Políticas

Code of Ethics and Conduct

PT/BREN/US

1. Purpose

This Code serves as a Practical Guide for Personal and Professional Conduct, to be used in daily interactions and decisions. It makes our principles and beliefs explicit and affirms our values. It applies to all our managers, employees, and service providers.

2. Values

  • Client: The reason for the company's existence. Contributing to their success is our purpose.
  • Employee: Our greatest asset. Our commitment to employee well-being includes creating an environment of respect and psychological safety, promoting equity in all its aspects, and vehemently rejecting any discriminatory barriers to access or advancement for underrepresented groups. We are committed to fostering personal and professional growth and rigorously respecting employees' contractual rights.
  • Partner: An extension of our operations. We maintain a relationship based on trust, mutual commercial interest, and shared values of ethics and integrity.
  • Company: Our success is important but only meaningful if it is aligned with providing socially relevant, high-quality services grounded in ethics and reliability.
  • Environment: We are inspired by corporate sustainability to develop values and practices that promote environmental preservation.

3. Conduct Commitments

3.1 In Corporate Relationships

Corporate relationships involve mutual commitments between CPD and its employees in a reciprocal process.

3.1.1 CPD's Responsibilities to Its Employees:

  • Act inclusively, without distinction based on race, color, sex, gender identity, religion, political views, or any other factor.
  • Provide a safe and healthy work environment, respecting individuals' integrity and privacy, with zero tolerance for threats, harassment, or intimidation.
  • Honor commitments made to employees, including those arising from good faith beyond contractual and regulatory obligations.
  • Create a workplace that serves as a “learning environment”, encouraging employees to develop skills essential for business growth and providing the necessary resources.
  • Offer fair professional opportunities that recognize and value each employee's talents and contributions.

3.1.2 Employees' Responsibilities:

  • Act ethically, courteously, and in compliance with applicable laws, regulations, and best practices, contributing to an inclusive environment free from prejudice or discrimination.
  • Strive for excellence in work deliverables.
  • Take primary responsibility for personal and professional development with a self-managed learning mindset.
  • Maintain professionalism within the company and when representing it externally.
  • Use shared spaces responsibly, keeping them clean and organized, and use company resources sustainably.
  • Maintain confidentiality regarding information entrusted to them.

4. Relationship with Clients

4.1 CPD's Commitments to Clients

  • Understand the client's needs and objectives to offer the most suitable products and services.
  • Serve clients with courtesy and efficiency, offering clear, accurate, and transparent information.
  • Maintain transparency in all communications.
  • Value client feedback, whether suggestions or criticisms, and respond constructively.
  • Respect contractual obligations and meet agreed deadlines.
  • Keep client information confidential.
  • Avoid expressing opinions that could harm the company's image.

4.2 Relationship with Suppliers and Partners

  • We contract suppliers and partners who adhere to ethical standards aligned with ours, comply with our Compliance and Data Protection Policies, and pass our Due Diligence process, which verifies their legal compliance and business practices.

4.3 Relationship with the Market and Competitors

  • We respect our competitors and promote fair competition based on ethical principles and compliance with applicable laws and regulations.

4.4 Relationship with Government Agencies

  • Our employees must engage with public officials—including those in the Legislative, Executive, Judiciary, and Public Prosecutor's offices—with transparency and integrity, always observing the ethical principles established in this Code and our Compliance Policy.
  • We do not tolerate any form of offering advantages or privileges to public officials because of their position. We uphold ethics in all dealings with government entities at every level.

4.5 Relationship with Media and Advertising

  • Only authorized company representatives may speak on behalf of the company, and they must always express the official institutional position.

5. Commitment to Sustainability

We promote conscious, rational, and careful use of resources—whether financial, technological, material, or natural—actively combating waste. Regarding natural resources (e.g., water, energy, paper), we strongly encourage responsible consumption to help improve quality of life and preserve the planet. We adopt a Green Policy based on the 3Rs Rule: Reduce, Reuse, Recycle. This includes reducing the use of disposable items, favoring biodegradable materials, practicing waste sorting, and ensuring proper disposal of potentially harmful substances.

6. Commitment to Good Management Practices

We continually improve our processes by adopting modern, secure technology to ensure sound corporate management in all operational and support areas (e.g., accounting, finance, general administration). We maintain accurate and complete records and reports in compliance with applicable laws. Our reports reflect operational transparency with the necessary level of detail. Our financial statements are prepared according to legal requirements and fundamental accounting principles, accurately reflecting the company's financial situation. Our policies and strategic decisions align closely with the values and commitments expressed in this Code.

7. General Provisions

7.1 Conduct in Cases of Doubt or Violations of This Code

  • Situations that conflict with this Code—or are not specifically addressed—may arise unexpectedly. Each person is responsible for responding appropriately.
  • Violations of this Code or the company's policies and procedures are subject to disciplinary actions, regardless of the individual's position, in addition to applicable legal penalties.
  • If in doubt, employees should seek guidance from their immediate supervisor or the Ethics and Compliance Committee.

7.2 Anti-Corruption and Anti-Bribery Obligations and Guarantees

  • Employees acknowledge and agree to comply with Brazilian anti-corruption laws, including Law No. 9.613/1998 (Money Laundering Law) and Law No. 12.846/2013 (Anti-Corruption Law), as well as the U.S. Foreign Corrupt Practices Act (FCPA).
  • Employees must strictly comply with all provisions of the company's Compliance Policy, refraining from any activity that may constitute or lead to a violation of anti-corruption rules.

7.3 Compliance with the Brazilian General Data Protection Law (LGPD)

  • The company and all employees must operate in compliance with Law No. 13.709/2018 (LGPD) and other data protection regulations and policies.