appropriate disciplinary measures when such deviations are found.
The guidelines contained in this Code of Conduct apply to employees, interns, partners, suppliers, customers, "Users" of the "Site" and other interested parties ("Stakeholders", "Stakeholders") and cover the relationship between them.
2. Relationship with people
what is expected
Everyone involved in the company's business and operating activities must act in a fair, competent and efficient manner to positively and ethically influence their colleagues. Therefore, they are expected to be responsible for complying with and ensuring compliance with the guidelines established in this code, spreading its application with breadth and depth.
Interested parties observe and comply with the guidelines established in this code and must immediately report possible cases of non-compliance through the Institutional Ombudsman/Ombudsman/ Complaint Channels .
General guidelines of conduct
Those involved must:
Carry out its activities in accordance with this code and follow the company's policies, rules, codes and procedures (available in the Institutional Sections), encouraging and guiding everyone in this regard.
Maintain a positive, dignified, loyal and honest attitude, one of mutual respect, trust and collaboration with others involved.
Act with impartiality, objectivity, honesty, respect, transparency, loyalty, without obtaining undue advantages and remain in compliance with all applicable laws, including our policy. anti-bribery [to be published] and anti-corruption policy [to be published].
Do not practice, present or tolerate any type of violence, prejudice, abuse, discrimination, threat, blackmail, false testimony, retaliation, psychological violence, moral or sexual harassment or any other act contrary to the company's ethical principles.
Avoid situations in which there may be a conflict of self-interest with the company's interests and, when this is not possible, immediately report the fact to the company.
Preserve the company's assets, including its image and reputation, facilities, equipment and materials, using them only for their intended purposes.
Resist pressure from superiors, contractors, interested parties, suppliers, partners and others who seek to obtain undue favors, benefits or advantages as a result of immoral, illegal or unethical actions, denouncing those involved through the Institutional Ombudsman/Ombudsman/Whistleblower Channels .
Keep confidential information or information that violates privacy, to which you have access due to professional practice or social life.
Guarantee the fundamental right of access to information, considering publicity as a general precept and confidentiality as an exception, in accordance with other guidelines and basic principles of administration.
Do not deceive or obstruct the actions of public authorities or any other necessary.
Absolutely abstain from exercising their function, power or authority for a purpose that is beyond the public and private interest, even if they comply with legal formalities.
Caring for the environment, avoiding waste and encouraging sustainable attitudes.
3. Intolerable conduct and subject to disciplinary measures
Discriminate based on ethnicity, origin, gender, sexual orientation, religious belief, union status, political conviction, ideological, social class, physical or mental disability, marital status or age, among others, as protected characteristics [link in English from the Commission on Equality and Human Rights] .
Harassment in any form and type, including moral or sexual.
Treating any customer, partner or supplier preferentially or favorably contrary to company policies and standards.
Use your role in situations that constitute abuse of power or authoritarian practices.
Change or misrepresent the content of documents you must submit for action.
Promising, offering or granting, directly or indirectly, an undue advantage to a public or private agent, national or foreign, or to a person related to it.
cheat bids, contracts, partnerships, with governments, entities, associations, organizations, companies, entrepreneurs, individuals and legal entities of any nature, national or foreign.
Embarrass the actions of inspection authorities.
Accept an error or violation of this code or related legislation.
Failure to comply with the guidelines provided for in this code will be subject to measures and sanctions proportional to the seriousness of the offense committed, except in cases of fact-finding, in which investigation procedures must be initiated, potentially culminating in verbal warning(s) ; private written notice(s); temporary suspension of the activity(ies) and relationship(s); suspension of the contract(s) and any related objects; renounce; possible liabilities provided for by law.
4. Use of digital media - "SITE"
Ethical principles, policies and standards and the use of appropriate language must be considered when using digital media in the exercise of activities or because of them. Thus, it is expected that some guidelines are followed by those involved:
Do not use your email or social media to express negative opinions or defame the company in any way.
Do not make private use for commercial activities of buying and selling, offering services or advertising without proper written authorization.
do not manifest or propagate speeches and expressions of hate against people or groups of people due to their color, sex, religion, nationality, sexual orientation, social origin, political preferences, among others.
Do not disclose their own opinions on behalf of the company.
don't try invade, violate systems or security controls, look for vulnerabilities, monitor, break or obtain passwords for systems, computers, applications, among others.
don't get or propagate intentionally viruses and the like.
Do not act on social media identifying exclusively with your personal profile to respond to reviews, comments, among others, related to the Company.
5. Relationship with the public
Conflict of interests
Any situation generated by the confrontation between the company's interests and the private interests of employees, interns and those covered by this code (involved) that may compromise the company's interests or unduly influence the performance of its activities, such as:
The provision of services to individuals or legal entities or the maintenance of a business relationship with individuals or legal entities that have an interest in individual or collective decisions, in matters related to the purpose of the unit or service in which it is agreed;
The use of influence, directly or indirectly, whose agent has access due to the position, for their own benefit or that of third parties.
The selective use or leakage of confidential information, for their own benefit or that of a third party, to which the agent has access due to their position. The occurrence of a conflict of interest does not depend on the direct or third party receipt of any gain or retribution by the public agent.
Stakeholders are expected to make their decisions in view of the company's interests, observing the guidelines:
Not receiving salaries or any other remuneration from a private source in violation of the law, nor receiving transportation, accommodation, food or any favors from individuals to allow for a situation that could raise doubts about your probity or honor. Participation in seminars, congresses and similar events, as holder of the position held/agreed partnership, is allowed, provided that any remuneration to the company is informed, as well as the payment of travel expenses by the event promoter, who may not be interested in decision to be taken by the company;
Do not engage directly or indirectly in any activity that conflicts with the company's interests.
Do not disclose or use privileged information, for personal benefit or that of third parties, obtained as a result of the activities carried out.
Do not carry out any activity that implies the provision of services or the maintenance of a business relationship with an individual or legal entity that has an interest in the decision of the agent/partner, in the collegiate in which he participates or in the function in which he exercises.
To prevent employees, interns and others involved from being in a direct subordinate relationship with a spouse and relatives, care is requested and to inform the company about the relationship of:
Spouse, partner or relative in a straight line/collateral, by consanguinity/affinity, up to the third degree.
Legal entity whose administrator or partner with management power is a member of the family of:
Stakeholders who exercise a function of trust in the unit responsible for the demand or contracting.
Immediate superior to those involved in the Company who exercise a function of trust in the unit responsible for the demand or contracting; and
Occupying a trust role responsible for contracting authorization.
Relatives are consanguineous relatives and, by affinity, up to the third degree, that is: mother/father, stepmother/stepfather, son/daughter, son-in-law/daughter-in-law, stepson/stepdaughter, brother/sister, father-in-law/mother-in-law, grandfather/grandmother, nephew/niece, uncle/aunt, cousin/cousin, brother-in-law/sister-in-law, grandson/granddaughter, great-grandfather/great-grandmother, great-grandson/great-granddaughter.
If there is a need to contract/partner with a member who has a subordinate relationship with a spouse and relatives, it is up to the applicant to justify through the Institutional Contacts and for the company to assess the reasonableness of the need.
Gifts and souvenirs
Gifts are values and goods given to those involved, intended for their own use. Favoritism is the act of prioritizing or benefiting someone over others.
Gifts: Participants are prohibited from giving and accepting gifts, benefits or advantages, except those resulting from prizes and gifts that:
It has no commercial value; or
They are distributed as a courtesy, advertisement, customary disclosure or on the occasion of special events or commemorative dates, not exceeding R$ 100.00 (one hundred reais). Gifts and gifts sent directly to interested parties who want any kind of compensation in the form of favoritism cannot be accepted and must be returned.
Favoritism: Obtain prior formal approval from the company whenever you offer or receive hospitality to third parties who have any business or institutional relationship with the company.
6. Code support
The Company provides communication channels through which interested parties can report, without the need to identify themselves, situations with indications of illegality of any nature, such as suspected fraud, corruption, ethical misconduct and illegal acts. Compliance with the rules contained in this Code of Conduct is everyone's duty, therefore, it is also up to everyone to monitor compliance. The company counts on the help of those involved, regardless of position, so that the general conduct is always ethical, fair and correct.
To make your complaint possible, use the Institutional Ombudsman/Ombudsman/Whistleblower Channels .
7. General provisions
If in doubt about the content or interpretation of this code, interested parties should contact the company.
Right not to be identified: In order for all reports to be treated fairly and impartially, os Institutional Ombudsman/Ombudsman/Complaint Channels guarantee the confidentiality of information and the anonymity of the whistleblower, avoiding any type of retaliation. It is up to the whistleblower to choose whether or not to identify himself during contact, but it is important that all details and information about the offense are transmitted.
It is essential that communication strategies and training programs are continuously implemented to disseminate policies, procedures, standards and practices based on this code among interested parties.
It is important that there is an effective involvement of those involved in the compliance mechanisms, allowing any deviations to be avoided or proactively identified, corrected and, eventually, punished.
The Company reserves the right to update the terms of the code from time to time, in the sole discretion of the Company. You should periodically review it for any updates and modifications.
If this code is translated into other languages and there is a discrepancy between the versions, the Portuguese (Brazil) version will prevail.
If you need additional information about the website or this code, please contact us at dos Institutional Contacts.
Code created on 10/07/2020.