CODE OF CONDUCT AND ETHICS

INITIAL MESSAGE

Acting ethically and transparently is not just a matter of image or an attempt to avoid legal problems. We understand that it is a way of being for everyone who is part of our Organization, ensuring our pride in being a part of it!

Integrity, honesty, and respect when dealing with colleagues, leaders, clients, partners, and suppliers are our obligations and commitments that contribute to building healthier and more prosperous relationships.

 

PURPOSE OF EFFICAZX

This document gathers the principles and values adopted by EFFICAZX and aims to serve as an internal regulation, with the purpose of promoting a consistent posture among all involved in the company, conducting their activities within the rigorous technical, moral, and ethical standards recognized by national and international society.

 

SCOPE OF THE CODE OF ETHICS

The code of conduct binds all employees of EFFICAZX who are part of its team, including executives, partners, employees, partners, clients, third parties, and company suppliers.

 

COMMITMENT TO GOOD CONDUCT

We consider the good conduct of all who are part of EFFICAZX as a fundamental standard, as it represents our commitment to ethics in an integral way. Thus, all direct and indirect employees, as well as partners, are encouraged to adopt ethically oriented norms and principles.

Since the promotion of ethics permeates all company behaviors, actions contrary to this are strictly prohibited. Therefore, good conduct aligned with EFFICAZX is related to:

  • Not using the position of a direct and/or indirect EFFICAZX employee to gain any personal advantage;
  • Complying with all EFFICAZX rules and regulations;
  • Reporting any violation or non-compliance with the rules, practices, and postures required in this Code;
  • Ensuring the confidentiality and privacy of EFFICAZX data related to clients, businesses, and direct and/or indirect employees;
  • Safeguarding the security of privileged information, accessible due to position or responsibilities, as they are reliable and relevant data that should not be disclosed to the public and should be treated with appropriate rigor and confidentiality;
  • Acting with respect for the intellectual products of EFFICAZX;
  • Preserving the good image and reputation of EFFICAZX;
  • Acting with respect, courtesy, and politeness towards all team members, partners, and other professionals, regardless of their position;
  • Immediately rejecting any form of sexual harassment, moral harassment, or negative discrimination, as well as any other form of physical or verbal violence, intimidation, coercion, threat, or humiliation, and immediately reporting it to Compliance for immediate investigation of the conduct;
  • Ensuring complete transparency in actions taken;
  • Rejecting any action aimed at personal gain or benefiting close family members or friends;
  • Refusing to accept money, valuables, properties, or services, directly or indirectly, from suppliers or third parties;
  • Avoiding situations of conflict of interest, reporting to Compliance any situation that could be interpreted as such, so that decisions are made based on ethical guidance;
  • Respecting fair competition, so any contact with direct competitors should be approached cautiously, based on a strategy aligned within the Company, grounded in ethics and compliance with competition laws, to avoid illegal practices, fraud, and abuses of power;
  • Considering and respecting the expectations of all clients, taking into account their specificities in decision-making;
  • Conducting prior risk assessments when contracting business partners, evaluating the potential supplier in terms of health, safety, environment, reputation, integrity, qualifications, conduct, and the ability to meet the needs of EFFICAZX in accordance with its policy;
  • Safeguarding information security, using IT systems appropriately to minimize risks such as virus attacks, invasions, and information security breaches.

 

COMMITMENT TO PEOPLE: WORK ENVIRONMENT

We do not allow any type of disrespectful and unethical treatment among people, suppressing any behavior or manifestation that indicates discrimination of any kind.

It is our commitment to create a positive support environment for all forms of positive discrimination, aiming for equality, including:

  • Gender, to align with the specific needs of women and their diverse roles in Portuguese society;
  • Race, to embrace and give visibility to individuals who self-identify as Black or Mixed-race;
  • LGBTQIA+ individuals, to ensure a diverse space in terms of sexual orientation;
  • Elderly or young people, to encourage intergenerational experiences with respect for their individual qualities and professional experiences;
  • People with disabilities, to ensure their inclusion in the workplace.

We also understand that, in addition to the need for an internal policy, this should be reflected in the relationship practices with our clients, promoting involvement and concern for non-discriminatory conduct and policies.

 

COMMITMENT TO OUR CLIENTS

  • We develop services that provide real benefits.
  • We fulfill our promises, keeping services within their specifications.
  • We provide services with a good cost/benefit ratio, tailored to each situation.
  • We provide information about correct and safe practices for using the services.
  • We provide constant feedback, within our limitations, to clients, informing them about each action involving their name throughout the service chain.
  • We record and address complaints about services, taking necessary measures to improve service efficiency and effectiveness.

 

COMMITMENT TO SUPPLIERS

For us, integrity is a criterion for eligibility and maintenance of contracts. We honor contracts, conditions, values, and agreed-upon deadlines. We prioritize suppliers with high ethical standards. We prefer suppliers that meet our quality and cost requirements. We value suppliers committed to the end result and ethical anti-corruption conduct.

 

COMMITMENT IN CONTRACTS WITH THE PUBLIC ADMINISTRATION

Any act by our representatives regarding legal entities, national or foreign, is based on ethics and transparency, aiming for compliance with Brazilian and international compliance legislation.

We do not promise, offer, or give directly or indirectly any undue advantage, whether pecuniary or not, to a public official or third party, with the aim of improving their position as a competitor or executor of a public contract. Our employees and representatives are prohibited from engaging in any illegal practices and making payments not provided for by law or contract.

In public tenders, we maintain the same values and conditions presented to private clients to ensure the integrity and experience contained in our services and products.

We keep a record of all contacts and meetings with public agents. When interacting with public authorities, we prioritize written acts, formal submissions, or meetings attended by more than one EFFICAZX employee/representative.

 

COMMITMENT TO PARTNERS

When forming partnerships, we ensure that partners are equally committed to ethical and competitive purposes.

Our participation is contingent upon partners’ acceptance of the norms in this Code of Conduct through a commitment and responsibility agreement, which can be waived if the partner has its own integrity program compatible with this Code of Conduct.

The documents establishing partnerships will include a specific annex that will regulate the relationship, task division, responsibilities, and specific and individualized accountability.

If the partner violates the conduct norms in this Code or its own norms, we commit to immediately notify the situation to the person responsible for monitoring and overseeing compliance in the partnership. In cases of non-compliance with norms and illegal practices, we reserve the right to terminate the partnership and, if necessary, notify the control and oversight authorities.

 

COMMITMENT TO SOCIAL, ENVIRONMENTAL, AND SUSTAINABILITY DEVELOPMENT

We act sustainably to preserve socio-environmental resources and ensure their availability for future generations, promoting resource savings and conscious and socially responsible use.

We develop technological solutions that minimize paper usage and mobility, thereby reducing environmental impact.

Acting in relation to supervisory public entities

We commit to collaborating and providing all timely information and requests related to tax, accounting, and corporate compliance.

We treat everyone with civility and respect, providing all relevant elements to inspectors and public agents when requested, within the limits established by law.

 

OUR SPECIFIC COMPLIANCE POLICIES

  • CONFLICT OF INTEREST:

We understand a conflict of interest as a situation where our interests as professionals at EFFICAZX interfere with or appear to interfere with our ability to make decisions for the benefit of the company.

Some examples of conflicts of interest, but not limited to:

  • Hiring a company supplier for personal purposes, and this personal relationship obstructs fair decision-making as a professional in the company;
  • Holding another job that affects performance in the company;
  • Participating in external activities involving organization information or knowledge;
  • Having friends or family who are competitors’ employees or clients or EFFICAZX suppliers. If in this situation, be cautious so that your friendship or kinship does not affect or appear to affect your ability to act in the company’s interest.

 

RELATIONSHIP WITH POLITICALLY EXPOSED PERSONS

We take preventive measures to document contracts, deliveries, and payments of services when dealing with “Politically Exposed Persons,” their family members, and intermediaries who held public management roles in the last 5 (five) years, through a specific declaration.

Our policy is based on self-declaration. We do not actively search public databases or private data systems. In cases of a positive declaration by a politically exposed individual and with their prior consent, we exclusively verify an official list of public data.

Any employee doubts about conflict of interest situations or whether inclusion as a politically exposed person is warranted can be directed to the external compliance assistant for additional clarification.

Information Security, Confidentiality, and Duty to Communicate Policy

We maintain a governance policy in compliance with legislation and best practices regarding personal data and information of partners, clients, suppliers, intermediaries, and partners.

In our services and activities, we respect privacy and protect the data of any personal information of clients, according to current laws. The authorized and legitimate use of clients’ personal data is done carefully, minimizing the risk of personal data exposure.

We are diligent and careful in accessing data and communications through IT means, especially in the use of email and accessing computer systems, to prevent data loss, fraud, or other types of cybercrime.

Transparency in Accounting Records and Balance Sheets

We transparently, accurately, and clearly record our accounting data and balance sheets, respecting specific fiscal and accounting standards. Our internal processes control all financial transactions, monitoring the flow of transactions and the maintenance of relevant documentation.

We instruct all parties involved to prevent any collaboration with terrorism or other crimes, especially money laundering prevention.

 

COMMUNICATION CHANNELS AND PROTECTION AGAINST RETALIATION

Individuals wishing to report any act or situation they consider inappropriate and in violation of this Code can do so through email: contact@efficazx.com.br.

We ensure the confidentiality of the identity of all reporters, who will be referred to our Compliance Committee.

 

NON-COMPLIANCE REPORTING WILL FOLLOW THE FOLLOWING PROCESS

  1. Evaluation of admissibility, maintaining the confidentiality of data contained in the report;
  2. If the report is accepted, investigation of the situation of possible non-compliance with the guarantees of the notified person;
  3. Presentation of investigation results to management, when necessary, to decide on the appropriate solution and applicable sanctions;
  4. Review of policies to improve or minimize the risk of recurrence and strengthen training of the team and other individuals involved in the company.

 

OUR COMMUNICATION POLICY FOCUSES ON

  • Ensuring non-retaliation;
  • Maintaining the relationship with the reporting person;
  • Raising awareness about the negative effects of whistleblowing and the legal implications of situations such as false reporting, administrative advocacy, and other relevant matters;
  • Respecting the reported person, ensuring their right to be heard and their right to defense during the investigation phases;
  • Seeking dialogue and conflict mediation.

 

This Code of Conduct was approved on 07/31/2023.