Code of Business Conduct

1 – What is the Code of Business Conduct

The Code of Business Conduct is a document containing a set of ethical principles and conduct rules to govern the activity of Fundiven SA, promoting the lines of behavioral guidance and professional role model to all its employees.

2 – Fundamental Objectives

Code of Business Conduct conception determines a responsible opportunity of our organization, assuming a positive self-identity that reveals a social and environmental well supported policy. Fundamental objectives are:

– Make known to all employees, customers, suppliers, public authorities and, in general, the whole community and other stakeholders, the principles and values that guide the activity of Fundiven SA, promoting and increasing trust relations between them all;

– Define and promote with the employees, the common behavioral rules that must be observed in their mutual relations and in relations established with external agents associated with Fundiven SA (stakeholders);

– Consolidate our institutional image of excellence, responsibility and rigor.

3 – General principles of operation

3.1 – Customers

∙ Treat all customers with professionalism, respect and loyalty;

∙ Provide, to our customers, products and services of excellence, fulfilling the agreed conditions and commitments;

∙ Ensure equal treatment to all customers.

3.2 – Suppliers

∙ Choose suppliers based on impartial, fair and transparent criteria;

∙ Ensure equal treatment to all suppliers, honoring the commitments made with them.

3.3 – Shareholders and Market

∙ Act fairly in respect of shareholders, promoting the defense of their interests and trying to create more value;

∙ Ensure the accuracy and availability of the necessary information, in an appropriate and transparent manner.

3.4 – Concurrence

∙ Relate with our competitors in a hearty way, promoting mutual respect;

∙ Respect the criteria and market rules, promoting healthy and fair competition.

3.5 – Public authorities

∙ Ensuring compliance with all the legal requirements, Community regulations and National regulations, that can be applicable to the activity of Fundiven SA;

∙ Provide to the public authorities all the requested collaboration or required information.

3.6 – Employees

∙ Define human resources policies ensuring respect for the dignity, diversity and rights of each person;

∙ Ensuring equality of personal and professional development opportunities through a rigorous and constructive performance evaluation;

∙ Interdict any form of individual discrimination that can be incompatible with the dignity, diversity and rights of the human person, in particular in reason of nationality, gender, ethnicity, political belief, religion, sexual orientation or disability;

∙ To respect and promote the balance between work life and personal life of employees.

3.7 – Work ambience, Health and Safety

∙ Promote a good working atmosphere and team spirit, aimed at sharing common purposes and mutual assistance among employees;

∙ Ensure communication, sharing and recording of information among employees;

∙ Ensure compliance with the standards and applicable legal requirements relating to health, safety and hygiene at work.

3.8 – Social and Environmental Responsibility

∙ Promote and implement policies consigned to social responsibility, following a strategy based on the ten universal principles advocated by the United Nations Global Compact Initiative (areas of human rights, labor, environment and anti-corruption);

∙ Foment social responsibility in the communities where Fundiven SA carries out its business activities in order to contribute to their progress and welfare;

∙ Promote, reveal and encourage employees, customers, suppliers and the community in general for the adoption of good environmental practices;

∙ Minimize environmental impacts of developed activities and services.

4. Individual Rules of conduct

4.1 – Responsibilities

∙ Respect the values and principles established in this Code, in internal and external relations;

∙ Guide their conduct in compliance with the assigned responsibilities, always with impartiality, competence, rigor, dedication and transparency;

∙ Taking a loyalty behavior in all situations, committing themselves to safeguard the credibility and good image of the company;

∙ Act responsibly and rigorously seeking to improve and update their knowledge, aiming continuous improvement of professional capabilities;

∙ Report any behavioral irregularities or circumstances which are likely to cause damage to the business development or to the good name of the Company.

4.2 – Interpersonal Relationship

∙ Assume a respectful behavior, honesty and cooperation with all coworkers and superiors, privileging the team spirit and a good working atmosphere;

∙ Respect and implement the decisions of superiors, according to the plans established by the Company.

4.3 – Protection and use of assets and resources

∙ Ensuring the protection and good condition of the available resources for the performance of functions;

∙ Use the tools and Company resources rationally and efficiently in order to achieve defined objectives.

4.4 – Interest conflicts

∙ Refrain from performing any functions in organizations where the carried activity collide or interfere with the Company’s objectives;

∙ Avoid situations likely to give rise to conflict of interest by intervention in decision-making processes that involve, directly or indirectly, entities that work or have worked, or persons who are or have been connected by ties of kinship or affinity of any kind.

4.5 – Confidentiality and professional secrecy

∙ Preserve facts or confidential information, while respecting the established rules. Do not use inside information for their own benefit or third parties.

∙ All collected personal data should be processed fairly and carefully, in order to protect the privacy of each employee in strict compliance with the standards and applicable legal requirements.

4.6 – Integrity

∙ Do not accept or propose offers to third parties, payments or other benefits that may create in their interlocutors favoritism expectations in the relations with the Company

∙ The received offers from third parties that exceed the mere courtesy or a symbolic value and commercially irrelevant should be communicated to the Administration, and rejected if they evidence the expectations for a special favor.

 

Despite the Code of Business Conduct establish the minimum acceptable standards of behavior, not intended to anticipate every situation that may arise. Common sense should always be the reference.