Code of Ethics and Conduct
OBJECTIVE
Establish a systematic approach to values that guide the company, as well as the personal and professional conduct of its employees, collaborators, suppliers and contractors.
TERMS AND DEFINITIONS
Good faith - means sincere, honest behavior, guided by integrity and ethics, including the fair and just way of treating other people, matters, business, etc.
Corruption - means the effect or act of corrupting someone or something, with the purpose of obtaining advantages over others through means considered illegal or illicit.
Active Corruption - means offering or promising undue advantage to a public official, in order to influence him to perform, omit or delay an official act.
Passive Corruption - means requesting or receiving, for oneself or others, directly or indirectly, even outside the role or before assuming it, but because of it, undue advantage, or accepting promise of such an advantage.
Fraud - means any cunning, deceptive, dishonest and bad faith act, action or omission, with the intention of harming or deceiving others, in order to obtain an advantage for one's own benefit or that of third parties.
Money laundering - means economic-financial practices with the aim of hiding and/or disguising the illicit origin of goods or assets, in order to make them appear legitimate.
Bribe - means the payment of any value, good or advantage offered or given to a third party in exchange for a favor related to a business or benefit obtained, both in the public and private sphere.
Bribe - means the act of promising, offering or paying to an authority, government official or public agent a benefit, value, goods or advantage of any kind with the aim of obtaining a benefit. It is one of the ways to practice Corruption.
Terrorism - means the practice of acts through the use of violence, physical or psychological, against people, groups, authorities, entities or societies, in order to inspire fear, panic and, thus, obtain specific objectives.
RESPONSIBILITIES
Contact Channels with the Compliance Committee:
• Electronic access via email: etica@intelcav.com.br
• Telephone access at: (54) 3341-8021
• Written access via addresses:
Barueri Unit
Alameda Caiapós, 493, Tamboré Barueri – SP - CEP:06460-110
Attention of the Compliance Committee
Getúlio Vargas Unit
Rua Irmão G Leão, 1102, Getúlio Vargas – RS – CEP: 99900-000
Attention of the Compliance Committee
GENERAL RULES
Message from Senior Management
This is the INTELCAV Code of Ethics and Conduct that addresses the values that guide the company, as well as the personal and professional conduct of its employees, collaborators, suppliers and contractors (“Code”).
Inspired by our values and beliefs, this Code aims to support constant growth and the search for excellence and integrity. We hope you read, understand and use this guide as a reference for your everyday actions.
What is this code?
It is a document that brings together the main ethical guidelines for conducting our business, that is, it describes the main guidelines in relation to the ethical behavior that we expect from our managers and employees. Furthermore, it establishes guidelines and procedures related to combating corruption, money laundering and terrorist financing, as well as guidelines that seek to ensure that all INTELCAV Employees understand and act in accordance with applicable legislation.
We believe that these principles, values and guidelines are essential to guide decisions and conduct in the development of our activities.
Who does this code apply to?
This Code applies to all areas and all members of the company, temporary or not, including, but not limited to, all employees, representatives, collaborators, partners, suppliers, third parties and contractors, as applicable, as well as anyone acting on behalf of INTELCAV, in addition to the members of the Board of Directors, its Committees and Senior Management (“Employees”). It is the responsibility of INTELCAV administrators and managers to ensure that all Employees know and fully apply this Code, strengthening the principles and values established in this document.
Vision, Mission and Values
VISION - To be the best company in its segment, preferred by the market for its quality, innovation, safety, flexibility and socio-environmental responsibility.
MISSION - Provide products and services with excellence in quality and safety, exceeding the expectations of our customers, ensuring returns for shareholders and employee growth.
VALUES
Ethics - We always act correctly and fairly in relation to shareholders, employees, customers, suppliers, government, the local community and society in general, respecting current legislation and our organizational policies.
Integrity - We honor our commitments and take responsibility for our actions.
Respect - We respect people, their beliefs, their values and their individuality. We value diversity of ideas and opinions, treating divergences and differences with dignity.
Cooperation - We are always willing to share our ideas and knowledge, encouraging cooperative efforts between all hierarchical levels and in all company activities.
Commitment - Our efforts are directed towards achieving our objectives and goals, generating the expected results, through the practice of our corporate values.
Transparency - Our communication, between all hierarchical levels, with our customers and our shareholders, is clear and open.
Effectiveness - We work in an agile, persistent, responsible manner, ensuring that the company's actions are carried out.
How should we act
Working with Health and Safety
We believe that all individuals have the right to a decent, safe and healthy working environment. INTELCAV does not tolerate or use any type of forced, slave, involuntary, prison, or irregular labor, or allow its suppliers to do so. Additionally, INTELCAV does not tolerate or use any type of child labor, and therefore does not hire anyone under 16 years of age. Intelcav reaffirms its unwavering commitment to not tolerating, in any way, the exploitation of child or adolescent labor, vehemently repudiating any form of exploitation. We are fully aware of the public policies that seek to protect the fundamental rights of children and adolescents, as established in LAW No. 8,069, OF JULY 13, 1990, which provides for the Statute of Children and Adolescents. We are dedicated to actively contributing to the development of social well-being in all the communities in which we operate. Our mission is based on strong values of social responsibility and business ethics, reflecting our commitment to creating a work environment and society where the rights and futures of younger generations are protected and valued.
Promoting an inclusive and diverse work environment
We value diversity and seek to include all people without distinction in our organization. We ensure that everyone develops their potential regardless of their cultural or ideological differences, opinions, gender, color, ethnicity, origin, political convictions, religious beliefs, generation, marital status, union membership status, social class, sexual orientation, level of education and special physical or intellectual needs.
IntelCav believes that in addition to repudiating discrimination, it is important to support and value these people with equal employment conditions. We promote lectures on diversity and social inclusion that guarantee a work environment free from prejudice, we do not accept any hateful attitude that aims to judge people for their differences.
Appreciation for an inclusive, respectful and accessible environment requires special attention to certain vulnerable groups and minorities. This is how we want, every day, to inspire inclusive practices in relationships between leaders, teams, customers, partners and suppliers. We know that inclusion involves respecting freedom and ensuring good social coexistence for people with different identities, cultures, origins and religions. Effective inclusion demands that each professional's individuality is actively valued, understanding diversity naturally, with autonomy and empowerment.
Human Trafficking
IntelCav understands that it is extremely important that we all commit to not colluding with Human Trafficking. And not just limited to our organization, but we are also attentive to our suppliers. We have people trained to identify and deal with this situation if we become aware of it, as this type of illegal activity involves the recruitment, transport, transfer, shelter or collection of people using violence, threats or other forms of coercion for exploitation purposes. Victims of human trafficking are often subjected to imposed working conditions, servitude, sexual slavery, organ removal, forced begging and other forms of exploitation. We understand that together, we can work to end human trafficking and help protect the human rights of everyone.
Promoting Female Empowerment
We have women on our staff who occupy high hierarchical levels, we guarantee equal pay between men and women who perform the same role. We promote equality and respect at all times, we do not tolerate sexual, physical or verbal abuse, insults, intimidation or any type of disrespect towards women. IntelCav is committed to female empowerment, and as part of this commitment, offers childcare assistance resources to women who are mothers of children under two years of age. We recognize that supporting women in their journey to maintain and achieve the work positions they desire is fundamental, as this represents an inalienable right. This resource provides women with the safety and comfort they need to perform their duties with dignity.
Caring for the environment
We manage risks and impacts with the aim of not causing harm to employees, Collaborators and the communities in which we are present.
Competing fairly
We believe that free competition is the best way to promote a fair and healthy business environment. We act with integrity and promote a business environment free from fraud and manipulation of any kind.
Avoiding Conflicts of Interest
When making decisions on behalf of INTELCAV, we exclusively consider the company's best interests.
Fighting Corruption
We have zero tolerance for corruption, regardless of its form, and we believe that the abuse of power for personal gain is not a fair way of doing business. We guarantee that all Complaints received by the IntelCav Organization are properly examined with independence, transparency, integrity and ethics. The registration of reports of corruption or bribery, whether anonymous or not, which can be made by any interested party, through the contact channel on page 2 of this document.
Using the Company's resources correctly
INTELCAV assets must only be used to carry out professional activities necessary to conduct our business.
Our Commitments
With Customers
INTELCAV Employees understand that in relation to customers they must: Avoid those whose reputation is dubious and/or does not comply with ethical principles compatible with the stance of INTELCAV and/or the market in which it operates. Strive for transparency, dignity and loyalty, not providing misleading or unfounded information and, under no circumstances, granting advantages, direct or indirect, that contradict company policies.
Maintain absolute secrecy and treat all information obtained confidentially.
With Suppliers and Partners
The hiring of suppliers by INTELCAV must be based on the following criteria: Suppliers that have a dubious reputation and/or do not comply with ethical principles compatible with the stance of INTELCAV and/or the market in which it operates should not be hired . Supplier hiring must always be based on technical, ethical and professional criteria.
Whenever possible and necessary, the hiring of suppliers must respect the principles of free competition, which includes, whenever possible, a price quotation and quality measurement procedure, guaranteeing the cost-benefit ratio.
With Third Parties and Correspondents
The rules contained in this Code are applicable to everyone who represents INTELCAV, including third parties and correspondents.
Service provision contracts signed with third parties and correspondents must be based on INTELCAV's needs and contain clauses referring to its subjection to this Code. No third party, acting on behalf of INTELCAV, may exercise improper influence over public officials or be appointed by public officials to provide services for INTELCAV or its clients.
With Regulatory and Government Bodies
INTELCAV Employees understand that in relation to regulatory and governmental bodies they must:
Never respond to any requests made by employees of these bodies, which violate ethical principles, to obtain facilities in obtaining any type of authorization or license. Under no circumstances, offer any type of benefit or advantage to employees of these bodies, which violate ethical principles, to obtain benefits in obtaining any type of authorization or license.
Conflict of interest
A conflict of interest may occur when personal objectives interfere with the evaluation and objectivity of an Employee in relation to defending the interests of clients and the development of other activities representing INTELCAV. Examples of circumstances in which there is a conflict of interest are:
The existence of a direct or indirect financial advantage for the Employee. The relationship with any competitor, supplier, client or partner that influences the development of the Employee's professional work, such as, but not limited to, defending the interests of clients.
Situation involving a family member or friend of Employees, which compromises the defense of clients' interests or the development of their professional activities before and/or on behalf of INTELCAV. Request or accept gifts or any type of undue advantage from suppliers, customers or any others who are or will be part of business with INTELCAV or seeking to do so (unless in accordance with company policies regulating the receipt of gifts , bonuses and entertainment, which allow the acceptance of gifts of small value).
Misuse of INTELCAV assets (including tangible assets, confidential information, non-public information or business opportunities). Employees must immediately inform the Compliance Committee of any situation that could be perceived as a conflict of interest.
Gifts, Gifts and Gratuities
It is prohibited for Intelcav Employees to accept or give gifts, gifts and/or gratuities to customers or suppliers, requiring prior knowledge and authorization from the Compliance Committee.
The Compliance Committee must inform the position regarding the receipt or offering of any gift, gift or gratification that implies an obligation on the part of the recipient, or that gives rise to consideration for preferential treatments in obtaining contracts, services, goods or business with Intelcav.
The receipt and offering of gifts, gifts and gratuities will be acceptable, in cases where these: Are not seen as a bribe, kickback, payment or undue attempt to exert influence. Do not cause embarrassment when revealed publicly. They are of small value, that is, limited to the total value of R$ 200.00 (two hundred reais). Do not violate the INTELCAV Code of Ethics and Conduct.
Anti-Corruption Policy
In addition to what is already set out in this Code, INTELCAV reiterates its position and commitment to combating any and all acts of corruption, whether related to money laundering, bribery, fraud, payments of bribes, active or passive, direct or indirectly. We reiterate our commitment to act ethically, transparently, in good faith and in accordance with Brazilian legislation, especially rules related to anti-corruption. Therefore, we expect the same commitment from anyone who has a relationship with or acts on behalf of INTELCAV, whether with Intelcav itself or with its affiliates.
It is prohibited for any INTELCAV Employee, or affiliate, to offer, promise, grant, authorize, deliver or pay any amount, donation of gifts, gifts or gratuities to any government authority, third party related to them, or to any other person or entity from the commercial or private sector, with the intention of inducing the recipient to abuse their position or obtain undue advantages, in violation of any Applicable Laws or the provisions of this Code.
It is also prohibited to request, accept or receive, directly or indirectly, any promise or payment for oneself or any person, public or private, in exchange for the execution or omission of any act in the exercise of one's functions. We also condemn the offering or payment of facilitation to accelerate or favor the analysis and obtaining of licenses, authorizations and permissions for INTELCAV. If any request, request, demand or requirement is made, whether directly by the public agent, or indirectly through any third party or intermediary, it must be immediately and unequivocally rejected.
Hiding or disguising the source of funds in our transactions is prohibited, and such practice is considered money laundering, an action understood as a crime according to Brazilian law. We prohibit secret operations, not registered in the name of INTELCAV, or affiliates, that are not correctly and fully reflected in the respective financial statements. Furthermore, the misuse of the products and services offered by us for the practice of financing terrorism, laundering or hiding assets, rights and values is also prohibited, taking the necessary measures to mitigate such risks.
In the same way, the maintenance and development of processes that could constitute evidence of terrorist financing, money laundering or concealment of assets, rights and values is prohibited. All Collaborators, as well as any other person or entity acting for or on behalf of INTELCAV, are responsible for the integrity of the information, reports and records under their control and must never make a false or misleading statement in an INTELCAV record or to any person , including internal or external auditors, regarding INTELCAV's financial activities and various business activities.
Any type of direct or indirect contribution to political parties, organizations or individuals acting in party politics is prohibited, as a way of obtaining an illegal advantage. To reduce the risk of third parties acting as facilitators of bribes, kickbacks, any contributions to philanthropic and/or social projects, including schools, educational funds and infrastructure projects, must be previously approved by the Compliance Committee. Donations must only be made for legitimate philanthropic reasons, to serve humanitarian interests and to support cultural or educational institutions, and duly approved by the Compliance Committee.
Violations of the Code of Ethics and Conduct and Protection against Retaliation
It is the responsibility of all Employees to report any misconduct and suspected violation of the guidelines and terms set out in this Code of Ethics and Conduct, regardless of the identity or position of the person suspected of the infraction.
Violation communications, whether made by an identified person or not, must be directed to the Reporting Channel, using the contact at the bottom of the page.
Contacts may be made anonymously and will be treated with due confidentiality. All information received will be treated confidentially and confidentially by the Compliance Committee. The Compliance Committee is committed to maintaining confidentiality regarding the identity of those who reported and/or participated in the investigation into the reported violation.
Intelcav repudiates any discrimination or retaliation against Employees as a result of a possible complaint, a suspicion of misconduct, even if it is found at the end of the investigation process that the complaint was unfounded.
If the occurrence of any type of discrimination or retaliation is identified, the Employee who adopts such behavior will be subject to internal proceedings, which may culminate in their dismissal or contractual termination.
Omission in the face of possible violations will also be considered unethical conduct. Therefore, all Employees have the duty to immediately report any violation of this Code of Ethics and Conduct.
Proven violations will result in varying disciplinary actions, depending on the severity of the situation. In the case of third parties and correspondents, failure to comply with the Code of Ethics and Conduct may result in immediate contractual termination.
Management of the Code of Ethics and Conduct
The management of the Code of Ethics and Conduct is the responsibility of the Compliance Committee, whose function is to promote the actions necessary for its implementation, clarify doubts regarding its content and possible situations of inappropriate ethical conduct and carry out the review of the Code, when necessary.
All Employees must be fully aware of the provisions of the Code of Ethics and Conduct and seek to understand its guidelines.
Declaration of Commitment to Human Rights
Supported by the ethical principles that govern our guidelines, Intelcav Tecnologias e Cartões positions itself in favor of the right to life, peace, human dignity, social justice, development, democracy, individual and collective security and, Why not say, the right to happiness. We believe that through empathetic behavior, welcoming habits, respect for differences, protection of the environment, commitment to human rights and fundamental rights, we contribute to the transformation of the world.
We provide access to the universal declaration of human rights on our websites and internal communication networks.