1. Purpose

This policy establishes the principles and guidelines that ensure full respect for Human Rights in all operations of CPD Informatica, covering its supply chain, strategic partnerships, and interactions with stakeholders.

It aims to ensure compliance with national and international regulations while reinforcing the company's commitment to sustainable and socially responsible practices throughout the lifecycle of its operations.

Additionally, it seeks to promote safety, dignity, and inclusion, preventing adverse impacts and ensuring an ethical, diverse, and respectful environment for employees, communities, customers, and all stakeholders.

2. Scope

This policy applies fully to CPD Informatica and must always be adopted in compliance with internal documents and current legislation.

All employees, managers, and members of the board of directors and fiscal council must be fully aware of and committed to the guidelines established in this policy, ensuring its implementation and continuous dissemination.

Clients, suppliers, and other strategic partners must also be aware of and comply with the principles outlined in this policy, ensuring that their practices are aligned with the human rights guidelines adopted by the organization, thus preventing conflicts or violations.

The guidelines established herein must be followed regardless of local laws that may be more permissive. In the event of a conflict between this policy and local legislation in a given jurisdiction, the rule offering the greatest protection to human rights shall prevail.

3. References

  • 3.1. ABNT NBR ISO 37001:2017 - Anti-Bribery Management Systems.
  • 3.2. ABNT NBR ISO 37301:2021 - Compliance Management Systems.
  • 3.3. COD.SGI.001 - Code of Ethics and Conduct.
  • 3.4. POL.SGI.001 - Anti-Bribery Policy.
  • 3.5. POL.SGI.002 - Compliance Policy.

4. Definitions

  • 4.1. Human Rights: A set of fundamental rights and freedoms guaranteed to all individuals, regardless of race, color, sex, nationality, ethnic origin, language, religion, or any other status.
  • 4.2. Decent Work Environment: A professional setting free from discrimination, harassment, and violence, promoting inclusion, equity, and the well-being of employees.
  • 4.3. Forced Labor and Modern Slavery: Situations where individuals are subjected to degrading working conditions, without fair compensation or freedom to leave the job.
  • 4.4. Child Labor: Any form of work performed by children or adolescents that compromises their education, health, or physical, mental, and social development.
  • 4.5. Child Sexual Exploitation: Any form of sexual abuse involving children or adolescents for commercial, financial, or other purposes.
  • 4.6. Freedom of Association: The right of workers to organize and participate in labor unions or other professional associations without interference or retaliation.
  • 4.7. Whistleblower Channel: A confidential tool provided by the organization for receiving and handling reports related to human rights violations and unethical conduct.

5. Responsibilities

  • 5.1. Senior Management: Promote and uphold the organization's commitment to human rights, ensuring that these topics are respected and integrated into operations.
  • 5.2. Compliance Officer: Monitor adherence to human rights principles, investigate all reports related to the topic—including those involving children and adolescents; prevent and address harassment (of all types) in the workplace, whether in-person or remote; conduct risk assessments on received reports concerning potential human rights violations; and take appropriate corrective actions.
  • 5.3. Employees: Comply with all legal and regulatory norms related to human rights in the jurisdictions where the organization operates, as well as this policy, the Code of Ethics and Conduct, and all related policies.

6. General Guidelines

CPD Informatica reaffirms its commitment to social responsibility and positive societal impact, assuming an active role in the promotion and protection of Human Rights.

Respect for and defense of human rights are intrinsically linked to the organization's ethical behavior and corporate responsibility. Accordingly, CPD Informatica commits to respecting human rights in its operations, engaging suppliers and stakeholders, and taking responsibility for conducting its business ethically and transparently.

The guidelines include:

A. Promotion and Defense of Human Rights

  • Train, guide, and encourage employees to promote and defend human rights in all professional and social interactions, ensuring alignment with applicable legislation and internal policies.
  • Participate in voluntary commitments, when applicable, that align with the company's mission and advance the human rights agenda nationally and internationally.

B. Safe, Diverse, and Non-Discriminatory Work Environments

  • Ensure a decent, safe, inclusive, and diverse workplace, free from discrimination based on gender, gender identity, race, color, age, religion, origin, sexual orientation, marital status, political opinion, social status, or disability.
  • Reject any form of violence or human rights violations committed by private security personnel within company premises or in the supply chain.

C. Freedom of Association and Collective Bargaining

  • Respect and guarantee freedom of association and collective bargaining, promoting open dialogue with employee representative entities.
  • Ensure a professional and educational environment free from any form of abuse, intimidation, or violence.
  • Promote values of respect, solidarity, and cooperation in the workplace and educational settings.
  • Encourage creativity and human development as a response to professional and academic challenges.
  • Implement human-centered management practices and provide continuous technical support to employees and clients.

D. Identification and Mitigation of Social Impacts

  • Prevent and combat all forms of harassment (moral, sexual, psychological, etc.).
  • Provide a confidential whistleblower channel for reporting human rights violations.
  • Establish formal mechanisms for recording, investigating, and monitoring reports, ensuring protection against retaliation.

E. Rejection of Child Labor, Forced Labor, and Modern Slavery

  • Adopt measures to eliminate all forms of child labor, forced labor, and modern slavery, both in direct operations and across the supply chain.
  • Protect the rights of children and adolescents, fostering a safe and exploitation-free environment.

F. Rejection of Child Sexual Exploitation

  • Implement prevention and combat measures against child sexual exploitation within direct operations and the supply chain.
  • Raise awareness and train employees and partners to identify and report situations involving child sexual exploitation.