Collaborators

Channel of conduct and ethics

This Code of Conduct was developed for employees, shareholders, board members, and suppliers. Aligned with our values, it seeks to guide our attitudes and behaviors on a daily basis.

In case of situations not foreseen in this Code or if you have questions, talk to your manager or contact the Conduct Channel.

• Parallel activities
  Every employee is free and responsible for what he or she does outside of work hours, but it is important to keep in mind:
  • Your external activities cannot harm your work or the company’s image.
  • Activities that compete directly or indirectly with the Group’s business are not allowed.
  • Inform your area manager and the HR department if you participate in discussion forums, lectures, seminars or academic work.
  • You may not take advantage of our internal promotional pricing policy to resell products purchased from the Group.
  • You must not use your job or position to obtain benefits or advantages, for yourself or for people close to you.
• Political, union, and religious activity
  We respect each employee’s right to participate in civic affairs, religious matters, political processes, and also in social networks, as long as they occur outside working hours, do not use company resources, and do not generate conflicts of interest.
• Freedom of Association
  Cidade Center Norte respects the right of free association in unions, associations, class entities, political parties or any other entities, provided that made responsibly, within the law and with care of exposure on social networks such as Facebook, Instagram, Linkedin, among others.
• Job referrals
  Collaborators
  Cidade Center Norte accepts referrals of its professionals for hiring new employees. But it is important to be careful to avoid:
  Conflicts of interest:
  • Referred applicants will go through an unbiased recruitment process.
  • The collaborator cannot refer first-degree relatives – father, mother, siblings, spouse, or children.
  • The recruitment process for referred professionals cannot be conducted by the person who recommended them. For specific positions, the presence of an HR employee is required for joint evaluation.
  
  Suppliers
  To avoid partiality or conflicts of interest:
  • The employee who referred the supplier may not participate in the negotiation and contracting process.
  • The purchasing and contracting decisions are based on technical, transparent and objective criteria, such as quality, cost, delivery, level of service and compliance with the laws and regulations in place.
  • There will be no partiality or privileges in the contracting processes.
  • Companies in which our employees have an equity stake cannot be referred or contracted.
  • Strategic purchases from specific suppliers must follow all the items of the purchasing policy.
  
  Conduct in practice
  “My cousin has a company that supplies materials to a Group Unit. You may have a relative who is a partner or owner of a supplying company. But you must communicate this in writing to the responsible area. You will not be part, directly or indirectly, of the supplier selection process and contract management.
• Romantic relationships
  • Direct or indirect leadership or subordination relationships are not allowed between suppliers and employees who have an affective involvement.
  • It is recommended that professionals with affective involvement do not work in the same department.
  • These situations must be reported to the Unit Executive and to the Conduct Commission.
• Gifts and Presents
  In order to guarantee total transparency and impartiality in business relationships, Grupo Baumgart does not allow receiving gifts, presents and favors from suppliers, customers or future suppliers/customers.
  • The employee may receive gifts considered as institutional, that is, without commercial value, such as: office supplies, T-shirts, and samples developed in projects.
  • The benefit received or offered must not be seen as something that may unduly influence the decision-making of those who received it.
  • For practical purposes, consider as a reference the value of BRL 100.00 (one hundred reais) for each item received.
  • In situations of return that may generate discomfort, or in Transparency in facing Conflicts of Interest that cannot be refused, the gift should be forwarded to Center Norte, to be donated to social institutions.
• Travel and Entertainment
  It is prohibited to accept, request, offer trips or any kind of entertainment (shows, theater, etc.) from or to suppliers or customers, whether actual or potential. This includes the use of customers’, suppliers’ or the Group’s resources for this offer.
• Business lunches and dinners
  Meals with customers or suppliers are part of building a good business relationship, as long as they do not lead to partiality or retribution. Accordingly:
  • In meals with suppliers, each party must cover their own expenses.
  • Meals with clients or future clients paid by Group companies must be previously approved by the manager.
  
  Conduct in Practice
  I received a valuable gift from a future supplier that I am consulting. How should I handle the situation?
  Do not accept a gift that could compromise your independent judgment when making business decisions. Make sure that this prospective supplier knows our Code of Conduct to explain the reason for refusing the valuable gift or anything that could influence the business relationship between you.

• Conduct in Business Relationships
  Professionalism is one of the ethical principles of Cidade Center Norte. Therefore, it is very important to maintain a proper, professional and transparent conduct in negotiations and business relationships.
  
• Commitments of Suppliers and Service Providers
  The values and practices of Cidade Center Norte reflect high ethical, safety and sustainability standards, seeking to ensure credibility and preserve the image of the company and its partners. Thus, it is up to us together, Cidade Center Norte, suppliers and service providers, to ensure that these behaviors are always fulfilled and respected.
  It is important to have the assurance on the part of suppliers and service providers as to the quality and adequacy of processes to provide products or services, following safety and sustainability standards, as well as the contractual obligations established for each negotiation.
  
• Accounting books and records
  It is important that suppliers and service providers of Cidade Center Norte have their procedures and internal controls in place accurately detailed in their books and accounting records. This should always be done in accordance with good market practices and accounting standards. The practice aims to ensure that assets, liabilities, transactions and other activities with financial impact are recorded in detail to ensure the integrity of the business results.
  
• Hiring Rules
  Cidade Center Norte employees who are conducting a recruitment or hiring process must communicate with suppliers and service providers participating in the process about their commitment to always follow legal, ethical and moral standards in all relations.
• Audits and Contract Terminations
  When deemed necessary, any company that is part of the Cidade Center Norte may conduct audits, at its discretion, within ethical precepts and following the appropriate procedures.
  Audits can be initiated by the collection of qualification forms from suppliers and service providers, followed by field audits, and also by audits carried out by contracted companies, upon prior notification.
  When suppliers and service providers do not meet the expectations of this code of conduct, Cidade Center Norte can present solutions for the partners to comply with the guidelines. If the action plan for such compliance is refused by the partners, Grupo Baumgart together with Cidade Center Norte Management may terminate the contracts.
  
• Relationship between employees and suppliers and service providers
  We seek to establish increasingly transparent business relationships, and for this we count on the commitment of suppliers and service providers. All market and competitor information must be obtained through transparent and honest practices.br /> All necessary hiring for supply or services must be executed by the contracted partner, without outsourcing the demand.
  In case of Direct Billing, it is necessary to notify the Purchasing area, so that the information is added in the contractual draft. Any and all subcontracting can only occur with the approval of the contract manager.
  
  Not allowed:
  • Attitudes that belittle the image of competitors or business partners.
  • Promoting the abuse of economic power or oppressive business practices.
  • Disclose confidential information.
  
• Gifts, Presents, Travel, and Entertainment
  No benefits may be received or offered between suppliers, service providers and Cidade Center Norte. Any gift or item offered should not influence any company decision making.
  
  In practice:
  • Suppliers and service providers may only offer gifts with no commercial value, such as institutional office supplies or t-shirts. Consider as a reference the maximum value of BRL 100.00 (one hundred reais) for each item received.
  • It is forbidden to offer trips or any type of entertainment (tickets to shows, theater, etc.) to any employee in order to influence business decisions with CCN.
  
• Conflicts of interest
  This occurs when personal interests interfere in business decisions for the benefit of employees, suppliers, business partners and even clients. To avoid conflicts, we seek maximum transparency in the negotiation and contracting processes.
  Suppliers and providers with degree of kinship on 1st of our employees (as well as spouse, brother-in-law, etc.) and / or companies in which employees of Cidade Center Norte have ownership interest may not be referred or hired to provide services.
  
  In practice:
  • Contracting processes should not favor or privilege employees, suppliers, business partners or customers.
  • It is common and important for the Procurement process the referral of a supplier by the business area, for having the technical knowledge – for the hiring to occur other factors are verified in the RFI and RFP. However, the employee who refers a supplier will not participate in the processes of selection and negotiation of new suppliers or partners.
  • Purchasing and contracting decisions must follow the technical, transparent and objective criteria, following the laws and regulations in place.
  • Any and all purchases must follow the Purchasing Policy of Cidade Center Norte.
• Suppliers with degree of kinship of our employees
  Companies in which Cidade Center Norte employees have equity participation cannot be referred or hired to provide services.
  
• Fighting Corruption
  Any practice of corruption or bribery will not be tolerated by Cidade Center Norte. Suppliers and service providers must not grant or receive gifts, courtesies or hospitalities or any undue payment or advantage. It is prohibited to offer or promise, request or suggest payments or grants of any commercial, contractual, regulatory or personal advantage.
  The Companies of Cidade Center Norte do not practice acts of corruption and do not use third parties to do so.
  It is strictly forbidden for any contracted employee, supplier or service provider to commit acts of corruption on behalf of the company.
  
  Not allowed:
  • Using false documents to cover up illegal payments.
  • Failing to record incoming or outgoing cash flows.
  • Concealing information from auditors.
  • Omitting transactions of any nature or using false data.
  • Offering bribes to any professional with whom you do business.
  
  Money Laundering is unacceptable. Besides being illegal, this practice seriously compromises the credibility and reputation of the organization. It consists of transforming resources of illegitimate origin to create the appearance of legality. When identifying suspicious situations of money laundering, it is important to report the event.
  
  Not allowed:
  •According to irregular, overpriced financial agreements or performing services without an invoice, thereby condoning the irregularity.
  •Carrying out or accepting unusual operations, with different values than expected, “from” or “to” places not common to the group.
  •Performing transactions without detailed identification.
  

• Company-provided resources for work
  It is important to use resources appropriately, that is, for business purposes and not for personal use.
  Employees must take care of the Company’s property and resources in the same way as they take care of their own, protecting them from loss, damage, theft, improper or even illegal use.
  The following are considered the Group’s property or responsibility:
  • Facilities, equipment and their parts;
  • Computer equipment and software;
  • Internet access;
  • E-mail;
  • Telephones, fixed or mobile;
  • Copiers;
  • Office material and other supplies;
  • Vehicles;
  • Intellectual property, such as name and brand.
• Information and Confidentiality
  Confidential information is strategic to the company and vital to the business. Improper disclosure can cause enormous damage to the Group. Therefore, it must be treated with responsibility.
  • Do not talk or use under any circumstances, confidential and/or sensitive information of Cidade Center Norte with anyone.
  • Do not use this information to take personal advantage, especially after the employment contract.
  • Inform your immediate manager if you discover the leak of confidential information.
  • Do not send e-mails with confidential documents or make backups on external devices or cloud servers without authorization from the Information Technology team.
  • Never disseminate false or distorted information inside or outside the company.
  
  We consider confidential information:
  • Pricing
  • Investment and expansion plans
  • Business results
  • Personal employee information, such as compensation
  • Business management policies and practices
  • Major projects, such as acquisitions
  • Registration of new brands and patents
  • Information from companies we do business with
  • Production data, among others.
• Inappropriate Content and Privacy
  • It is forbidden to exchange, store and consume obscene, pornographic, violent, racist or defamatory content that disrespects any individual or entity and that is contrary to the policies and interests of Cidade Center Norte.
  • All files and information transmitted, received, created and stored in electronic systems are the property of Cidade Center Norte. Thus, the company may have free access to information from its equipment.
• Intellectual Property
  Intellectual property can be defined as ideas, knowledge or any other non-material activity developed by or for the Group, which would bring advantages to a competitor, if it had access to them.
  
  Intellectual property is understood as:
  • Brands
  • Patents
  • Domain Names
  • Copyrights
  • Innovations
  • Improvements
  • Processes or Products
  • Designs or Models
  • Financial Information
  • Commercial or Market
  
  The result of intellectual work and strategic information generated in the companies is the exclusive property of Cidade Center Norte. It is the responsibility of everyone who has access to this content to treat it confidentially.
• Conduct in Practice
  “I constantly receive on my corporate e-mail inappropriate content that I understand to be passed on to a mailing list. What should I do? Report the fact to your Manager so that he/she can take the necessary measures. If you do not feel comfortable doing so, report it to the Conduct Channel.

• Moral Harassment and Abuse of Power
  We consider moral harassment the fact of someone using his or her privileged position to humiliate, disrespect and embarrass other employees in the work environment.
• Sexual Harassment
  We consider sexual harassment to be any unwelcome advances, request for favors, exposure of inappropriate content or material, or any other inappropriate verbal or physical behavior of a sexual nature in the workplace.
• Use of alcohol, drugs and carrying weapons
  Not allowed:
  • The consumption of alcoholic beverages during working hours.
  • Work while under the effect of alcohol or drugs.
  • Possession and use of drugs in the work environment.
  • Working under the influence of drugs, including the improper use of medication.
  • Carrying and using weapons on company premises, except in the case of professionals authorized to do so.
• Fighting Harassment
  Employees who feel disrespected, discriminated against, humiliated, or subject of prejudice, pressure, or abusive practices, and do not feel comfortable in discussing the matter with their managers, should communicate the fact to the Conduct Channel.
• Conduct in practice
  My manager repeats the same order to perform a simple task “hundreds of times” until he emotionally destabilizes me. I have tried to talk to him, but he continues with this attitude. What should I do? You did the right thing by talking to him, but since his attitude hasn’t changed, you should contact Human Resources or report the fact through the Conduct Channel.

• Diversity and equal opportunity
  We value the participation and contribution of each individual to the achievement of a common goal, respecting diversity of culture, ideologies, or any other factor. Our goal is to ensure that no situations of discrimination based on:
  • Race
  • Sex
  • Color
  • Nationality
  • Religion
  • Age
  • Marital Status
  • Physical or psychological disability
  • Ideology
  • Sexual orientation
  We encourage the professional and personal development of our collaborators according to merit and guarantee equal opportunities.
• Working conditions
  We respect the fundamental rights of individuals, as one of the ways we contribute to a more just world.
  We support the fight against child labor and do not admit practices that go against the rights established in the International Labor Conventions about minimum age for admission to employment, conditions of servitude, forced or compulsory labor at any stage of our business chain.
• Environment
  All laws and regulations protecting the environment must be strictly followed. For this reason, we work actively with investments in equipment, research, training, policies and procedures that reduce our impact. Furthermore, the disposal of waste must occur in accordance with the legal determinations, seeking the reduction of environmental impacts.
  This is not only a commitment of the company: our employees must comply with internal standards, as well as report to the managers any suspicion of irregularity in this area, with an active commitment to the protection of the environment.
• Health and Safety
  We have the responsibility to look after the health and safety of our employees and customers. Thus, we have a policy of risks at work, safety and health. It is our employees’ daily commitment and duty to respect applicable health and safety standards.
• Community
  One of our commitments is the concern and care for people, involving us in issues related to social responsibility, culture, environment, and valuing the human being.
  • We work directly with the community and invest in future generations through Instituto Vedacit and Instituto Center Norte.
  • Our projects seek to supply the real demands of the communities where we operate, including education, actions with non-profit organizations such as hospitals, churches, and schools.
  • The choice of projects is made through criteria established and publicly disclosed by the Institutes, with the objective of effectively meeting the expectation of social transformation.
  Such attitudes are a fundamental part of our commitment to sustainability and responsible business management.
• Conduct in practice
  “I noticed that employees in the operational area are not using their PPE correctly or that there is no PPE available for these employees. What should I do?” Report the fact to your Manager so that he/she can take the necessary measures. If you do not feel comfortable doing so, report it to the Conduct Channel.

• Violation of the Code
  Any person who becomes aware of conduct or activities contrary to the principles of the Code must inform one of the members of the Conduct Committee or make a report through one of the channels, by phone or website.
  All information and reports received by the Committee will be treated in the strictest confidence, and the identity of the reporter will be preserved. Violations of the Code will be punished in accordance with the evaluation of the Conduct Committee, as well as being subject to the application of Brazilian Law.
  All reports registered by the Conduct Channel are directed to an external entity, qualified and independent, for classification. After this initial treatment, the report will be forwarded to the Conduct Committee, which will make an analysis and recommend corrective actions.
• Conduct Committee
  Cidade Center Norte will maintain, permanently, a Conduct Committee, composed of people elected by the Board of Directors. Its responsibilities will be:
  • Review the Code every 2 years.
  • Receiving reports of violations of this Code.
  • To guarantee the confidentiality of the information received.
  • Evaluating violations of the Code, investigating the facts and supporting the decision making process.
  • Forwarding to the Board of Directors serious cases of violations of the Code of Conduct.
  • Disseminate this Code, which will be given to all employees during their integration.
  • To solve doubts and present other information to the employees about the Code, by means of the company’s communication channels.
• Disciplinary Measures
  This Code is of mandatory compliance. Therefore, it is important that everyone is aware that contrary conducts may lead to the application of disciplinary measures, which include the termination of the working relationship, without prejudice to the applicable legal responsibilities.
  This Code does not exhaust all possible issues of conduct related to work and, therefore, does not restrict Cidade Center Norte in the application of disciplinary measures, which will always be guided by common sense and applicable law.
• Conduct Channel
  The Conduct Channel is a confidential tool, available to all the Companies of Cidade Center Norte and its publics, internal and external. In this way, it offers the collaborator an alternative for the solution of questions related to the Code.
  Impartial and transparent, the Conduct Channel ensures confidentiality of information, preserves the identity of those involved and promotes a safer environment. Through it, it is possible to clarify doubts of interpretation and forward complaints.
  The Group will not tolerate retaliation and will seek, by all means, to prevent this type of conduct. False reports made to defame or threaten the reputation or position of others may result in disciplinary action.