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Code of Conduct and Ethics

This policy is intended to guide all employees and partners on the principles of Fadel's code of conduct and ethics.

Promoting a harmonious environment that favors the dissemination of the topics of this Policy with transparency, so that everyone feels comfortable asking any type of question.

Everyone has the obligation to comment on any violation of the rules set out in this Policy, failure to comply may expose the employee and the company in illegality (civil, criminal, labor, etc.).

The employee must be aware that the violation of this document or of the determined policies and procedures may result in administrative measures or the termination of the Employment Contract, without prejudice to the filing of the respective legal actions applicable to the situation.

This document is mandatory for all employees and should serve as a reference for our service providers and business partners. The standards presented are relevant to all employees, regardless of their hierarchical position. - Everyone should follow them without distinction.

Responsibilities

Fadel has become a successful and recognized company in the logistics segment, offering differentiated solutions to the market, prioritizing excellence in the service level, based on quality and operational efficiency and sustained by the management of people, processes and resources.

The procedures for this conduct must be ensured by the managers (leader, supervisor, manager, director) guaranteeing free access to the disclosure of the principles mentioned in this policy. They must also ensure the correct understanding and application of the standards to their team. After becoming aware of it, it is the responsibility of every employee to follow this policy and the aforementioned guidelines.

The duplication or reproduction of this volume, or parts, under any means, is prohibited without the express authorization of Fadel.

The elaboration and approval of this Policy are the responsibility of the Quality, HR and Fadel Corporate Directors area, and should be reviewed and updated whenever any changes are proposed.

Personal Conduct

Respect the individual's capacity and limitations in working relationships, without any prejudice or distinction of ethnicity, sex, color, nationality, age, religion, disability, health, political nature and social position;

Maintain a positive work environment, treating everyone with dignity and respect, disseminating, informing and encouraging co-workers to fully comply with this Code of Ethics and Conduct;

Prioritize safety in all work relationships, seeking the physical integrity of all our employees and partners.

It is forbidden to misuse confidential information of the organization or to compete unfairly with the company after its termination.

Conflict of Interest

Deviate from conflicts of interest that could put the company at risk or in an embarrassing situation. The conflict of interest will exist whenever the decision making for a given situation contains elements of personal considerations.

The employee must inform his immediate superior when any particular activity may interfere or conflict with the interests of the company, clarifying its nature and extent.

External professional activities are only allowed when they do not impair the employee's activity in the Company and do not involve the use of information, resources, time or knowledge owned by the Company.

Political Positioning

The use of resources in direct or indirect favoring of political parties, candidates for public office, committees, public officials, politicians in public office, suppliers, customers is prohibited, unless previously verified as a legitimate and legal act by the legal department, in addition to authorized by the board;

Relationship

The hiring of first-degree relatives (father, mother, children, siblings and spouses) is not permitted.

In exceptional situations, this rule may be relaxed considering the needs for hiring operational personnel and market restrictions. The evaluation of the convenience of this flexibility will be made by the HR Area. Authorization must go through formal board approval.

It is not allowed to negotiate or formalize contracts on behalf of the company with individuals or legal entities with whom the employee is related or has an intimate relationship. Exceptional situations may be authorized by the Board.

Relationship with Competition

Deny promises or offers of payments that aim to facilitate access to privileged information, or that provide differentiated commercial treatment, not allowing the treatment of free competition in ways that affect commercial decisions.

Media relations and disclosures

Contacts with the media on social, environmental / financial or other issues that may affect the company's image should be made known or discussed with the Board of Directors beforehand to avoid conflicting messages on behalf of the company.

Fighting bribery and corruption

The Company conducts its activities in accordance with national laws applicable to the fight against bribery and corruption. People must do the same. Any and all forms of corruption, direct or indirect, whether in the public, governmental or private sphere, will be condemned.

Offering to receive gifts, bribes or advantages, agreeing to pay bribes for the purpose of commercial benefit, be it from the company and / or personnel, is prohibited from the practice of active or passive corruption.

Gifts and presents

It is prohibited to accept gifts, gifts of any value, currency or any benefits offered by third parties that are not officially communicated directly to the company, that is, directly to the employee.

If it is not convenient to refuse the gift, the employee must send it to the HR Area, for the promotion of sweepstakes or donations to charities accredited for this purpose.

Donations

In the case of benefits or donations from suppliers or partners of gifts, products, services or advantages that are perceived as having high added value due to a commercial or institutional relationship, it is up to the employee to inform the HR area for an analysis of the situation and consequent guidance on how to proceed.

In this case, trips and events in Brazil or abroad are included.

Use of Resources and Preservation of Patrimony

It is prohibited to use the company's assets / assets for any particular purpose without prior authorization from the responsible sectors.

It is forbidden to use the internet, intranet and / or e-mail system to send or receive discriminatory or harassing messages, chain letters, obscene or bad taste, commercial requests that, in any other way, violate this Code of Ethical Conduct. All messages sent or received by these means are the property of Fadel Transportes, with the right to verify and use it, and may even use such material as legitimate evidence and disclose its content in case of litigation or legal investigation.

Employees must, in their actions inside and outside Fadel Transportes, protect the physical and intellectual assets of the Company, which includes its brand and other intangible assets, movable and immovable assets, technology, business and marketing strategies, information, research and data.

It is not allowed to modify the original characteristics of the assets of Fadel Transportes, as well as to paste stickers or objects on computers, tables, among others.

The employee is responsible for preserving and protecting the property and assets entrusted to him, and must be alert to any situations or incidents that may result in losses, misuse or theft of Fadel Transportes' assets.

Notebooks, cell phones and / or other equipment must be used for work, properly and safely.

Protection of Information and Data

It is forbidden for all employees to give, inform and / or pass on to other employees or third parties, their password for access to computerized systems.

It is not permitted to cause or consent to security breaches or interruption of network communication, avoid user identification or the security of any computer, computer network, application or other technology and / or reveal your password to others allowing them to use it.

The Employee is responsible for the health and integrity of Fadel Transporte's information stored on the devices assigned to them for the performance of their professional activity. If such information is violated, the IT area must be immediately communicated and if negligence and misuse of the equipment is found, the Employee may be held responsible.

Responsibility for the preservation of information also extends to customer information that the Employee has access to because of his professional activities developed at Fadel Transportes, with all information obtained as a result of the existing service provision being considered confidential information, its disclosure being forbidden in any case.

It is not permitted to use unauthorized software on the Fadel Transportes data network, share confidential company information in any medium, or disclose company information on your social networks without authorization.

Confidentiality of Information

All information that the employee has access to as a result of his employment contract is considered confidential, and its disclosure to customers, competitors, suppliers, as well as to employees from other areas is expressly prohibited, in view of the duty of care with the information. obtained due to the role performed at Fadel Transportes.

The above prohibition even extends to employees and other companies belonging to the same economic group, and the duty of confidentiality is also violated in these situations.

For the purposes of this chapter, information that is in the public domain will not be considered confidential information.

In situations where the employee is summoned and / or summoned to provide clarifications involving information considered confidential, he / she must immediately communicate his / her superior for knowledge and guidance on how to proceed.

Associate the company in Social Networks

Fadel Transportes expects, from all employees and suppliers, an ethical positioning with social networks, as employees form the image of the company, representing and building the reputation of Fadel Transportes.

All the principles, guidelines and conduct established in the company's Code of Conduct are applicable to your participation in social networks.

Therefore, the following guidelines are established:                                                                                             

  • The creation, participation or interaction, by the collaborators in social networks, forums, blog on the Internet or in any means of written or virtual communication, the opinions or manifestations issued must be strictly personal, and the association of Fadel Transportes with the image is expressly forbidden. employees on social networks;
  • Criticism of Fadel Transportes professionals, suppliers or customers on public websites and social networks is not acceptable;
  • When making your own publications or commenting on third-party content, be courteous and relevant. It is possible to disagree or argue respectfully, maintaining a good education;
  • It is prohibited to share confidential company information on public or private networks, as well as comments on internal matters dealt with in meetings or conversations with coworkers;
  • The carrying out of cyber crimes by employees of Fadel Transportes will not be tolerated;

Moral / Sexual Harassment

Avoid and report behaviors that can be interpreted as any form of harassment, whether of a sexual nature or offensive behavior, such as insults, jokes, criticisms, use of abusive language, exposure of offensive material in the workplace, which may convey a connotation of hostile environment;

It is considered bullying:

  • Exposing someone to a humiliating situation;
  • Embarrassment;
  • Defamation;
  • Slander;
  • Psychological violence;
  • Scoldings;
  • Threats;
  • Giving wrong instructions or omitting information necessary for the exercise of functions;
  • Impose unjustifiable schedules;
  • Transfers to isolate or punish the subordinate;
  • Force the employee to resign;
  • Persecutions;
  • Unjustifiable or illegal punishments.

It is considered sexual harassment:

  • Approach physically against your will;
  • Offer benefits or favors in exchange for sexual favors;
  • Retaliation against refusals of sexual involvement;
  • Sexual gestures;
  • Looking with sexual conduct;
  • Playing with objects, drawings that suggest sexuality;
  • Malicious words;
  • Obscene letters, invitations, tickets or messages;
  • Touching, preventing or blocking movements;
  • Sending emails, SMS, WhatsApp with pornographic content.

Discrimination or prejudice as to race, color, ancestors, nationalities, marital status, age, philosophy of life, beliefs, political ideologies, disabilities, physical and mental limitations, physical condition or pregnancy will not be tolerated. Offering equal opportunities based on competence and individual performance.

Environment

Sustainability is a suit used to define human actions and activities that aim to meet the current needs of human beings, without compromising the future of future generations. In other words, sustainability is directly related to economic and material development without harming the environment, using natural resources in an intelligent way so that they remain in the future. Following these parameters, Fadel aims to be able to guarantee human and sustainable development in the business environment.

We preserve the environment, and take necessary measures to minimize or eliminate the impact that its activities may eventually generate, always taking care to maintain health and preserve the environment.

Compliance with Laws, Rules and Regulations

Fadel Transportes respects the current labor legislation, as well as the working conditions of its employee. This document is based on the principles of the anti-corruption law, labor law.

No forced, slave or child labor will be tolerated, except for a minor apprentice contract.

Use of illicit substances

It is forbidden to work under the influence of alcohol, illegal drugs, as well as the use, possession or sale of alcoholic beverages, and drugs in the workplace or on the clients' premises is prohibited. Likewise, the carrying of a weapon of any kind is prohibited, except when duly authorized due to the exercise of the profession and the function exercised.

Weapons

Weapons of any kind are not allowed on the premises of Fadel Transportes, except for professionals expressly authorized to protect the company's employees or assets.

To ensure effective compliance with this standard, Fadel Transportes may authorize inspection of cabinets, vehicles, bags and backpacks of employees and contracted third parties.

Violation of the Code of Conduct

Fadel Transportes guarantees through the Ombudsman Channel, the necessary apparatus so that the employee can declare his suspicions of violation of this policy or unethical conduct. In this way the company will not terminate, transfer, suspend or discriminate against the person who proceeded to register the occurrence of an allegedly unethical or illegal action. Also included is anyone who is assisting in the investigations. Remembering that the process of reporting through the Ombudsman Channel, there is the option of anonymous reporting.

However, false statements will not be tolerated, with the aim of harming third parties or the company itself. Disciplinary procedures will be used for such conduct.

Failure to comply with the rules set out in this Code will result in disciplinary action, including procedures authorized by labor law, including the possibility of termination of the Employment Contract.

The company may also adopt civil measures and report criminal acts to the competent administrative and judicial bodies.

The waiver or amendment to any part of this Code requires the approval of the Ethics Committee.

Internal Ombudsman Channel

It is everyone's duty to cooperate to clarify facts and conduct that disrespect the rules provided for in this code. For this reason, Fadel Transportes provides the Complaints Channel. It is a tool where employees, suppliers and business partners can contact and report a suspicious action that is at odds with our Integrity Program, composed of:

  • Fadel Transportes' Code of Conduct;
  • Ethics;
  • The laws;

The complaint will be received by a third party company, guaranteeing the whistleblower's exemption and anonymity, this company will carry out an initial analysis and forward it to the Council

Administrative Board of Fadel Transportes, composed of members of the board. The Council will go deeper into the analysis and as a group it will make decisions about the actions to be taken.

Fadel, in order to further strengthen communication with employees and other interested parties in matters related to ethical conduct and / or irregularities, as mentioned above, hired Contacto Seguro, an independent company that provides communication channels for receiving complaints. and through a secure and anonymous tool.

Reports can be made in two ways:

By telephone on a toll-free number 0800 726 7111 this contact is available 24/XNUMX.

Via web on the website www.contatoseguro.com.br/fadel. This option works 24 hours a day.

The whistleblower can remain confidential, but if he wishes, the whistleblower can identify himself. If the complaint is made by telephone, Fadel Transportes will not receive the recording of the conversation, only the transcript, and there is no risk of identifying the person by the voice.