1. Introduction
Brazil Ports Consultoria Ltda., a company specializing in engineering services and consulting, is pleased to present its Code of Ethics and Conduct to guide the actions and decisions of employees, suppliers, business partners, clients and society through ethical, honest and transparent conduct.
To honor these commitments, senior management undertakes to ensure that this Code of Ethics and Conduct is understood, implemented and maintained at every level of the company. Everyone who is an employee, contractor or otherwise represents Brazil Ports must know, practice and respect the principles established here.
Through this Code, we reinforce our commitment to integrity, trust and loyalty, as well as to respecting and valuing people, their privacy, individuality and dignity, without prejudice or discrimination, in compliance with anti-corruption law and with respect for the environment and society.
2. Purpose
- Compliance with rules for coexistence in the workplace, regardless of hierarchy, area or role.
- Transparency in operations in general.
- Safety in the activities of everyone involved.
- Security and confidentiality of information that must be protected.
3. Scope
The Code of Ethics and Conduct sets guidelines based on ethical and moral standards that serve as a reference for the behavior of all employees, contractors and people representing Brazil Ports in any way. It applies to everyone without distinction.
4. Values
5. Ethical principles
Brazil Ports directors and employees base their actions on the following principles in their relationships with the various sectors of society:
Clients
- Professionalism, trust and transparency.
- Solutions that add value to clients' businesses, with continuous investment in suitable technologies and improved business strategies.
- Valuing and respecting agreements and contracts, as well as clients' rights.
- Valuing business opportunities and partnerships built with clients, seeking results that benefit society.
- Identifying, proposing and enabling innovative, integrated solutions that contribute to clients' continuous improvement.
Government agencies
- Recognizing and supporting the role of government and regulatory agencies by providing relevant, reliable information at the appropriate time.
People
- Maintaining a workplace where relationships are based on professionalism, trust, cooperation, integration and respect for individual differences.
- Sharing knowledge and experience to improve technical training, methods and processes.
- Valuing people and contributing to their personal, technical and professional development.
- Taking permanent care to use the Company's material, technical and financial resources properly and economically.
- Preserving and respecting the Company's image, assets and interests.
- Recognizing and valuing the Company's intellectual capital and encouraging new leadership.
- Valuing and encouraging individual and collective ethical conduct.
Suppliers and outsourced service companies
- Legality, impartiality, morality, publicity and efficiency in every act.
- Maintaining relationships based on mutual respect and preserving the confidentiality of information concerning the Company and its clients.
- Relationships with suppliers and partners whose practices align with Brazil Ports' ethical standards.
- Building partnerships while preserving Brazil Ports' image and interests.
- Rejecting contractual provisions that undermine the dignity, respect or safety of outsourced employees.
Employee representatives, associations and institutions
- Recognizing the legitimacy of legally established employee representative institutions and maintaining dialogue based on mutual respect, seriousness, responsibility and transparency.
- Negotiation as the proper instrument for integration and convergence.
- Following the provisions of the instruments that regulate the relationship between the Company and its employees.
Community
- Establishing fair and balanced relationships with the community by encouraging, promoting and supporting social responsibility and citizenship initiatives.
- Encouraging and supporting government initiatives for social development and poverty reduction.
- Encouraging sociocultural, sports and educational initiatives.
6. Business conduct code
Required conduct
- Preserve and cultivate the Company's positive image.
- Sell only products and services owned by and of interest to the Company.
- Create favorable conditions for a productive and pleasant workplace.
- Treat people and their ideas with dignity and respect.
- Act loyally, fairly and candidly in work relationships.
- Protect collective well-being while respecting personal characteristics, freedom of opinion and privacy.
- Act clearly and loyally in defense of Brazil Ports' interests.
- Present oneself appropriately when duties require personal protective equipment and workplace safety measures.
- Refrain from using internal or external influence to obtain personal or professional advantages.
- Do not use one's position, trusted role or status as a Brazil Ports employee to obtain advantages for oneself or others.
- Use Brazil Ports resources only for Company purposes.
- Contribute to the Company's proper functioning and avoid acts that hinder or disrupt services.
- Refuse gifts from individuals or companies doing business with Brazil Ports when their value exceeds R$200.00.
- Present or disclose economic, financial, operational, logistical or other results only with Brazil Ports' authorization.
- Prioritize and preserve Brazil Ports' interests with clients, government agencies, financial institutions, suppliers and other institutional partners.
- Be accompanied by another employee, manager or peer under the four-eyes principle in relationships with suppliers or partners that may result in a Brazil Ports contract.
- Strictly observe corporate strategy and guidelines when accepting a position of trust.
- Resign from a position of trust when it conflicts with corporate strategy and guidance.
- Respect and follow tax, social security, labor and civil law, keeping up to date with applicable legislation.
Unacceptable conduct
- Claim personal benefits or advantages for oneself or others because of a commercial or financial relationship conducted on behalf of Brazil Ports.
- Be complicit or omit errors and violations of this Code or applicable laws and regulations.
- Perform professional activities that create a conflict of interest or direct or indirect competition with Brazil Ports.
- Discriminate against people for economic, social, political, religious, color, racial or gender reasons.
- Allow persecution, favoritism, antipathy, whims, passions or personal interests to interfere with professional relationships.
- Deliberately harm the reputation of a Company employee or any professional with whom Brazil Ports has an institutional relationship.
- Deliberately harm the reputation of clients, government agencies, suppliers or other commercial partners.
- Request or receive gifts or advantages for oneself or others in exchange for concessions or privileges from Brazil Ports.
- Prioritize personal or third-party interests over the interests of Brazil Ports.
- Gain advantages for oneself or others from privileged access to Brazil Ports information, even without harm to the Company.
- Make donations, sponsorships or financing to political parties.
- Use or pass to third parties documents, methodologies, products, tools, services or information owned by Brazil Ports, its clients or suppliers, except by legal or court order.
- Speak on behalf of the Company through public channels without authorization.
- Use the Company's material, technical or financial resources improperly or uneconomically.
- Prevent or hinder the investigation of suspected irregularities at the Company.
- Alter or distort any document, information or data for which the Company or a third party is responsible.
- Facilitate third-party actions that cause loss or damage to the Company.
- Create any confusion between Company assets and personal assets.
- Remain in a position of trust when it conflicts with the guidelines of this Code.
7. Code compliance
When unsure of the correct conduct, employees should seek help sincerely and transparently. Any situation that may constitute a conflict of interest, harm the Company or violate this Code must be reported immediately and formally to the Company's Legal Representative or through the Whistleblowing Channel.
The Company ensures confidentiality in handling these matters and is committed to investigating reported cases. Violations of this Code may lead to disciplinary action, including dismissal for cause and legal proceedings.
8. Whistleblowing channel
The Whistleblowing Channel is available 24 hours a day, 7 days a week, for anonymous reports by employees, representatives, partners, suppliers and other stakeholders concerning legal violations or inappropriate and unethical conduct. Brazil Ports guarantees complete anonymity and expressly prohibits retaliation against anyone who reports or assists with an investigation.
Reports may be submitted by phone +55 11 2348-5142 or by email ouvidoria@brazilports.com.
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