Code of Ethics | CADMUS

PRESENTATION

In a dynamic scenario of constant transformations it is increasingly important to be committed to our purpose: To provide an extraordinary digital culture journey for our clients!

Our purpose reflects who we are and how we work with our employees, service providers, customers, suppliers and business partners, always with the intention of fostering new ideas, talents, inspire, innovate, empower and enable extraordinary people!

Aiming to ensure our commitment to the highest ethical level, already observed throughout our trajectory over the years, we present and formalize this CODE OF ETHICS & CONDUCT, that will serve as a guide in professional and personal conduct, providing orientation and delimiting parameters in the form of ethical principles and values.

However, this Code does not list absolutely all the inconvenient situations that may arise, which does not remove the responsibility of those involved with society as a whole, in the protection of fundamental rights, the environment, with technological development, not tolerating, in turn, any act pertaining to corruption, violation of constitutional and infra-constitutional rules, any discriminatory act and violation of the ethical values set forth herein.

These guidelines not only reflect our culture, mission, values, and principles, but also consolidate the building of trust with every employee, customer, supplier, business partner, governmental entities, and society.

We thank you in advance, immensely, for every effort, commitment, and dedication in the defense of the principles and values foreseen in our Code of Ethics and Conduct.

Cordially,

Joelma Freire
(Controler)

Angélica de Lima
(Enterprise Agile Coach)

Adriana Garcia
(Data Protection Officer)

CADMUS Ethics Commission

SUMMARY

Our Code is based on the following pillars

Purpose

Our purpose is to provide an extraordinary digital culture journey for our clients.

We act to stimulate, encourage, and propitiate the development of new businesses, as well as to offer our clients the best solution, with excellence and quality.

Somos una institución innovadora, incansable en la búsqueda de nuevos talentos, comprometida con el desarrollo y la transformación digital y tecnológica con efectos en toda la sociedad, proporcionando también calidad de vida a nuestros empleados y prestadores de servicios.

Values

Our values and purposes establish our world view, what we want for the future of society, and the way we conduct our business every day:

People First - At Cadmus the most important thing is people! We all want to be valued and respected and this is how we should act with our partners, co-workers and customers.

In every detail we want to make this evident, when talking on the phone, when sending a message, and even when making this Code available.

Every decision we make, we want to and must think about people.

This is Cadmus! We believe that kindness generates kindness!

Happiness - The time we spend here is precious and this time should be the best it can be! For this reason, we want it to be a fun, challenging and rewarding place.

Spreading our values is the key to a culture where everyone can be happy doing what they love, in the best environment possible!

Clarity - Clarity is communication! We believe that everyone should know what the path is and how to walk it.

Each day when we start our work, clarity above all helps us to make better decisions, not to be afraid of making mistakes, to be sure and reassured that we will be supported and supported.

It's about being clear about what is expected of us and, when necessary, being the first to know.

Keep to the deal - Trust is the best contract!

Our customers, partners, employees, and service providers have full confidence that what has been agreed upon will be delivered, whatever the cost.

We understand that agreement involves planning and informing the other what exactly will be delivered, how and when. So when we fulfill the agreement, we meet expectations and have a long life.

"Fair account, long friendship:" This is the motto of the three founding partners of Cadmus: Claudinei, Renato and Rogério.

Knowledge added to practical experience is priceless. That is why we value sharing everything with everyone: every learning experience, every challenge, every success, every novelty, every new technique!

We promote Techday, talks, meetups and this moves us to share more and more!

We promote Techday, talks, meetings, and this leads us to share more and more!

Your business is my business - We value the business of our customers.

We seek to deeply understand the needs and characteristics of businesses. It is to 'sit in the chair' of people and remember that our success is the result of our clients' success, and therefore we spare no effort to provide the BEST, always!

Here, we understand exactly what ownership & accountability mean, expressions that demonstrate very well the true "sense of ownership" and responsibility over the assets of others, as if they were our own! And that is why we proactively propose solutions that make your day to day life easier and add real value.

Objectives of this Code

Therefore, the general purpose of this Code of Ethics and Conduct is to consolidate clear rules and principles of conduct for all those who are related to CADMUS Group, whether our employees, service providers, customers, suppliers, business partners, associates, having or being able to have access to confidential and privileged information, and this Code is also fully applicable to those who hold management positions, direction, board, administration, presidency and vice-presidency, for the transparent integrity of the business and for the commitment to society.

The Code, as already presented, does not aim to cover in absolute the incident hypotheses, as it would be easily outdated, but through values and principles foreseen here, as well as the other Policies that are part of the internal normative structure, to guide the conduct, in an ethical and transparent way, of those who make and contribute to the growth of CADMUS, in the professional and commercial relationships, in the market results, in the conflicts, as well as administratively, about all the reports, presentations, records, whether they are only internal, to the supervising authorities, or the information to the public in general.

Furthermore, this Code aims to ensure that any misuse of purpose or violation of the law and regulatory standards are promptly reported and taken to Compliance for investigation.

In case of doubts and/or complaints, you can send a message via e-mail to the Ethics Commission, through the following e-mail address: canaldaetica@cadmus.com.br

SUITABLE WORK ENVIRONMENT

It is important to say that we value highly and recognize the need for our employees and service providers to have the best possible working environment, which involves those who work directly on the company's premises, at clients' premises, and those who perform home office work. It is our commitment that they have a healthy, transparent, constructive and respectful environment and relationships, which includes the practice of good manners, courtesy, polite expressions and gestures that ensure that good manners permeate relationships and keep them free of embarrassment, aggression or ill feeling.

Drug Use, Drinking and Gun Ownership

This implies that the use of drugs and alcoholic beverages is not allowed in the work environment, including remote work, or the carrying of weapons on CADMUS premises.

The consumption of alcoholic beverages is strictly forbidden, except at specific events where consumption is allowed, but in moderation.

Discrimination

Furthermore, any discriminatory act, whether direct or veiled, by comments, expressions, gestures, jokes, adjectives, of a racist, religious, political affiliation or neutrality, circumstantial (including pregnancy), enabling, misogynistic, sexist, LGBTphobic nature, or that in any way reinforces stereotypes or prejudices, is not allowed.

Moral and Sexual Harassment

In the same vein, any form of harassment, whether moral or sexual, verbal or written, gestures, attitudes, or behavior, is not allowed, as set forth in the country's legislation.

For the purpose of the clarification of those who will have access to this Code and who must duly comply with it, it is clarified that moral harassment is the exposure to humiliating and embarrassing situations in the work environment, which may occur in a prolonged manner, during the exercise of one's activities. Moral harassment damages a person's integrity, dignity, self-esteem, endangers their work, professional development and, above all, their emotional health, damaging what is expected of an adequate work environment.

For more information, you can check the link below:

573490e3-a2dd-a598-d2a7-6d492e4b2457 (tst.jus.br)

Sexual harassment exposes a person to embarrassment with the aim of obtaining sexual advantage or favor, sometimes using the condition of hierarchy. This act is a crime, provided for in the Brazilian Penal Code, and will not be admitted by CADMUS.

Therefore, any of the above situations must be promptly reported to our channel.

Commitment of Employees and Service Providers

Regarding the activities of employees and service providers, it is essential that each one performs their activities with good faith, maximum transparency, watching over what is stated in the contractual instrument, in the Corporate Policies, in the principle of secrecy and confidentiality of information, and always respecting the provisions of the Brazilian legislation.

Also, regarding the exercise of the collaborators' and service providers' attributions, it is relevant to respect the information flow and the organization chart established by the area manager or the person responsible for the project, duly complying with the deadlines that were previously established and immediately communicating any impediments and incidents.

An important commitment of our employees and service providers for the good progress of the activities is the receptivity to the project management, to the follow-up and evaluation of the results by the area manager, with the purpose of improving our product/service and the professional growth of each one.

During the exercise of activities, with the company and/or our clients, it is pertinent that our employees and service providers present themselves in an appropriate manner, regardless of whether they are present in person or remotely.

We understand that given the circumstances of each individual, the speed of information, and even with regard to many of our employees and service providers performing their services at home office, many interferences and unforeseen events of everyday life may arise, which forces the use of phone, messaging applications for communications unrelated to the company's activities, which is fully understandable, however, it is required that each one makes use of good judgment in order to avoid going overboard in solving personal matters during working hours, except for special situations clearly justifiable. In addition, our employees and service providers should also be expected to avoid using corporate cell phones and e-mails for this same purpose.

Physical Facilities

Many of our employees and service providers carry out their activities directly on the client's or company's premises, which, in turn, is highly committed to complying with all work safety requirements and standards in order to be healthy and accessible. Therefore, it is the responsibility of all employees and service providers when working in the client's or company's facilities, to preserve and take care of the equipment, resources, and premises of the contractor and the client, and the presence of people not authorized by the manager or the use of the facilities for personal purposes is not allowed. The use of PPE (Personal Protective Equipment) is mandatory for the execution of activities in which it is required, and it is the professional's duty to pay attention to compliance with this requirement.

Others yes, the presence of authorized visitors, including for meetings, must be monitored during their entire stay in the office.

CONFLICT OF INTEREST

Conflict of interest can occur when evaluations or decisions are influenced or distorted to serve personal interests to the detriment of the real purpose of the organization's business, policy or operation. Organizational decisions based on negotiations in which there were such conflicts deviate from the legitimate interests of the company and can tarnish its reputation, in addition to hindering the success of its operations and causing financial impacts.

Therefore, it is extremely important that all our employees, service providers, partners, and suppliers act with total impartiality to maintain transparency and fairness in relations, seeking equal opportunities and the best business decisions.

In our relationship with business partners we offer gifts within a reasonable financial limit, without excesses and with values that cannot suggest any kind of bribe or purchase of favors, because we value fair competition. The same standard of behavior is expected from our suppliers, therefore, they must not offer gifts, hospitality, or entertainment to our employees or their families that could characterize an appeal to undue advantage in a business deal with the company; only gifts of low monetary value may be offered.

Family relationships or relationships with emotional ties between our employees and business partners, government bodies, service providers, and suppliers must be reported immediately, so that measures can be taken to prevent any undue favoritism, such as the use of privileged information or other actions that do not comply with the limits of transparency and fairness necessary for free competition. Employees who have professional activities external to those of the company must adopt the same ethical posture, notifying the company in case of a possible business relationship.

Every employee, partner, service provider or supplier who witnesses something that may cast doubt on the suitability of the company in its commercial relations must report the fact to the Ethics Committee through canaldaetica@cadmus.com.br, so that the facts can be ascertained and, if necessary, measures can be taken. The same channel must be used in case of doubts about whether any action to be taken may generate or characterize conflict of interest, before a decision is made, the Ethics Committee must analyze it and provide guidance.

LAWS, RULES AND REGULATIONS

We comply with absolute rigor the laws, rules and regulations, in all areas that CADMUS permeates, such as labor legislation, tax, social security, free competition, data protection, intellectual property, anti-corruption and money laundering, among others, also maintaining corporate policies, such as those below.

All other stakeholders, i.e. employees, service providers, customers, suppliers, business partners, and those in executive positions, must also be committed to complying with the laws, rules, and regulations, as well as being aware of and complying with the provisions of the corporate policies.

INFORMATION CONFIDENTIALITY AND SECURITY

What moves society today is information. It is essential, it is the driving force that enables us to accomplish our mission on a daily basis! For this we need protection!

Information security is what will shield in integrity all the information we handle, whether it is personal data, proprietary data, or information from customers, partners, and suppliers. This is made possible by a thorough program, with appropriate mechanisms for preventing and protecting against cyber-attacks and leaks.

Moreover, we consider of extreme relevance the protection of our assets, which involves Intellectual Property, not disregarding all those who maintain relations with CADMUS, as well as our competitors. Therefore, it is not admitted and tolerated any practice of information hijacking, malicious codes, espionage, cybercrime, as well as it is strictly necessary that not only our employees and service providers are well prepared, trained and adequate to our Information Security Policy, but also all those who maintain business relations with us.

Under no circumstances shall samples, computer programming codes, knowledge, contracts, contracts, drawings, diagrams, documents of any nature, technical or commercial specifications, know-how, lists, materials, models, plans, details, projections, records, reports or systems, whether commercial, accounting, strategic, financial, institutional, legal, organizational, technical, intellectual property or innovations and improvements, which are the exclusive property of CADMUS, be revealed, copied, disclosed, used shared, reproduced.

It is not admitted under any hypothesis to share login and/or password with third parties or other collaborators and service providers, since the credentials are the registered user's custody and responsibility.

For more information, you can also consult the Information Security Policy.

DATA PROTECTION

Data protection stems not only from the already known specific legislation, Law n. 13,709/2018 (LGPD), but also because it is a constitutional guarantee provided in Article 5, which protects the right to privacy, and that with Constitutional Amendment n. 115, of 10/02/2022, changed the Federal Constitution, including the protection of personal data among the fundamental rights and guarantees.

What can we understand from this? Our responsibility and commitment to the personal data of all natural persons that by nature of our work we may have access to.

The processing of any type of data, whether it belongs to employees, service providers, executives, customers, suppliers, business partners, or third parties, may only occur when authorized and for the fulfillment of specific purposes that are stipulated in a contract, to the extent and within the limits of the law, also observing the principles of purpose, adequacy, necessity, free access, data quality, transparency, security, prevention, non-discrimination, accountability, and responsibility.

Violation of any rule established in the LGPD and failure to comply with the relevant contractual clauses may incur administrative, regulatory, and as the case may be, criminal penalties.

PREVENTION OF FRAUDULENT ACTIVITIES, MONEY LAUNDERING AND CORRUPTION

We can define corruption as any act that is translated as the promise, delivery, offering, of any undue advantage with the objective of obtaining a benefit from a public agent.

Bribery is a corrupt practice, which involves offering money, advantages, gifts in exchange for certain benefits that should not happen.

Fraud is any act that has the objective of obtaining illicit gains to the detriment of others, which can be related, for example, to the falsification and alteration of documents and accounting records.

Money laundering is a set of activities that seeks to transform and incorporate ill-gotten assets into resources that are considered legal and justifiable to the authorities.

Any suspicion of conduct involving any of the above-mentioned illicit activities must be immediately formalized in a denouncement to the Ethics Commission.

It is also important to say that CADMUS does not tolerate and does not condone any act involving corruption, bribery, fraud, money laundering, or any other violation of current legislation, whether in internal processes or in negotiations.

Likewise, CADMUS requires the same conduct from all its employees, service providers, customers, business partners and suppliers.

CUSTOMER RELATIONSHIP

CUSTOMER RELATIONSHIP

Just as CADMUS would not exist without the many talents that collaborate with us, neither would the company's success exist without our customers who place so much trust in our products and services.

It is our commitment to give 100% of what we agreed upon, and we do not measure efforts to be effective, agile, and precise as to our clients' needs, including training for the use of our software and other services that may be useful for our clients' growth in the market as well.

This means that we only make commitments to our clients that we can fully meet; and that, above all, these commitments will always be in accordance with the current legislation, with our values and principles, and with our corporate policies.

RELATIONSHIP WITH SUPPLIERS AND BUSINESS PARTNERS

We place great value on the relationship with our suppliers, so that there is maximum transparency, honesty, and integrity, with negotiations based on the best technical conditions, in accordance with the legislation in force, and the best cost-benefit.

Clarity is one of our main values, and just as we understand this to be one of our main commitments, we expect this same regularity in return from our suppliers, whether directly with us in negotiations, or in other commercial relationships they may have, that is free of any act that involves corruption, bribery, favors, gifts, and/or other practices contrary to the law, such as exploitation of slave and child labor.

It is equally important that our business partners also maintain the same ethical standard and commitment to comply with anti-corruption and money laundering laws, as well as with the other regulations in force in the country and the corporate policies made available at the beginning of the partnership.

It is very important to CADMUS that our suppliers and business partners are in good standing with the laws and regulations in force, just as we place ourselves under the same duty of honesty before society.

FREE COMPETITION

We understand that the existence of free competition, as a constitutional principle (Art. 170, IV) is beneficial, not only for our customers who seek better products and services, but also drives us to be increasingly better and innovative. It stimulates our creative process for the development of new technologies.

This balanced concept makes sure that our competitiveness does not stifle unfair competition and/or unilateral practices that harm the dynamics of the markets.

We ensure that we respect the reputations, intellectual property, and opinions of our competitors.

SOCIAL-ENVIRONMENTAL RESPONSIBILITY

We understand that we have a very big responsibility for what we want for the future of our society. There is no development, evolution, and innovation without giving due attention to the environment. Therefore, it is also up to us to contribute to an increasingly sustainable ecosystem, which implies minimizing paper printing, reusing paper, reducing the use of disposable plastics, disposing of disused assets in an ecological and appropriate manner, encouraging the conscious consumption of water and energy and separating waste, environmental awareness campaigns.

We also have a partnership with a company that has ISO 9001:2015 and ISO 14001:2015 - IBAMA certification, which has the scope of the ecological and adequate disposal of the assets that are no longer in use, making waste collection points available.

Our commitment to proper disposal is in line with the National Solid Waste Plan (Federal Law n. 12.305) SETESB, as well as the requirements contained in the General Law of Data Protection (LGPD), Law n. 13.709/2018.

The respect and contribution to a more sustainable ecosystem, and the effort to apply the pertinent legislation, earned us the Environmental Destruction and Recycling Certificate.

Allied to this purpose, we work with digital sustainability; we have the D4S Sustainable Company Seal. This way we decrease the consumption of natural resources by reducing the use of paper, inks, and folders, besides avoiding displacement, which positively impacts the environment by not emitting pollutant gases.

Undoubtedly, we do not want to stop there, as if we have already done enough! We want to contribute more and more through new actions, new models, consider, inform, sensitize and engage all those who directly or indirectly have commercial and professional relations with Ventron.

SOCIAL ACTION AND HEALTH

In the search for a positive impact on society, we strive to do our best also through inclusion, which involves making PcD job openings available, especially for people with psychosocial disabilities, as well as the TEA (autistic spectrum disorder) person, but not limited to these.

Our efforts are also focused on promoting the health of our employees and service providers, by means of weekly activities for the well-being in the work environment, such as breaks, labor gymnastics sessions, and meditation, as well as a partnership program with gyms, whether they are weight-training, dance, Pilates, etc.

In addition, there are occasional lectures to raise awareness of occupational diseases and recommendations for self-care.

Looking at society as a whole, we have the "Solidarize", where the employee or service provider through our software donates coins (fictional currencies) and we contribute 100% of the amount collected, and the amount can be reverted in winter campaigns or for needs that occur throughout the year in charities.

As we grow, we seek and foster the professional growth of those who are with us, not forgetting first and foremost their well-being and health, also taking into account our commitment to those in unequal and vulnerable situations in society.

Related to the vulnerability issues, we work in partnership with a social assistance entity that works to transform young people by promoting their integration into the labor market. Thus, we participate in promoting this change of life by hiring these teenagers as young apprentices.

ETHICS COMMITTEE

When we receive a complaint in our e-mail, what happens next?

Everything we receive in our e-mail canaldaetica@cadmus.com.br , is screened, treated and investigated by the members of the Ethics Commission, in an autonomous, impersonal and independent manner, as described in the Ethics Commission Regulation. The content received will be carefully analyzed, and after the due process, if a violation to the Code is found, measures will be defined and taken, observing mainly what the Brazilian legislation provides.

The Committee may opt for various disciplinary sanctions, according to the seriousness of the occurrence and consequences generated in the general scope. The sanctions provided for in the committee's guidelines are:

  • proposal of conduct adjustment, which implies in a recommendation for a change of posture regarding the situation denounced;
  • application of the penalty of ethical censure, which can be carried out through a verbal or written warning;
  • recommendation for suspension from work, in case of an employee under the CLT regime;
  • dismissal or contractual termination;
  • judicial measures that may be appropriate or guidance to the offended party to seek the competent authorities, depending on the offense reported.
  • judicial measures that may be appropriate or guidance to the offended party to seek the competent authorities, depending on the offense reported.

Anonymous denunciation is not admitted. However, the identity of the Whistleblower will be kept confidential by the Ethics Commission.

In addition to the confidentiality of the Complainant's data, the investigation will also be kept confidential.

Inconsistent complaints will be disregarded.

Reports made in bad faith with the aim of harming others, without there having been an actual violation on the part of the Whistleblower, may result in disciplinary sanctions for the Whistleblower.

No retaliation will be admitted to the good-faith Whistleblower, because we have an absolute commitment to integrity and the reports made in good faith are of great importance for its maintenance! Therefore, in case of retaliation or attempt to retaliate against the good-faith Whistleblower, the author may suffer disciplinary sanctions.

For any questions you may have about whistleblowing or anything else related to the provisions of this Code, remember:

You can contact us by e-mail canaldaetica@cadmus.com.br !