CHAPTER II
DUTIES AND RESPONSIBILITIES OF EMPLOYEES

Art. 5th. Ethics and rule-following behavior are individual responsibilities. All employees are expected to show the highest standards of conduct, regardless of their position or where they work. No manager is authorized to demand from the employee a conduct that violates this code, rules created in his function or any applicable legislation.
Art. 6th. Every employee has the obligation to report the occurrence of a violation of this regulation, in addition to others in force at BRAVO. Employees who provide such information in good faith must not fear retaliation. The company ensures that all information will be investigated and examined with the greatest possible confidentiality. The measures will be proportionate and taken in accordance with current legislation for each particular situation.
Art. 7th. Thus, in the relationship with BRAVO, administrators, with other collaborators, with clients, with public authorities, the Collaborator undertakes to:
I. Be courteous, loyal, dedicated, honest, cooperative, and responsible, respecting the individual differences of all BRAVO customers, users, and employees, without any kind of prejudice or distinction of race, sex, nationality, color, age, religion, imprint political and social status;
II. Preserve the intimacy, privacy, personal data, honor, and image of co-workers and contribute to adequate interpersonal and professional relationships;
III. Fulfill the professional commitments assumed between themselves and with the company, without prioritizing personal interests or those of third parties;
IV. Respect professional secrecy, except when its breach is authorized or required by law;
V. Preserve the interests and care for the company’s image, whether in an internal or external environment, and not associate BRAVO’s brands with actions, images, or negative information, in any form of communication, including electronic ones;
VI. Ensuring the proper use of information and available technological resources;
VII. Take care of the company’s assets that you are a user or holder of and give them the correct destination;
VIII. Preserve, in exercising the right to strike, the company’s assets and respect the right to come and go of employees and customers;
IX. Resist pressure aimed at obtaining any favors, benefits, or undue advantages as a result of immoral, illegal, or unethical actions and denounce them;
X. Have respect for the hierarchy, but without fear of denouncing their hierarchical superiors in the event of an irregular act of which they are aware;
Xl. Show up for work wearing clothes suitable for the exercise of the function;
XII. Refrain from participating in activities that characterize a conflict of interest in relation to BRAVO’s activities, as well as communicating to the appropriate channels any real or apparent conflicts between BRAVO’s interests and interests related to their professional, personal, or third-party activity.
Xlll. Know, comply with, and collaborate in the dissemination of this Code of Ethics and other internal regulations of BRAVO;
XIV. Communicate immediately to your superiors any and all acts or facts contrary to the interest of BRAVO.
XV. Refrain from pleading, soliciting, provoking, suggesting, or receiving any type of financial aid, gratuity, prize, commission, donation, or advantage of any kind, for themselves, family members or any person, for the fulfillment of their mission or to influence another collaborator for the same purpose;
XVI. Preserve the integrity of documents, registers, registrations, personal data of third parties, information systems and not remove any document or property belonging to BRAVO without being legally authorized.
XVII. Avoid inappropriate public behavior, do not participate in disreputable groups, or engage in socially reprehensible activity;
XVIII. Respect the intellectual production and recognize the relative merits of the works developed by their colleagues, regardless of their hierarchical position;
XIX. Obtain prior authorization from the company for the publication or exhibition, in external environments, of studies, research, opinions and other works of its authorship or participation, involving knowledge related to BRAVO;
XX. Exercise professional management responsibilities with transparency and equanimity, guiding and motivating other employees and collaborators to create a healthy work environment conducive to excellence in performance and productivity, ensuring compliance with corporate rules and instructions, as well as this Code of Ethics;
XXI. Prioritize and preserve BRAVO’s interests with customers, government agencies, financial institutions, suppliers, entities, and other companies with which BRAVO maintains a relationship.
XXII. Refuse any prize, gift, or other type of benefit of significant commercial value, from suppliers, partners, and contractors, reporting the fact to their immediate superior;
XXIII. Texts, reports, opinions, software, among any other materials developed within the organizations, are the property of BRAVO, not allowing the individual use or transfer of said material to third parties without formal authorization from the Board of Directors;
XXIV. BRAVO does not allow piracy of any kind, and the unauthorized reproduction of any materials, systems and software is prohibited, under penalty of criminal sanctions and compensation for damages;
XXV. Use BRAVO assets only for business purposes, with a duty of protection, conservation, and preservation, avoiding inappropriate use or use without obtaining adequate training, in addition to communicating to hierarchical superiors any loss or damage that is identified;
XXVI. Comply with this Code and the Manuals that form an integral part of this Code.
Art. 8th. In relation to information and data that you have access to on BRAVO:
I. Preserve the secrecy of information (commercial, strategic, or technological), personal data and intellectual and industrial knowledge produced by BRAVO;
II. Maintain professional secrecy and be careful when making comments about the businesses, activities of organizations and clients that use BRAVO services;
III. Obtain authorization from the Board of Directors to promote lectures, conferences, presentations, publications, comments, or any other form of communication with the external public, through which concepts, plans, results, strategies, name, and image of BRAVO are exposed, being prohibited the disclosure of non-anonymized personal data;
IV. Carry out academic work on the Bravo Group or provide materials and information for third parties to do so, only with the authorization and/or monitoring of the area responsible for the subject and/or the Communication area. The result of work of an intellectual nature and the strategic information generated is the exclusive property of BRAVO, with the disclosure of non-anonymized personal data being prohibited;
V. Communicate in writing, verbally or anonymously to the immediate superior or responsible area any and all incidents related to the security of information and personal data that are identified inside and outside the perimeters of BRAVO organizations for taking measures;
VI. Insert truthful information and analytical quality into BRAVO’s systems, as all the results obtained in the analysis of the company’s performance and growth depend on them.
VII. Report as soon as possible to the Information Technology department any instability, data leakage, operational non-compliance or failure found in the systems, whether generated by systemic errors or by mistaken processes;
VIII. Comply with BRAVO’s Data Protection Code of Conduct.
Art. 9th. With regard to technological resources and personal passwords, the employee must observe the following rules:
I. Collaborators must use the technological resources made available by BRAVO only for professional purposes, as established in the Information Security Policy, with BRAVO having the right to verify their proper use and access personal devices, corporate emails and other instruments made available for the work.
II. Access, transmission and archiving of inappropriate and illegal content, including, but not limited to, pornography, games, discrimination, and activities against public property or third parties are not allowed.
III. Any personal passwords assigned by BRAVO to the employee are for exclusive use and cannot be transmitted to third parties, because the employee’s access to the systems through the use of such passwords will be presumed, in addition to generating the penalties resulting from improper use to the employee.
IV. Employees must keep their passwords confidential, changing them periodically to prevent unauthorized access to BRAVO information and data by unauthorized third parties. Any incident of improper access must be communicated to the hierarchical superior and, in the case of personal data, to the ETDP.
Art. 10. For BRAVO, reputation and credibility are fundamental to strengthen the image of organizations as solid and reliable entities. The participation of its employees on the internet and social media affects the reputation and credibility of BRAVO’s brands. Therefore, the following are essential precautions and recommendations for all employees:
I. Do not share images (photos or videos) of BRAVO establishments, employees or customers on social networks or any form of communication without the consent of the data subject or BRAVO;
II. If the employee identifies any information, image or personal data that may be harmful to BRAVO or that is not part of an official advertising campaign, he must immediately notify his hierarchical superiors or the ETDP in case of personal data.
III. It is not allowed to disclose information for internal or confidential use and work routines;
IV. It is not allowed to disseminate, by any means, including electronic mail and the internet, any messages that deal with illegal, pornographic, discriminatory matters of any origin, of a religious or political-partisan nature, or in disagreement with BRAVO’s ethical principles;
V. Register on social networks, shopping sites or other types of personal interest of the employee only with personal e-mails and passwords and different from those assigned by BRAVO for work purposes. The corporate e-mail must be used exclusively for professional purposes;
VI. Share campaigns and posts referring to Grupo Bravo companies, only already published in the official profiles of the companies.