CODE OF ETHICS
GENERAL PROVISIONS AND PRINCIPLES
Art. 1st. BRAVO is committed to establishing and enforcing the highest standards of moral and ethical conduct, implementing its mission and conducting its commercial activities with honesty, integrity, free from all types of applicable prejudices, with the commitment to comply with all legislation pertinent to its business and the Code of Conduct practiced by its customers, suppliers and the community where it is installed.
Art. 2nd. This Code of Ethics aims at BRAVO’s commitment to comply with its obligations in relation to all those who have a personal, professional, or financial interest in its activities, including shareholders, employees, and suppliers.
Art. 3rd. This Code sets out the ethical principles that must guide all BRAVO employees, directors, and suppliers in the performance of their daily duties. If in doubt: (a) consult your immediate superior; (b) in the case of a supplier, expose the situation to the Supply Department; (c) in case of situations involving personal data, contact the Person in Charge for the Processing of Personal Data; (d) in specific integrity situations, notify the company’s Compliance. They will have all the subsidies for the necessary clarifications.
Art. 4th. Failure to comply with the precepts set forth herein, as well as other internal regulations, will result in disciplinary action, which may include the dismissal of the offending employee, or systematic breach of contract with its suppliers, contractors or any third party acting on its behalf.
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.
Art. 11. All employees with leadership roles are responsible for the acts performed by their subordinates. They are also responsible for ensuring that the various policies established by the company are effectively complied with.
Art. 12. Every employee with a leadership role is responsible for informing his or her team of all the company’s policies, including those dealing with legal and ethical conduct. The boss is also responsible for maintaining a healthy work environment, encouraging the group of employees to have a constructive, frank, and open exchange of information.
Art. 13. The employee with the function of boss must refrain from any practice that implies moral or sexual harassment in relation to subordinates, in addition to avoiding the use of aggressive and discriminatory language in relation to subordinates, under penalty of personal responsibility.
RELATIONSHIP WITH EMPLOYEES
Art. 14. BRAVO values its diverse staff. Trust in business conduct and ethics are paramount to achieving and maintaining good relationships between stakeholders. For this to happen, it is fundamental that the company recognizes the individual value of each person.
Art. 15. In accordance with the legislation applicable to the workplace, the company guarantees that each employee will be assessed and treated with dignity and respect, based on their behavior and their qualifications, without considering factors related to race, creed, sex, religion, nationality, age, disability, and political current to which they belong.
Art. 16. If there is a violation of the company’s policy involving any of these discriminatory aspects, employees must immediately inform the Human Resources sector of what happened or register the fact through the E-Ouvir system available on the Web through the link https:/ /bravolog.com.br/e-ouvir to which everyone has access.
LIABILITY OF PARTNERS, SUPPLIERS AND CONTRACTORS
Art. 17. All suppliers, partners, contractors and their respective partners, administrators, employees, representatives, subcontractors and any third party acting on behalf of BRAVO are expected to undertake to comply with the legislation and/or national and international regulations related to anti-corruption, money laundering or conflict of interests, including, but not limited to, the terms of (i) Brazilian anti-corruption law (Law No. 12,846/2013) and its complementary regulations; (ii) Brazilian bidding law (Law No. 14,133/2021); (iii) administrative impropriety law (Law No. 8,429/1992); (iv) money laundering law (Law nº 9.613/98) and its subsequent amendments.
Art. 18. It is prohibited, therefore, under penalty of contract termination:
I. Give, offer or promise, directly or indirectly, any valuable asset, or undue advantage, whether in monetary form, product, or service, to a public agent, national or foreign, or to persons related to them with the aim of influencing act or decision or direct business illicitly;
II. Using intermediaries or legal entities to hide or disguise the real interest or identity of the beneficiaries of the committed acts;
III. Financing, sponsoring or in any way supporting the practice of illicit acts;
IV. Offering gifts and/or gifts with significant commercial value to a Public Agent or persons related to him, and to BRAVO employees, in exchange for any type of benefits;
V. Prepare the accounting records, internal reports and disclose them, in a way that they do not represent the truth, that they are not accurate and reliable.
Art. 19. Suppliers, Partners, and Contractors that maintain a commercial relationship with BRAVO compulsorily agree to these guidelines and undertake to comply with all its terms, conditions, and ethical principles, being aware of their responsibilities and diligence for the dissemination of the Code among its collaborators and any third parties acting on its behalf that have activities related to BRAVO.
PROTECTION OF BRAVO HERITAGE AND ITS CUSTOMERS
Art. 20. The protection of all the company’s assets, as well as those of its customers under its custody, including physical assets, software, intellectual property, and confidential information, is the responsibility of each employee or service provider. Such assets must only be used for the purposes defined and required by the function performed by the employee or service provider, during and after the existence of the contractual relationship with BRAVO. They may not be used for personal advantage, nor may they be sold, loaned, donated, or disposed of without prior authorization.
Art. 21. Any individual who becomes aware of the loss, theft, or misuse of any assets of the company or its customers that are temporarily under the employee’s custody, must inform the Human Resources sector or his immediate superior.
RELATIONS WITH COMPETITORS
Art. 22. In relations with competitors, BRAVO undertakes to:
I. Base your conduct on compliance with legislation, loyalty, respect, and market rules;
II. Respect competitors, obtaining and providing lawful information and maintaining the necessary secrecy.
CONFIDENTIALITY OF BUSINESS INFORMATION
Art. 23. In order to ensure the confidentiality of BRAVO information, its customers and the personal data processed, employees must follow the following principle:
I. The disclosure, by any means, during or after their employment relationship, of commercial data or data considered confidential by the Company, entrusted to the employee for the exercise of his duties or that he becomes aware of by virtue of coexistence, is prohibited;
II. The disclosure, by any means, during or after their employment relationship, of records, technical, commercial, or confidential information of BRAVO’s Clients, entrusted to the employee for the exercise of his duties or that in any way he may have knowledge;
III. Access, capture and disclosure of personal data processed by BRAVO are prohibited, except in cases of pertinence to the employee’s functional attributions and as required by public bodies.
Art. 24. Violation of the Data Confidentiality policy is considered a profoundly serious offense and subjects the offending employee to disciplinary actions provided for in BRAVO’s Disciplinary Policy, without exempting him from legal proceedings, when applicable.
Art. 38. BRAVO has an Ethics Committee that is competent to:
I. Enforce this Code of Ethics and Manuals in accordance with its Internal Regulations;
II. Guiding and advising on the professional ethics of all those covered by this Code;
III. Investigate, through denunciation or ex officio, conduct in violation of the relevant ethical standards and apply ethical censorship, provided for in this and its Operational Manuals, which become an integral part of this Code;
IV. Recommend, monitor, and evaluate the development of actions aimed at the dissemination, qualification, and training on ethical standards;
V. Act as an advisory body for those covered by this Code and Manuals.
VI. Investigate, through investigation, the violation of this Code practiced by its Suppliers, Partners and Contractors;
VII. The activity of the Ethics Commission will be regulated by Internal Regulations approved by BRAVO’s Executive Board.
VIII. The management of this Code is the responsibility of the Ethics Committee, which will be responsible, with the support of the Board of BRAVO, for proposing its periodic updating, application, dissemination, and disclosure.
IX. Without prejudice to any penalty, forward to the Data Treatment and Protection Officer any incidents or problems identified regarding the processing of personal data by BRAVO, for the necessary measures and systemic corrections.
X. Without prejudice to possible corresponding administrative, civil, and criminal responsibilities, to be determined in specific procedures, the transgression of the precepts of this Code constitutes an ethical infraction.
XI. For breach of this Code and/or the Manuals, the Ethics Committee may adopt the following measures, if it concludes that there is an ethical misconduct:
a) Application of sanctions such as verbal or written warnings and suspensions, as the severity so requires;
b) Forwarding the Employee’s dismissal suggestion WITHOUT Just Cause or WITH Just Cause to the CGP – Personnel Management Committee.
c) Notification or exclusion of the Supplier, Partner, or Contractor from its business, depending on the severity of the act performed.
Art. 39. It is BRAVO’s expectation and requirement that this Code of Ethics be compulsorily complied with, in its entirety, by its directors, employees, partners, suppliers and contractors, in all business carried out involving the company.
Uberaba/MG, December 16, 2021.
Uberaba/MG, 16 de Dezembro de 2021.