Code of Conduct

The Code of Conduct is a guide that consolidates the company’s values and principles and translates them into words that describe, in a clear and concise manner, the expected behavior of each professional. As a complement to this Code, some Units of the Organization have policies, guidelines and procedures related to their performance in the company and the daily life of the professional.

Each of us must read this document in its entirety, as well as the policies, guidelines and procedures relating to the Unit with which it is associated, and the other Units with which it interacts, in addition to being attentive to the guidelines published on the intranet. Although the Code of Conduct, policies, guidelines and procedures seek to cover the widest possible range of situations, doubts may arise. Do not hesitate to contact your board of directors for clarification.

Business Conduct

The SETAPE Group’s business relationship is guided by ethics and transparency with all stakeholders and in all dimensions. It is essential that our professionals are uncompromising in observing these principles of conduct in their work on behalf of the company.

All company professionals have a mission to help our clients achieve their strategic and operational objectives. In addition, they must try to understand their expectations and reach them or, even, if possible, exceed them within the established business context.

Conduct of Our Professionals

SETAPE is the expression of the value of its professionals, it is the result of the combined efforts of individuals of similar vocations, with the aim of creating conditions for their professional and human fulfillment. It is the responsibility of all professionals to contribute to achieving this goal.

In our activity we seek equal opportunities and we must provide all professionals with the same treatment and working conditions without distinction of appearance, physical or health condition, color, marital status, gender, age, language, nationality, political or other opinion, social origin, sexual orientation, race, religion or any other condition not linked to strict professional competence.

Likewise, our company does not tolerate any type of illegitimate discrimination against third-party professionals or any individual or group with which it relates.

Safety, Environment and Health

Safety, Environment and Health refer to the conditions and factors that affect, or could just affect the safety, the environment and the health of professionals, external consultants, third parties, visitors or anyone else in SETAPE environments and in client companies. It also includes initiatives in favor of the health of professionals, for occupational, non-occupational topics, aspects of food and other healthy habits.

SETAPE facilities and those operated by it must operate with the permits, approvals and controls necessary to protect safety, the environment and health.

In all its activities related to our projects, corrections of procedures carried out outside the safety and technical standards established by SETAPE must be identified and corrected or requested.

Any situation that threatens your physical integrity or that of your colleagues in the workplace must be identified, you must report the fact to your manager or to the area of Safety, Environment and Health.

Emergency situations, such as environmental accidents, should be quickly reported to their managers or responsible areas, so that the relevant measures are immediately adopted.

Do not work under the influence of alcohol or drugs.

Do not be in possession of weapons of any kind, unless you have the legal possession of the weapon and there is formal authorization from the company to exercise your function always with the specific weapon for which you have the legal possession.

Right to Free Trade Union Association

Freedom of association is a right conferred by law and SETAPE recognizes this right, respecting the participation of its professionals in unions and making no discrimination whatsoever.

Use of Electronic Media, Cell Phones, Cameras

Internet access and the use of telephone, e-mails, software, hardware, pen drives, external drives, cloud storage, CD/DVD and any other electronic system are means made available exclusively by the company for professional use.

According to Brazilian law, SETAPE is responsible for the actions of its professionals and expects them to use these means with discretion, respecting the company’s internal policies.

All information written or stored in electronic media is the property of SETAPE and can be monitored.

You can use SETAPE’s electronic media for personal purposes, as long as it does not affect the productivity of your work and does not disrespect the company’s policies and procedures. For example, it is occasionally acceptable to make phone calls or send personal emails from your workplace. Excessive personal phone calls or emails constitute misuse of these means.

Do not download, upload or otherwise transmit data about pornography, nudity, indecency, vulgarity, obscenity or other inappropriate material.

Do not disable the company’s information security tools.

Do not install software or connect hardware without a license or authorization from the Systems area.

Do not use the facilities or use the company’s means of communication for purposes that could be harmful to you or SETAPE.

Photographs should not be taken in the environment of external companies (customers) without the express authorization of those responsible.

Preservation and Proper Use of Company Assets

The company’s assets can be financial, physical or intellectual property, such as financial resources, movable and immovable property, equipment, tools, supplies, communication facilities, computer programs, data, information, technology, documents, knowledge (know how), domains, patents, trademarks, copyrights and any other resources or assets that are intended to promote the company’s business and activities.

SETAPE professionals are responsible for using the company’s assets and our clients’ work-related assets responsibly and for protecting them from wear and tear, except for normal wear and tear resulting from proper use, loss, damage, misuse, theft, misappropriation or violation.

Cleaning and Organization

It is the obligation of professionals to maintain the cleanliness and organization of the workplace and to conserve the assets and resources made available by SETAPE and its customers to carry out their function, as well as to avoid waste and unnecessary expenses, their own and that of other professionals, respecting company assets and the environment.

Harassment

“Harassment” means any action, conduct or behavior that an individual or group of individuals may deem to be inappropriate, humiliating, intimidating or hostile. Actions or behaviors that are or could be interpreted as moral, sexual or any other type of harassment should be avoided. In addition, everyone should be careful about actions or behaviors that may be acceptable in one culture, but are not acceptable in another.

“Moral harassment” is characterized by the exposure of professionals to embarrassing and humiliating situations during the exercise of their function repeatedly and for a prolonged period. It is what is called “moral violence”. These acts aim to humiliate, disqualify and emotionally destabilize the victim’s relationship with the organization and the work environment, which can put their health or job at risk.

“Sexual harassment” is characterized by the embarrassment of colleagues by means of embarrassing and constant insinuations with the objective of obtaining advantages or sexual favoring. This attitude can be clear or subtle; explicit or implied; written or gestural; come in the form of coercion or blackmail.

When traveling for work, find out about local behaviors, practices and customs to ensure that there is no disrespect or misunderstanding when dealing with a native.

Deviations from the Code of Conduct

Any and all indications of an act or behavior incompatible with the Code of Conduct, or non-compliance with the laws to which the company is subject, must be reported to the SETAPE management. This can be done directly to your coordinator, manager, manager and or board.

In this Channel, both the internal and the external public can communicate, in a confidential and secure manner, conduct that may represent a violation of the Code of Conduct, policies, guidelines, internal procedures or current legislation. The recording of reports can be done in three ways:

If the misconduct is proven, the necessary measures will be taken. The person who reports any evidence of violation of the Code of Conduct will not suffer any type of retaliation.

Consequences and Treatment for Deviations from the Code of Conduct

Deviations from the Code of Conduct, policies, guidelines, internal procedures or current legislation can have serious consequences for those involved, for the company and for society itself. When the deviation is proven, measures compatible with the seriousness of the facts will be applied, which may include: verbal or written warning, suspension; or more severe sanctions (termination of employment or service contracts, commercial or business partnership agreements, among others). In addition, the identification of specific situations may give rise to corrective actions or improvement of existing normative instruments, such as revision of standards, procedures, the Code of Conduct itself, training, among other actions.

Cases involving unlawful conduct may be referred to the competent authorities, making those responsible subject to administrative, civil or criminal proceedings.

Resources and External Consultants

The relationship with partners and service providers is considered a central element in SETAPE’s strategic positioning. In this sense, the company seeks collaborative relationships with a long-term perspective, established on ethical grounds, guided by trust and the definition of fair trading conditions.

SETAPE understands that the relationship with partners and service providers must be guided by the search for quality, technical reliability and added value for the end customer.

SETAPE professionals must choose their resources for our projects from the perspective of objective, technical and ethical criteria, conducted by formally defined procedures, and with the purpose of ensuring the best cost-benefit ratio, and that it is ethical for the company and its customers.

Society and Environment

A company is a social organization that is justified while preserving its capacity to add value to the society that welcomes it. SETAPE understands this dimension and seeks to actively contribute to society and the environment in which it operates and with which it relates.

This positioning guides the company’s strategic decisions, considering the aspects of economic, social and environmental sustainability of its projects, products and services, seeking to maximize its benefits to society and respecting the relevant legislation.

A SETAPE espera de seus profissionais e incentiva os seus clientes, parceiros e seus recursos a adotarem posicionamento ambiental e social semelhante, a fim de promover a sustentabilidade na sua cadeia de valor.

Fair Competition

The free competition law seeks to guarantee fair and balanced competition opportunities in the market and is a constitutional principle. For this reason, SETAPE seeks, in its bidding process, the commercial and technical solution best suited to customer demands. The relationship with competitors is based on respect, ethics, good commercial practices and Brazilian legislation.

SETAPE prohibits and repudiates any conduct that restricts competition, such as entering into bidding agreements between competitors, conspiracy to fix prices, market sharing, formation and maintenance of monopolies or oligopolies.

SETAPE does not tolerate violations of Brazilian competition law and all professionals are obliged to comply with it.

Conflicts of Interest

The conflict of interests occurs when the professional uses his influence or acts with the objective of benefiting particular interests, and not the interest of SETAPE, and may even be contrary to the interests of the company, causing or not causing damages and/or losses.

SETAPE respects the affective and kinship relationship that unites our professionals. However, it understands that some limits need to be established in order to avoid conflicts of interest.

Professionals and third parties acting on behalf of SETAPE have an obligation to identify and avoid situations that may lead them to make decisions motivated by interests other than those of the company.

Confidential Information and Inside Information

SETAPE professionals are committed to not disclosing information about the company, suppliers, customers and partners, whether privileged or confidential.

Information that is or may be considered confidential includes, as appropriate: technical, financial or commercial information, business opportunities, specifications, drawings, diagrams, models, samples, flowcharts, computer programs, strategies, budgets, plans, technologies, ideas, concepts, knowledge, discoveries, formulas, methods, projects, analyzes, procedures, calculations, among others, regardless of the form in which such documents are made available.

In addition, confidential information can be defined contractually with third parties, whose disclosure and access are limited to certain people.

“Inside information” is considered the relevant information not yet disclosed in the market, of which the professional has knowledge in the exercise of his functions, capable of influencing in a considerable way:

• quotation of transferables securities issued by the company to which the information refers or referred to;
• investors’ decision to buy, sell or hold those transferables securities;
• investors’ decision to exercise any rights inherent to the condition of holder of securities issued by the company to whom the information refers or which is referenced to them.
• “Transferables securities” are documents issued by companies or other entities (public or private), which represent a set of rights and duties relating to their holders and which can be bought and sold on the transferables securities markets. Examples of transferables securities: shares, debentures, convertible notes and promissory notes.

The disclosure of confidential information can harm the company and/or third parties, and it is considered contractual breach, both of its service provision contract with SETAPE and of confidentiality commitments that may have been entered into between SETAPE and clients, subject to payment of fines and damages.

Professionals who, by virtue of their activity or as a result of their responsibilities, have access to privileged information and transferables securities based on that information or provide this information to people who can trade it, are acting against the law and can be held civilly, administratively and criminally liable.

Information security

Information Security aims to strengthen the security of SETAPE’s Intellectual Property, guaranteeing more protection to its information assets, such as storage systems, information generated in our company or made available by third parties.

All files and data related to professional activity created, received or stored in the SETAPE system, whether by e-mail, network or corporate cell phone, are property of SETAPE and constitute professional and legal assets of the company.

• Do not install software without proper authorization on your computer. The acquisition and installation of new programs must be approved by the Information Security area and the product must be accompanied by a legally acquired license.
• You must not share your credentials, be they login, password or badge; these data are individual and non-transferable and their custody, confidentiality and maintenance are the personal responsibility of the qualified user.
• Even if information is not your responsibility and you happen to have access, do not disclose it or misuse it.

São Paulo, October /2020