Our code of conduct

Introduction

The purpose of this Code of Conduct is to establish the ethical principles and rules of conduct that should guide the internal and external relations of the members of Intragroup Tecnologia da Informação.
Our presence in the national and international capital markets and the participation of our members in different business units, cultures and geographic regions, which constitute globalized and competitive markets, require transparent standards of action and compliance with different legal systems.
Our reputation and credibility are the most important assets we have, and the ethical principles that guide our work contribute to maintaining the image of Intragroup Tecnologia da Informação as a solid and reliable entity for our customers, suppliers, consumers and employees in general.

We emphasize that our philosophy is based on integrity, independence and freedom of expression; These precepts will always be encouraged at Intragroup Tecnologia da Informação.

The guidelines of this code must be observed by all members of Intragroup Tecnologia da Informação, regardless of their attributions and responsibilities.

Compliance with the Code of Conduct by each of its members reaffirms one of our most important objectives, which is to maintain and consolidate Intragroup Tecnologia da Informação’ reputation.

Preamble

Anyone who has an employment relationship with Intragroup Tecnologia da Informação, for all purposes, will be simply called a member. The guidelines established in this Code of Conduct apply to all members and also, when applicable, to those who only have a commercial and/or statutory representative relationship with Intragroup Tecnologia da Informação.

General Guidelines

The criteria for admission and promotion will be the fulfillment of the basic requirements of each position, in accordance with the predetermined criteria and objectives. There will be no discrimination based on religion, philosophical or political conviction, nationality, origin, sex, age, color, sexual preference, marital status or physical or mental disability.

Intragroup Tecnologia da Informação expects from its members, in the exercise of their functions, the care and diligence that any person usually employs in their personal affairs, that is, an honest and dignified conduct, in accordance with the laws and ethical standards of the society.

Intragroup Tecnologia da Informação expects all company matters, without exception, to be treated with secrecy and confidentiality.

Intragroup Tecnologia da Informação expects, in the relationships between its members, cordiality in dealing, trust, respect, dignified and honest conduct, regardless of any hierarchical position, office or occupation.

It is up to each member of Intragroup Tecnologia da Informação to guarantee the others a work environment free from insinuations or restrictions of any nature, avoiding possible embarrassment.

Intragroup Tecnologia da Informação does not allow intrusion into the private life of its members inside or outside the work environment. Controls or insertions of any nature will be repudiated.

Intragroup Tecnologia da Informação’s business must be conducted with transparency and strict compliance with the law, and it is the responsibility of the members to ensure their respective compliance.
This responsibility also involves the adoption of appropriate measures when they become aware of irregularities practiced by third parties that may compromise the name and interests of Intragroup Tecnologia da Informação.
Any and all operations involving Intragroup Tecnologia da Informação must be supported by competent documents, covered by all legal formalities.

4.1. Members’ Liability
It is the obligation of every member to know, understand and practice the provisions of this Code of Conduct.
The members will also be responsible, within their attributions, of preserving the name and image of Intragroup Tecnologia da Informação.

4.2. Responsibility of Managers
Managers are obliged, among others, to act as follows:
Be a role model for your subordinates and other members;
Disclose to your subordinates the content of this code and make them aware of its importance and application; thus preventing any member, service provider or employee from committing a violation due to lack of information;
Identify members who have violated this code and discuss the matter with the Intragroup Information Technology Board;
Create a culture that manages compliance with this code and encourage members to raise questions and concerns regarding its application.

Intragroup Tecnologia da Informação expects its members to conduct business relationships in compliance with laws, legal market practices and, in particular, national and international standards relating to the economic order.

All members of Intragroup Tecnologia da Informação are expressly prohibited from making any improper payment (dubious or illegal) or granting privileges or advantages to public officials or the like, either directly or through third parties. It is also not allowed to favor, by granting undue benefits, customers, suppliers and competitors outside the usual practices of commerce, to the detriment of others.

5.1 Relationship with Customers

Satisfying the customer is the foundation of the existence of Intragroup Tecnologia da Informação. Therefore, it is the basic principle of Intragroup Tecnologia da Informação’s business action to serve the customer, with an emphasis on quality, productivity and innovation. And always with social, community and environmental responsibility, respecting the laws and regulations of each product and region of operation.

Customers must be served with courtesy and efficiency, being offered clear, accurate and transparent information. The customer must obtain responses, even if negative, to their requests, in an appropriate manner and within the expected timeframe.

Customer expenses related to meals, transportation, accommodation or entertainment are acceptable as long as they are justified for work reasons, carried out within reasonable limits and do not imply embarrassment or need for compensation.

5.2. Relationship with Suppliers

The relationship with suppliers must be lasting, without prejudice to the principles of free enterprise and fair competition.

The choice and contracting of suppliers must always be based on technical, professional and ethical criteria, observing the needs of Intragroup Tecnologia da Informação. They must be conducted through predetermined objective processes, such as competition or price quotation, in order to ensure the best cost/benefit ratio.

Dealing with suppliers of dubious reputation should be avoided.

5.3. Relationship with Competitors

The competitiveness of the products manufactured and/or marketed by Intragroup Tecnologia da Informação must be exercised based on fair competition.

Comments that may affect the image of competitors or contribute to the dissemination of rumors about them must not be made, and the competitor must be treated with the respect that Intragroup Tecnologia da Informação expects to be treated.

It is expressly prohibited to provide strategic, confidential or otherwise harmful information to Intragroup Tecnologia da Informação’s business to any third party, including, but not limited to, competitors.

5.4. Relationship with Family

Family members are understood to be the spouse, parents, siblings, children, uncles, nephews and cousins ​​up to 2nd degree, including those of the spouse.

The member who wishes to do business, on behalf of Intragroup Tecnologia da Informação, with one of his family members or people with whom his family members have a strict personal relationship, or even with companies in which such people are partners, have relevant participation in companies or exercise management position, must obtain written permission from your manager, who will be responsible for discussing the matter with the Board of ACADEMIA Intragroup Tecnologia da Informação.

5.5. Relationship with the Public Power

It is expressly forbidden for all members of Intragroup Tecnologia da Informação to offer gifts or benefits to public officials, their families or similar, either directly or through third parties.

The members of Intragroup Tecnologia da Informação and their families must not give or accept gifts or favors from customers, suppliers or competitors that correspond to values above R$ 100.00 (one hundred Reais).

If any member has received something in excess of this amount, and, for any reason, has not been able to refuse, he/she must forward the item(s) or amount to the Board of ACADEMIA Intragroup Tecnologia da Informação, which will make the appropriate donation.  The member must thank the person who offered them, informing him of the destination given to the gifts.

Members must ensure that their actions do not conflict with the interests of Intragroup Tecnologia da Informação, nor cause damage to its image and reputation.

Just for example, some situations in which the member would be facing a conflict of interest are listed below:

Have confidential information that, if used, can bring personal benefits;

Accept benefits, direct or indirect, that can be interpreted as retribution or to obtain a favorable position for Intragroup Tecnologia da Informação in business of interest to third parties;

Accept an external task or responsibility that affects your performance at Intragroup Tecnologia da Informação;

Acquire shares in companies with which Intragroup Tecnologia da Informação has a relationship, whether they are customers, suppliers, service providers or competitors, based on privileged information, or even provide such information to third parties;

Use Intragroup Information Technology resources to meet private interests;

Maintain private business relationships with Intragroup’s client companies, suppliers, service providers or competitors, through which they may obtain privileges as a result of their attributions at Intragroup Tecnologia da Informação;

Hiring family members or asking other members, customers or suppliers to do so outside the established principles of competence and potential.

The member, faced with any situation of conflict of interest, must promptly report what happened to his manager, who will be able to resolve the issue or discuss the matter with his respective manager or with the Board of ACADEMIA Intragroup Tecnologia da Informação.

The members of Intragroup Tecnologia da Informação must not perform activities or engage in organizations that compromise their dedication to Intragroup Tecnologia da Informação or adopt behaviors that generate a conflict of interest with their responsibilities and attributions. Nor can they act in any other segment whose duties may in any way compromise their efficiency, integrity or jeopardize the confidentiality and security of Intragroup Tecnologia da Informação.

Communication with shareholders will take place through the director of investor relations.

The relationship with shareholders and investors must be based on accurate, transparent and timely communication of information that allows them to monitor the activities and performance of Intragroup Tecnologia da Informação, as well as the search for results that bring positive impacts on the market value of the company Intragroup Tecnologia da Informaçã.

The treatment given to shareholders does not depend on the number of shares they hold, subject to legal restrictions. All will be provided with a flow of information with equal treatment.

If any member has relevant and privileged information about the shares of Intragroup Tecnologia da Informação, it is prohibited by law to trade, directly or indirectly, for any reason, shares of Intragroup Tecnologia da Informação, or even to disclose this information to third parties.

Intragroup Tecnologia da Informação expects the member to comply with the legal provisions on the matter, as well as any and all policies, instructions or guidance from Intragroup Tecnologia da Informação in this regard.

By law, violation of this rule is punishable criminally and civilly.

Intragroup Tecnologia da Informação will not restrict the political-partisan activities of its members. However, they must always act on a personal basis and in such a way as not to interfere with their professional responsibilities.

It is strictly prohibited to carry out political-partisan activities in the work environment that involve, in any way, Intragroup Tecnologia da Informação resources.

Members will also not be able to wear company uniforms when carrying out political activities.

It is strictly prohibited to broadcast any form of political advertising on the premises, vehicles, publications or any other property of Intragroup Tecnologia da Informação.

The member who participates in political activity does so as a citizen and not as a representative of Intragroup Tecnologia da Informação.

It is up to all members to ensure the conservation of Intragroup Tecnologia da Informação assets, which include facilities, machines, equipment, furniture, vehicles, values, brands, patents and others.

It is not allowed to use Intragroup Tecnologia da Informação’s equipment and other assets for private use.

Internet and telephone access, as well as the use of e-mails, software and hardware must be restricted to the member’s professional activity, observing the other provisions established in Intragroup Tecnologia da Informação’s policies, regulations or guidelines.

Members are not authorized to use Intragroup Tecnologia da Informação’s address to receive private correspondence, except in authorized cases.

Only certain members are authorized by company management to speak on behalf of Intragroup Tecnologia da Informação and make comments about it to the press or external groups.

Transparency is essential to allow the correct evaluation of Intragroup Tecnologia da Informação by market agents.

Intragroup Tecnologia da Informação’s accounting standards and practices must be strictly observed, generating consistent records and reports and allowing a uniform basis for evaluation and disclosure of Intragroup Tecnologia da Informação’s operations and results. Thus, it is necessary to ensure the accounting of any and all assets, rights and obligations that Intragroup Tecnologia da Informação is obliged to do.

The balance of the environment and the preservation of nature are of fundamental importance for the business activity of Intragroup Tecnologia da Informação.

Intragroup actively participates in the preservation of the ecosystems where its industrial units are located, whether through attention and care in the manufacture, handling and transport of its products, or through helping to preserve forest reserves, preventing the waste of natural resources, promotion of conservation campaigns to raise awareness among regional communities, in addition to support for various public and private projects related to the preservation of the environment.

Therefore, it is the responsibility of each member to contribute to the conservation and improvement of the environment and its ecosystems.

The guidelines of this code make it possible to evaluate most situations and minimize the subjectivity of personal interpretations of moral and ethical principles, but do not necessarily detail all situations that may arise in the daily life of each member. Thus, in case of doubts regarding the application of the guidelines of this code, the area manager should be consulted.

Members are expected to adhere to these guidelines under all circumstances.

A member who violates an Intragroup Tecnologia da Informação conduct, practice or policy, or permits a subordinate to do so, will be subject to disciplinary action, up to and including dismissal. Any member who becomes aware of a violation of any aspect of this code, by any person, must bring this fact to the attention of the manager in his area.

Intragroup will have the Intragroup Tecnologia da Informação Board, which will be responsible for judging the most serious cases of violation of this code and imposing the appropriate disciplinary sanctions, as well as resolving on the clarification of doubts regarding its text.

This Council will meet whenever necessary.

This Code of Conduct will be effective as of this date. The conduct guidelines contained in this code will be made known to all members.

No member can claim ignorance of the guidelines contained in this code under any circumstances or under any argument.

This Code of Conduct came into force on January 1, 2018.

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