Code of ethics and conduct

I - TO WHOM THIS CODE OF CONDUCT APPLIES

 

This Code of Conduct applies to all MODAL CONSUL employees, such as its partners, employees, partners, clients, interns and suppliers in general, who work atMODAL CONSULT or provide some type of service to the company, regardless of the position held or the function performed.

The Code of Conduct aims to regulate the relationships that employees must maintain, inside and outside the company.MODAL CONSULT, with their own co-workers, customers, suppliers, consultants, business partners and Public Administration agents at all levels.

We hope that everyone follows the guidelines established in the document so that the execution of current and future contracts signed is guided by the principles contained in the Code of Conduct, safeguarding the reputable reputation of MODAL CONSULT and its partners and customers.

 

II - WORK ENVIRONMENT FREE FROM HARASSMENT, DISCRIMINATION AND INTERPERSONAL RELATIONSHIPS

 

Just as we care for all our employees and customers, we are aware that our partners also represent us in society. Therefore, their actions can be seen as attitudes of their ownMODAL CONSULT. Therefore, we expect that all agents who interact with theMODAL CONSULT act cordially and ethically in their relationships with society, business partners, public and private agents, in any circumstances.

We expect all employees to act in the performance of their daily duties based on the principle of good faith, respecting those with whom they work, always acting with honesty, transparency and integrity, resulting in the high degree of trust to which they are entitled, positively influencing results desired.

For good compliance with the regulations in force in the country, with the aim that employees of theMODAL CONSULT can carry out their activities in a productive and ethical manner, it is necessary to maintain a work environment free from any harassment and discrimination. 

It is, therefore, up to the employees of theMODAL CONSULT never expose each other to embarrassing situations while carrying out their activities.
Any type of distinction, exclusion or restriction based on race, color, sex, sexual orientation, gender identity, descent or national or ethnic origin is also prohibited. 

Respectful, cordial and professional treatment must permeate all hierarchical levels of employees and is mandatory inside and outside the company's premises.MODAL CONSULT.

 

III - CRITIQUES, SUGGESTIONS AND EVALUATIONS

 

AMODAL CONSULT encourages its employees and customers to submit criticisms and suggestions aimed at improving activities and stimulating their own development and proactivity. 

Criticisms, suggestions or compliments can be made via the email address contato@modalconsult.com.br or via the website, www.modalconsult.com.br/contatos.

 
IV - IMPORTANCE OF THE REPORTING CHANNEL

If you have knowledge or merely suspect a situation that does not seem correct to you – such as a violation of a law or the content of thiscode of Conduct, you must immediately communicate it to the responsible Compliance Manager so that the appropriate measures can be adopted.

If you do not wish to identify yourself, you can contact us through the so-called Reporting Channel available on the website.MODAL CONSULT, which is a confidential means of communication and, therefore, it is not necessary for the informant to identify himself. 

However, if you decide to reveal your identity, rest assured that it will be preserved (unless otherwise ordered by a court), and that you will not suffer any type of retaliation, even if it is a complaint involving your superiors. In this case, complaints may also be made through the Reporting Channel available on the company's website.MODAL CONSULT filling in the identification field of the complainant.

It is worth noting that theReporting Channel must be used exclusively for issues involving non-compliance with the conduct provided for in thiscode of Conduct and/or laws of which you are aware.

 

V - USE OF SENSITIVE INFORMATION

 

The collaborators ofMODAL CONSULT They operate in a sector of vital importance for the country and, therefore, have access to relevant information, as well as know-how that must be used solely and exclusively to meet the needs of the company and its respective customers.

It is mandatory for every employee to protect confidential information to which they have access and maintain confidentiality regarding the activities of the company.MODAL CONSULT and its clients, as well as the commercial secrets entrusted to it within the scope of the performance of its functions, which it became aware of as a result of its hiring or provision of services, including after the end of the employment relationship with the company.MODAL CONSULT.

The use of such information for one's own benefit or that of third parties constitutes a functional, civil and criminal infraction, subjecting offenders to the consequences provided for by law and internal rules of the Company.MODAL CONSULT. 

It is worth noting that disclosing untrue information, internally or externally, also constitutes serious misconduct, which may result in, in addition to labor consequences, civil and criminal liability for those who transmit it.

The transmission of information about theMODAL CONSULT and from its customers to external people or institutions should only be done by those who have authorization to do so.

 

VI - ELECTRONIC MAIL, TELEPHONES AND OTHER FORMS OF COMMUNICATION

 

AMODAL CONSULT provides its employees with access to email accounts, internet, telephones and other forms of institutional communication, which must be used for professional purposes and, therefore, may be monitored. AMODAL CONSULT will not monitor personal communications. Use for other purposes for this purpose is not recommended and is only permitted sporadically, without causing harm to its activities and to itself.MODAL CONSULT.

 

VII - CONFLICT OF INTEREST

 

A conflict of interest can arise when an employee demonstrates a personal, non-professional interest in the outcome of a certain conduct. Therefore, it is very important to avoid behaviors that may cause, favor or suggest a conflict of interest. However, if it is not possible to avoid it, its occurrence must be communicated to the Compliance Manager of theMODAL CONSULT.

If in doubt about the characterization of a conflict of interest, consult your immediate superior or the Compliance Manager. Employees must also inform if they have a close relative (understood: spouse, father, mother, siblings, children and other relatives up to the third degree) working in companies or public bodies with which theMODAL CONSULT relationships, in order to receive specific guidance to avoid any potential conflict of interest.

All employees must efficiently perform the tasks for which they were hired, to the best of their knowledge and ability. Therefore, any secondary work that undermines this obligation will not be accepted and may even result in the employee being dismissed.

 

VIII - INFORMATION, RECORDS AND DOCUMENTS

 

MODAL CONSULT employees are responsible for recording information that must be stored safely, correctly and accurately. All data that is part of everyday lifeMODAL CONSULT are of vital importance for the smooth running of the activities carried out. 

Any records and documents ofMODAL CONSULT must portray all progress accurately and in detail, without deviations and omissions, so that accurate financial statements and justifications can be provided at any time. Therefore, no relevant information must be omitted, fraudulent or recorded inappropriately, so that all possible audits are faithful to the reality of the situation.MODAL CONSULT.

 

IX - RELATIONSHIP WITH PUBLIC AGENCIES

 

It is part of the work carried out byMODAL CONSULT the close work of its collaborators with various entities and public agents. Therefore, it is important to say that this contact must always contain transparency, honesty and respect for these agents and for the public interest itself.
AMODAL CONSULT does not admit any type of corruption, public or private, being a company highly committed to the applicable legislation, in particular, the Brazilian Anti-Corruption Law (Law nº 12.846/13). This means that no employee may grant or accept any type of personal benefits, in the form of monetary value, goods or services that could interfere with the relationship in question.

AMODAL CONSULT Strictly prohibits its employees and third parties acting on its behalf from: offering, paying, promising payment or authorizing payment of amounts, gifts or any undue benefits to a public agent or person equivalent to them; agreeing on undue advantages to obtain and/or reduce the terms of a license, permit, authorization, permission, decision, etc.; illegally influence any act or decision of a public agent; induce a public agent to perform any act in violation of their legal duties.

If, by chance, a public agent requests any type of value, benefit, object, or favor that is not duly provided for by law, in order to carry out a task that he or she should carry out as a legal duty, the employee of theMODAL CONSULT You must refuse to do so and immediately report the fact to the Compliance Manager or your immediate superior.

It is the employee's duty to report as quickly as possible any action or mere suspicion that they have been aware of that could be harmful to the image and reputation of the company.MODAL CONSULT, ensuring the confidentiality of whistleblowers who do not wish to identify themselves.

Failure to comply with anti-corruption laws can result in serious penalties for theMODAL CONSULT and consequently to its employees, including criminal liability for the individual who is involved in the illicit practice. In addition, disciplinary measures may be applied if the employee's participation is proven, including dismissal for just cause or breach of contract.

It is also true that theMODAL CONSULT cannot allocate unjustified funds to this type of relationship – the so-called facilitating payments –, so that the rejection of the granting of undue advantages, not in line with the highest ethical standards adopted by the company, is clear and transparent.MODAL CONSULT.
In this sense, it is up to the employee and/or service provider not to offer in the name of theMODAL CONSULT, gifts, gifts, meals or any benefits for public agents, so that the attempt to illegally influence decisions or obtain privileged information is not characterized.

AMODAL CONSULT has an Anti-Corruption and Relationship with Public Authorities Policy available for consultation by all interested parties.

 

X - RELATIONSHIP WITH THIRD PARTIES

 

It is part of the reality of the work carried out byMODAL CONSULT the hiring of third parties, such as technical and legal advisors, general service providers, consultants, among others. 

The service provided by third parties must comply with current laws and maintain the ethical standards of the company.MODAL CONSULT, requiring respect for this code and the internal policies that complement it, so that the principles and values of theMODAL CONSULT.

The quality of the service provided by third parties, a basic criterion for their selection, is directly subject to compliance with this Code of Conduct, which will always be accessible to any and all third parties hired byMODAL CONSULT.

 

XI - GIFTS, GIFTS, HOSPITALITIES AND OTHER BENEFITS

 

Every employee ofMODAL CONSULT You must act with the utmost caution when accepting or offering gifts, meals or other benefits during commercial relationships with business partners and, especially, with public agents, so that this does not constitute or appear to be illegal.
It is important to avoid inappropriate situations that could illegally influence decision-making or cause conflicts of interest.

In the Anti-Corruption Policy and Relationship with Public Authorities ofMODAL CONSULT There is a specific chapter to guide employees regarding gifts, entertainment, hospitality and the like, establishing guidelines and values for offering and receiving the aforementioned items during relationships with third parties, public agents and customers.

The offering of gifts, entertainment, hospitality must comply with local laws, internal company policies,MODAL CONSULT and with the beneficiary's own rules. Furthermore, they must be offered in an open and transparent manner and be linked to a legitimate and verifiable business purpose.
Violations may result in severe administrative, civil and criminal penalties for theMODAL CONSULT and for its collaborators. If there are doubts about how to act, the employee should consult the Compliance Manager for the best guidance.

 

XII - APPLICATION OF SANCTIONS

 

Conduct that violates the provisions of this Code of Conduct or the Policies that complement it may result in the application of disciplinary measures in accordance with the severity of the act committed, with employees being subject, including, to the termination of their professional activities with theMODAL CONSULT through: i) dismissal for just cause; ii) dismissal of partners; iii) contractual termination, in addition to the penalties applicable by law.

AMODAL CONSULT will not, under any circumstances, admit practices such as bribery, corruption, money laundering and other illegal or unethical practices, which do not comply with the company's mission, vision and values or which violate any provision of this Code of Conduct or internal Policies.