Launched in 2019, our Compliance Program has the unconditional support of the Executive Board and the Board of Directors, as its main sponsors, and is constantly being improved, given the evolution of the Softplan Group’s businesses.

Discover the pillars of the Compliance program

Senior management support

Senior management support

Support the Compliance Program, ensuring a culture of integrity in conducting business.

Compliance Risk Management

Compliance Risk Management

Risk Management goes hand in hand with the company’s objectives and is in line with the business strategy.

Code of Conduct and Compliance Policies

Code of Conduct and Compliance Policies

The Code of Conduct, policies and other normative documents establish clear and transparent guidelines.

Internal controls

Internal controls

Mechanisms that ensure compliance with standards and procedures through controls and monitoring in order to mitigate operational and compliance risks.

Communication and Training

Communication and Training

Reinforce the culture of integrity and compliance through communications and training on the topic of Compliance.

Due diligence

Due diligence

Our due diligence process assesses risks of reputation, integrity, corruption and processing of personal and/or sensitive data under the responsibility of the Softplan Group, resulting from our relationship with third parties and potential employees.

Monitoring and Auditing

Monitoring and Auditing

Our program is independently assessed and aims at continuous improvement.

Ethics, Inquiry and Consequence Channel

Ethics, Inquiry and Consequence Channel

The official channel for secure and confidential communication, which can be made anonymously or confidentially, and is available to the internal and external public to report concerns or denounce situations that violate our Code of Conduct or current legislation.

Practices of compliance with Anti-Corruption Laws

Anti-corruption laws exist to ensure the quality of public management, a mission that we also undertake with our products. Therefore, we do not offer, promise or accept to pay money or anything of value to public officials from any country, their family members or anyone connected to them, with the intention of doing or retaining business. That is, we do not allow bribes, kickbacks, “facilitating” payments to any government official on behalf of Softplan Group companies or in their interest, and we also do not carry out acts that aim to defraud, frustrate, prevent or disrupt bids or bidding acts. Below are some of the main guidelines of our Anti-Corruption Policy:

The granting and/or acceptance of freebies and gifts is allowed up to the limit of BRL 200,00 (two hundred reais) in the domestic market and USD 40,00 (forty dollars) in the international market, nevertheless, granting gifts to Public Officials is prohibited. The granting and/or acceptance of hospitality and corporate courtesies is also permitted, provided that done for professional purposes directly related to the activities of the companies of the Softplan Group.

All granting and/or acceptance of freebies, gifts, hospitality and corporate courtesies, must occur in accordance with the applicable federal, state and municipal laws, including the internal rules of the receiving party, the most restrictive rule always prevailing, if there is more than one, the process being always conducted in a transparent and honest way.

Promising, offering, giving, requesting or accepting benefits in exchange for undue advantages, favors or business assurances, including any amount in cash, is prohibited.

As a principle, we only pay for business meals at reasonable prices, always observing if the practices of the receiving party allows it, especially if such party is a Public Official or PEPs.

The granting and/or acceptance of corporate courtesies is allowed, as long as for professional purposes, directly related to the activities of the Softplan Group companies, such as invitations to corporate and business events.

It is possible for the Softplan Group to pay for travel and/or accommodation, as long as they are in connection to events related to the Group’s business. This practice includes relationships with Public Officials or PEPs, provided that at reasonable prices and for reasonable services, leisure travel and/or accommodation is prohibited.

Softplayers or intermediary third parties responsible for conducting any type of act on behalf of the Softplan Group, which have ties of any nature that could compromise the Softplan Group’s interest in such act or are not independent for any reason in relation to the act, must timely declare their conflict of interest or particular interest and immediately withdraw from the conflicting relationship, abstaining from any decisions related to such act.

Our employees and third parties are chosen based on technical criteria, through transparent hiring processes.

Indications are welcome, however, participation in our selection process along with other candidates is a fundamental prerequisite for all hiring.

Until completed, all payments made by the Softplan Group go through rigorous fiscal approval and bookkeeping proceedings, and are actually paid through bank details, wire transfer or pay slips, never in cash.

Our third-party engagements are grounded on an Integrity Due Diligence (DDI) analysis, which allows us to know them better and have an understanding of the potential risks arising from the future partnership relationship.

Our care and commitment to keeping our accounting and financial records stated in a true, accurate and up-to-date manner is an essential part of our anti-corruption practices. Likewise, we require that our third parties have the same commitment in relation to their accounting and financial records.

The Softplan Group repudiates any practice of money laundering or terrorism, nor does it request, authorize or tolerate third parties to engage in such practices.

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CEO Message

“Our Code of Conduct was built with our values ​​as a foundation and, for this reason, it becomes a fundamental tool that guides our employees in making decisions and choosing the right paths. Furthermore, our Code is a commitment made by the Softplan Group to citizen and responsible management of its operations.

We are one of the largest software companies in Brazil and this position brings us great responsibilities for the security of our systems, our products and our information. With ethics as the basis of our relationships, this care must be reflected in daily actions, guaranteeing our commitment to all customers, partners, employees and associates.

We are growing and have major strategic objectives for the coming years. Therefore, we have reason to believe that the success of our business presupposes a commitment to ethics, diversity and doing what is right, maintaining the organic and consistent growth of our current operations and accelerating our M&A processes.

Our Code of Conduct offers readers accessible content and has a team of professionals to manage, guide and clarify doubts about how to act in accordance with the values ​​of the Softplan Group.”

Eduardo Smith – CEO

Softplan Purpose

To promote fundamental changes in people’s lives.

Discover our Values

https://www.softplan.com.br/wp-content/uploads/2022/08/success.png

Focus on customer success

Everything begins with the customer. We are a better company because of them, which is why it is so important to understand their challenges and needs, operating with excellence for the best results. After all, their success is our success too.

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Softplayers are our foundation

We trust and value our team, because it is each and every one of us that builds Softplan every day. We believe in healthy relationships, good communication and respect for a productive and inspiring environment.

https://www.softplan.com.br/wp-content/uploads/2022/08/leaf.png

Sustainable, strategic and results oriented vision

Responsibility is in our DNA and it includes a strategic vision that goes beyond today’s results. After all, every action we take today has an impact tomorrow. Being responsible is understanding how to build our future every day.

https://www.softplan.com.br/wp-content/uploads/2022/08/knowledge.png

Transformation-oriented innovation

Innovation focused on the user, aimed at solving a real problem. This is the innovation that interests us, which leads us to previously unimaginable solutions.

https://www.softplan.com.br/wp-content/uploads/2022/08/deal.png

Together we are stronger

We work better when we think together and celebrate more when one’s achievement is everyone’s victory.

ethical principles

  • Honesty
  • Reliability
  • Respect
  • Common sense
  • Responsibility
  • Diversity

What is the objective of the Code?

Built based on Group Values softplan, the Code of Conduct aims to present the conduct guidelines that guidem and directsm a performance da empresa in relationships with all audiences as a legal duty and mainly in compliance with its commitment with doing what is right. 

Who must comply with the Code of Conduct?

Observance and practice of the conduct and ethical principles defined in this Code apply to all people who have a relationship with the Softplan Group, which, for the purposes of this Policy, comprises its controlled, affiliated and invested companies, including all shareholders, advisors, committee members, Board members, employees, suppliers, service providers, business partners, representatives and distributors who act on behalf or in the interest of these companies in the national or international market.

Img who should comply?
img ethical decisions

Questions about making ethical decisions

If you are in doubt, at any point, about what to do in relation to ethical conduct, whether in the professional environment or outside it, ask the following questions: 

  • Is it within the limits of the Law?
  • Do you comply with Softplan’s policies?
  • Does it reflect the values ​​and ethical principles of the Softplan Group?
  • Does it respect employees, shareholders, customers, partners, communities and the planet?
  • Would you publish your decision on your social media?

If the answer to any of these questions is “no”, it is very likely that the behavior or attitude in question is inappropriate and not tolerated by the Softplan Group. If you still have any questions, look for your leader and ask for help, he is prepared to provide you with the support and guidance you need. You can also consult the Anti-Corruption Policy and contact the Compliance by email compliance@softplan.com.br. 

Additional responsibilities for leaders

Leaders are a strong reference for their teams and, for this reason, they have a transformative role in the work environment. Therefore, it is the leader's responsibility to have exemplary ethical conduct, promote a respectful work environment, ensure that their subordinates read, understand and sign the commitment to act in accordance with the Code of Conduct and always guide and act if they become aware of any attitude in non-compliance with this Code.

Code of conduct

COMMITMENT TO EMPLOYEES

Softplayers are our base – We value people, their differences and the difference that each person makes.

 

Healthy and respectful work environment

In all modalities (in-person, hybrid or virtual), the Softplan Group encourages a respectful, pleasant and productive work environment, with full freedom to clarify doubts and/or receive suggestions through open and transparent dialogues.

Your duty
  • Act with empathy, a collaborative spirit and professionalism, regardless of the position or professional activity you occupy.
  • Resolve problems professionally and respectfully, never with intimidation or violence.
  • Report irregularities or violations of the Code of Conduct via the Ethics Channel.

 

diversity and inclusion

The Softplan Group encourages and supports diversity and inclusion actions, respecting and valuing the differences between people, and does not tolerate any behavior of action and/or omission that may reflect prejudice or any form of discrimination, due to nationality, color, identity of gender, sexual orientation, age, disability, marital status, pregnancy, social class, religion, hierarchy or any other type not mentioned here.

Your duty
  • Respect the differences of each individual, ensuring equal treatment and providing an environment where everyone feels welcomed.
  • Do not base your actions on prejudgments, as, intentionally or unintentionally, some actions, such as: creating nicknames, making jokes or derogatory comments with any reference to nationality, color, gender identity and/expression, sexual orientation , age, physical and/or mental condition, marital status, pregnancy, social class and religion can embarrass and create a hostile work environment.

 

Prevention of harassment and other forms of violence

Everyone has the right to work free of intimidating, hostile or offensive behavior from anyone, including superiors, other employees, suppliers, partners and customers. Therefore, the Softplan Group does not tolerate abuse of power, moral and/or sexual harassment and other forms of violence in the workplace.

Moral harassment can be defined as any abusive conduct, such as gestures, words and attitudes that are repeated over time, affecting the dignity or psychological or physical integrity of a worker. Examples are, but not limited to:

_Constantly contest or criticize the person’s work;

_Overburdening her with excessive tasks or purposely leaving her idle, causing a feeling of uselessness and incompetence;

_Deliberately ignoring the person’s presence;

_Spread offensive rumors about the person;

_Address the screaming person;

_Threaten your physical integrity.

Sexual harassment is conduct of a sexual nature, physically manifested by words, gestures or other means, proposed or imposed on people against their will, causing embarrassment and violating their sexual freedom. Harassment becomes a crime when practiced by a hierarchical superior, however, conduct by people without a hierarchical relationship can be considered other crimes. Examples of sexual harassment conduct:

_Requiring sexual conduct in exchange for benefits or to avoid harm to the work relationship;

_Untimely sexual provocations with the aim of harming a person's work performance or creating an offensive, intimidating or humiliating situation.

Reports of harassing conduct, as well as other violations of this Code, must be reported to the Ethics Channel so that they can be investigated and dealt with under the terms of the items “Reporting concerns or Violations” and “Applicable Sanctions”.

Your duty
  • Address people respectfully.
  • Value work.
  • Report situations of any type of harassment via the Ethics Channel;
  • Respect each other's space.
  • Do not touch the person without their free and express consent.
  • Do not engage in any conduct that could constitute moral or sexual harassment or other forms of violence.
  • Do not doubt the victim's word or blame them for what happened.
  • Promote a safe work environment.

 

Health and safety in the workplace

The Softplan Group believes that health, quality of life and work safety are fundamental for its employees to have a life of more harmony, happiness and longevity. Therefore, considering health in the physical, mental and emotional spheres, it understands that employees must work in a safe and sustainable way, which will enable them to perform better in their daily activities and favor the maintenance of their personal and professional growth.

Aiming to achieve these objectives, the People & Culture area provides a team specialized in Occupational Health and Safety (OSH), which works to promote and raise awareness of daily care that is essential for the well-being of each employee. In addition to all this care, the Group also complies with legislation related to labor rights and working conditions in force in the locations where it operates.

Your duty
  • Know the company's safety standards and perform their work in a professional and responsible manner.
  • Take care of yourself and your peers to prevent any risks arising from work and use personal protective equipment (PPE) whenever necessary.
  • Carry out occupational medical examinations when called upon.
  • Communicate your absences due to illness and work disability to your superior, observing the deadlines defined by the applicable Collective Norms and Policies.
  • Participate whenever possible in actions promoted by the Occupational Health and Safety (OSH) team and the Softplan+Saúde program, such as health webinars, review reading and workplace gymnastics.
  • If you have any questions, please contact us via email:segurancadotrabalho@softplan.com.br.

 

Alcohol, illicit drugs, illegal carrying of weapons and violence

The Softplan Group understands that alcohol, illicit drugs, illegal possession of weapons and violence can negatively affect the safety, productivity, attitude, reliability and judgment of its employees who must provide and enjoy a working environment safe, without any type of negative interference that affects the full performance of its functions. Below, see some important conduct guidelines for guiding your stance in relation to these topics.

Your duty
  • Alcohol: Know that it is prohibited to be under the influence of alcohol or consume it on Softplan Group premises during working hours, including the home office or any other place where you are representing the Softplan Group. Any exceptions to alcohol consumption may occur in specific situations, such as celebrations or corporate events, as long as they have prior authorization from the board and/or People & Culture area. On these occasions, use common sense and consume in moderation.
  • Illicit drugs: Know that, under any circumstances, the consumption, possession and storage of illicit drugs is prohibited on the Softplan Group premises or in any other location where the Softplan Group is represented. It is also prohibited to remain under the influence of illicit drugs during working hours, even if in a home office or any other location.
  • Carrying a weapon: Know that it is prohibited to carry and/or keep a weapon of any kind on the Softplan Group's premises or in any other place where you are representing the Softplan Group, except if the use of a weapon is part of the duties of the position you hold.
  • Violence: Know that any type of violence is prohibited, whether physical or verbal, both through communication tools and in person, on Softplan Group premises or in any other location where Softplan Group is represented.

 

Respect for the privacy of personal and/or sensitive information of each person

The establishment of the company/employee relationship allows the Softplan Group to collect personal information from its employees (such as: names, ID and CPF numbers, bank account, email addresses, IP, among others), which are collected, processed and stored securely, with the aim of preventing leaks or misuse of this data, in compliance with the privacy and data protection laws in force in the locations where it operates.

Your duty
  • Do not share any personal information or other private data of Softplan Group employees, unless you have authorization from your immediate leader to do so.
  • Carry out your activities in an ethical and responsible manner, as the information you have access to is your responsibility.
  • Follow the guidelines provided by the Information Security and Personal Data Governance area.

 

Respect each person’s individual opinion and activities

The Softplan Group recognizes the limits of its employees' private lives and respects freedom of expression and plurality of opinions, in addition to understanding that all forms of communication and expression must be issued and received in a respectful and polite manner, regardless of the circumstances. In this sense, as a member of the company or related third party, you must act responsibly, taking care of your image and the image of the Softplan Group, as some individual and/or personal actions inside and outside work may be associated with professional activity and negatively affect the reputation and commercial interests of the Softplan Group. Below, see some important conduct guidelines for conducting your individual activities.

Your duty
  • Social media: Know that content published on personal social media and networks (Facebook, Instagram, Twitter, WhatsApp, among others) that is related to business activities can be associated with the company's image, so be careful that your communication is aligned with the company's values, respecting all people, especially if expressing value judgments.
  • Press: Only spokespersons are authorized to speak on behalf of the Softplan Group or its companies. Therefore, if you are not one of these people and are asked to give statements or grant interviews to entities or the press (newspapers, radios, television, websites, blogs or other vehicles) that involve your professional activity in the companies of the Softplan Group or about company, must direct it to its immediate leadership and the Marketing area so that the situation is evaluated. In any case where prior arrangement is not possible, thank them for the opportunity and say that they are not authorized to carry out such a practice.
  • External activities: When invited to participate in external events to act as a speaker, special guest, debater, mediator, presenter or any other functions due to your professional position in the Softplan Group, such as: live, webinar, among others, you must request authorization from the immediate leader before accepting the invitation, to avoid any interpretation of conflict of interest. On these occasions, you must take care that no confidential information is exposed.
  • Political positioning: The Softplan Group respects the political positioning of its employees and expects everyone to ensure the maintenance of its image of independence and neutrality in relation to the topic. Therefore, it does not allow political demonstrations within the company or through any communication tool used for work. Be careful when expressing yourself publicly so that your personal statement is not confused with the company's position or gives the impression that it supports or endorses any campaign, candidate or political party.

COMMITMENT TO SHAREHOLDERS AND FUTURE INVESTORS

Sustainable, results-oriented strategic vision – We are eager for the best results, we act with a sense of ownership and are oriented towards the future.

 

Conflict of interests

A conflict of interest is configured when, for their own interest or that of third parties, a person acts or is influenced to act against the objectives and principles of the company for which they work, provide services or have another type of relationship, making some type of inappropriate decision. in which they prioritize personal interests or those of third parties, failing to fulfill their professional responsibilities.

The Softplan Group disapproves of any activities and/or situations that pose a threat to the integrity of its values ​​and ethical principles or that may raise suspicions about the integrity of its activities.

Examples of conflict of interest situations:
  • Use Softplan Group equipment or resources (including confidential information or intellectual property of the company or its customers and third parties) for your own benefit or that of others.
  • Engage in any parallel activity that competes with the Softplan Group, that violates confidentiality, intellectual property or other obligations to the Group, or that is illegal, immoral or could generate negative consequences for the company.
  • Carry out business outside the knowledge of or not authorized by the Softplan Group with business partners, suppliers or active customers, with whom you have had contact through the Softplan Group.
  • Participate in boards of for-profit companies, whether publicly traded or privately held, unless approved by the CEO and indicated by the Board of Directors of the Softplan Group.
  • Having a family or romantic relationship with public agents or politically exposed people, especially those who perform a relevant function in entities that are related to the Softplan Group, including a leader, subordinate, colleague in the same area or colleague whose professional relationship includes a relationship of subordination or power of influence on the activities performed.
  • Use confidential or restricted information to obtain any type of advantage for yourself or third parties or to harm the Softplan Group.
  • Trading any type of Softplan Group security based on privileged information, such as: debentures, shares, subscription warrants, subscription rights, promissory notes, call or put options, indices and derivatives of any kind, or even any other securities or collective investment agreements issued by the Softplan Group or referenced thereto, which, by legal determination, are considered securities.
Your duty
  • Be careful not to put yourself in situations of conflict of interest, preventing your credibility from being questioned.
  • Remember that situations that may give rise to a conflict of interest are subjective and may vary depending on your personal relationships, side jobs, commercial partnerships, investments, personal businesses or the exercise of external functions as board members and governance.
  • Inform any of your relationships, associations or activities that may create an actual or potential conflict of interest to your leader or the Compliance area so that the situation can be assessed and dealt with appropriately.

 

Intellectual property

All work carried out by the Softplan Group through its administrators, collaborators and third parties is protected by law and must have its confidentiality, integrity and availability assured, and sharing is prohibited without express authorization from the competent authority.

The patrimonial and moral rights related to intellectual property assets created by its employees in the performance of their professional activities will be considered the exclusive property of the Softplan Group, which includes source and executable programs, components and classes developed, business models, sale, patents and brands, copyright of artistic or literary works, documentation, manuals, journalistic texts, content for portals and blogs, videos, photographs and any other products and by-products generated.

The Softplan Group not only protects its intellectual property but also complies with legislation and treats confidentially the intellectual property of third parties with whom it interacts (clients, business partners or other parties) as a result of professional activities.

Your duty
  • Ensure the intellectual property of the Softplan Group and/or third parties, refraining from maintaining and sharing unauthorized copies or revealing them to third parties.
  • Never copy, disclose or use protected information in any way without due authorization.
  • Reveal or receive confidential information only when supported by a confidentiality term prepared or validated by the Corporate Legal Department, in order to avoid infringement of intellectual property against the Softplan Group.
  • Never encourage piracy or unauthorized reproduction of any materials, source codes, systems or software.

 

Use of Softplan Group assets

The Softplan Group offers its professionals all the resources necessary to carry out their activities, which includes the provision of assets they own, including physical assets (physical premises, furniture, technology equipment, among others) and non-physical assets (software , information systems, digital files, e-mail, internet, intellectual property, confidential information, among others).

The use of the company's assets must be restricted to professional purposes, therefore, in accordance with local legislation, the Softplan Group reserves the right to monitor the use of its assets, including information technology resources, at any time, without prior notice, subject to the limits of the law.

Access, transmission and archiving of inappropriate and illegal content, including pornography, games, discrimination and activities against public property or third parties, are prohibited.

Your duty
  • Value the integrity, security and appropriate use of any and all company assets, especially those entrusted to you.
  • Use office materials, paper, as well as water, electricity and other company assets responsibly and conscientiously, avoiding waste and misuse.
  • Keep workstations clean and organized.
  • Use assets only for professional purposes and do not keep personal data, messages or private information in assets belonging to the company.
  • Follow the determinations of internal policies and procedures and information security guidelines: never install programs not licensed by the company; use strong passwords; lock your equipment when you are away from your workplace; only use software approved by Corporate IT; Turn off your equipment at the end of the day. These attitudes are important to ensure the application of IT and Information Security policies.
  • In no way lend, donate, sell or dispose of assets, regardless of their value, physical or economic condition. If you find the need to dispose of an asset, always follow the internal procedures to formalize the process.
  • Never use company assets to access, store or share offensive, pornographic or immoral content.

 

Information Security

Confidential Information

The Softplan Group's confidential information is an indispensable asset for business success and consists of patents, commercial secrets, copyrights and other intellectual properties developed, licensed or acquired by the Softplan Group. They may also consist of information belonging to or about customers, associates or other interested parties that was revealed to the Softplan Group under an obligation of confidentiality.

Examples of confidential information are: employee personal data (health, salary and performance), customer information, customer list, technical information, specifications (products, projects and prices), business strategies, internal policies and management practices. business, legal proceedings, financial results, planned or contemplated mergers, acquisitions or joint ventures).

Everyone who has access to any type of confidential information is responsible for the protection, management and use of this information, in accordance with the applicable legislation and the Softplan Group's internal regulations.

Your duty
  • Comply with all internal regulations on Information Security.
  • Store Softplan Group information in authorized physical locations or in electronic locations using tools authorized by the company.
  • Maintain the confidentiality of confidential or restricted information to which you have access, including that of Softplan Group customers and business partners.
  • Reveal or receive confidential information only when supported by a confidentiality agreement drawn up or validated by Corporate Legal.

 

Gifts, gifts, hospitality and corporate courtesies

The Softplan Group conducts its business ethically and with integrity, complying with all legal requirements regarding the granting and acceptance of gifts, gifts, hospitality and corporate courtesies everywhere it operates. No employee or third party is authorized to promise, offer, give, request, demand or accept benefits in exchange for undue advantages, favors or business guarantees. Guidelines for granting and accepting gifts, gifts, hospitality and corporate courtesies may vary, depending on the type and situation in question. These situations, when permitted, must occur in a transparent manner and in accordance with the Gifts, Presents, Hospitality and Corporate Courtesies Policy, mandatory for all employees and third parties acting on behalf or in the interest of the Softplan Group.

Your duty
  • Never promise, offer, give, request, demand or accept any type of tangible or intangible benefit in exchange for undue advantages, favors or business guarantees.
  • Do not accept any gift, gift, hospitality or corporate courtesy if you are in a conflict of interest situation.
  • Do not accept gifts or gifts whose value exceeds R$200,00 in the Brazilian market or US$40,00 in the international market.
  • Do not promise, offer or give gifts to public agents and politically exposed persons (PEP).
  • Consult local legislation and the internal rules of the recipient party in advance, whenever you intend to make any concession and always follow the strictest rule, if there is more than one guideline.
  • Not accepting gifts, gifts, hospitality and corporate courtesies frequently.
  • Politely refuse any gift, gift, hospitality or corporate courtesy that is above the allowed amount, reinforcing compliance with the Softplan Group's internal guidelines. If it is not possible to refuse upon delivery, report the situation to the Compliance area for proper disposal.
  • Follow the guidelines of the Gifts, Gifts, Hospitality and Corporate Courtesies Policy.

 

Financial records and accounting books

The Softplan Group understands that the integrity of its financial statements and other regulatory files is crucial for the continuity of its business and for the establishment of a relationship of trust with its employees, customers, commercial partners, supervisory entities and other interested parties, therefore, issues reports and balance sheets correctly, truthfully and in accordance with applicable legislation.

Your duty
  • Faithfully follow all implemented control processes, in an integral manner, so that all financial records are correctly accounted for.

 

Risk management and audit

At the Softplan Group, all leaders are responsible for managing the risks of the processes for which they are responsible, which may occur through compliance with external and internal regulations, as well as by monitoring and applying internal controls relevant to the process. Furthermore, the Softplan Group subjects its processes to external and internal audits, in order to promote continuous improvements that strengthen the longevity of its companies.

Your duty
  • Reflect on the impact of your actions and how they can affect the Softplan Group, so that your decision-making is safe.
  • Maintain constant compliance with the Softplan Group’s standards and procedures.
  • Carry out your activities in accordance with internal regulatory documents, always cooperating with audit, compliance and risk professionals, if requested.
  • Report risks to your leader or the Compliance area.

COMMITMENT TO SHAREHOLDERS AND FUTURE INVESTORS

Transformation-oriented innovation – We value a culture of learning and improvement, focused on the best solutions and innovation.

 

Acquisitions, mergers and other business operations

The participation of the Softplan Group in the processes of mergers, acquisitions, joint ventures and corporate reorganizations requires, in addition to economic and financial assessment, other prior diligence related to the verification of possible irregularities or illicit acts. All processes are approved by the Board of Directors and any interaction prior to the conclusion of the operation must be protected by the appropriate contractual documents relevant to the operation.

Your duty
  • Interact with employees of companies involved in mergers, acquisitions and joint ventures with due caution, in case you are called upon.
  • Receive employees from companies integrated into the Softplan Group with empathy, striving for a learning culture on both sides.

COMMITMENT TO CUSTOMERS

Focus on customer success – We deliver value to customers, who represent our key indicator of success.

 

Long-lasting relationships, keeping promises and providing safe and reliable solutions

For the Softplan Group, customers are its reason for existing and to them it is committed to doing business in a fair, honest, lawful and ethical manner anywhere in the world, complying with all legislation that protects consumer relationships and prohibits commercial practices. misleading. Additionally, knowing its importance and responsibility in developing software that simplifies and generates value for solving complex problems that benefit the whole of society, all Softplan Group solutions are developed in accordance with applicable regulations and standards, therefore, they are safe and reliable.

Your duty
  • Conduct negotiations and contracts in accordance with current laws and regulations, valuing ethics, transparency, integrity and honesty in interactions, from the promise of a solution to final delivery.
  • Offer the best solutions for customer success.
  • Never promise solutions that you are not sure can be fulfilled.
  • Communicate clearly and be available to clarify doubts.

 

Protection of personal data and confidentiality of customer information

The Softplan Group takes its responsibilities regarding the protection of customer data very seriously, as sometimes, depending on the contract, it may have access to private and personal information that, in addition to being highly confidential, is protected by law. In this sense, the Softplan Group complies with all Brazilian laws and regulations on the protection of personal data, including the Marco Civil da Internet and the General Data Protection Law, as well as international legislation in force in the countries in which it operates.

Your duty
  • Comply with the legislation as well as the policies, contractual obligations and standards adopted by the Softplan Group when dealing with customer data.
  • Maintain the integrity and confidentiality of customer data to which you have access and not disclose it to others or use it for other purposes.
  • Use only responsible and legal means when collecting information from customers or potential customers on behalf of the Softplan Group, ensuring that any personal information collected is only for legitimate business-related purposes.
  • Team members who work at the client's location or directly with the client's information technology resources must also comply with Softplan Group and client policies and standards for the protection of personal information.
  • Knowing that the misuse of customer data can result in serious consequences for Grupo Softplan and for you.

 

Compliance with public procurement requirements

Softplan Group's business is marked by a strong relationship with the public sector through the provision of technological solutions that help improve the lives of citizens in different locations. In addition to being crucial for the Softplan Group to conduct business lawfully, with integrity and in compliance with the laws that regulate activities in the Brazilian market and abroad, contracts with the Public Sector require additional obligations so that all interfaces and negotiations are carried out with due transparency. In this sense, only formally authorized employees and third parties can carry out commercial negotiations with the Public Sector on behalf or in the interest of the Softplan Group.

Your duty
  • Comply with the legislation, as well as with the policies, contractual obligations and norms adopted voluntarily by the Softplan Group when relating to the Public Sector in all interactions, in relation to offers, preliminary technical studies, bids, waiver of bids, negotiations, contract renegotiations or provision of services.
  • Provide correct, precise information within previously agreed deadlines in all interactions.
  • Comply with the Public Sector Relationship Policy, if you are involved with the topic.

COMMITMENT TO OTHERS, THE COMMUNITY AND THE PLANET

Together we are stronger - We collaborate and have a lot to share and grow together.

 

Intolerance of corruption and heinous crimes

The Softplan Group is committed to ethics and repudiates corruption, whether active or passive, regardless of where commercial negotiations are carried out. In this sense, it acts in compliance with all applicable anti-corruption laws, in particular Anti-Corruption Law 12.846/2013 and its decrees, and does not tolerate the direct or indirect involvement of employees, third parties or business partners in practices and conduct related to corruption and heinous crimes.

Your duty
  • Never promise, offer, pay or accept, directly or indirectly, a bribe, kickback or any other undue advantage in order to obtain favors in any contract/commercial agreement, even if requested, whether in the public or private sector.
  • Never offer, give or promise any gift or undue advantage to Public Agents or Politically Exposed Persons or people related to them, even indirectly or through others.
  • Never sponsor, directly or indirectly, personal interests or those of the Softplan Group with the aim of winning a bid or entering into public contracts with the Public Sector.
  • Notify the Softplan Group if it becomes involved in matters related to corruption or heinous crimes.
  • Act with good faith and transparency in all interactions, in accordance with the Anti-Corruption Policy.

 

Political activities and contributions to parties and candidates

The Softplan Group respects the position and political activity of its employees, however, it adopts a position of impartiality and impartiality in relation to any political party or candidate for elected office. Furthermore, the Softplan Group does not make donations or sponsor political parties or political candidates.

Your duty
  • Participate in civic and political activities of personal interest only during off-hours, without any connection to the image of the Softplan Group.
  • Do not use the financial resources or assets of the Softplan Group, including facilities, equipment or trademarks, to carry out personal political activities or for your own interests, such as making contributions to political parties or campaigns.
  • Be careful not to give the false impression that the Softplan Group supports or endorses any candidate, campaign or political party.
  • Inform the company if you want to run for public office, and request that you leave your professional activities during the election period and, if elected, request that you leave the Softplan Group.

 

Donations and sponsorships

The Softplan Group understands its social role and acts as a promoter of the common good also by supporting social actions and projects that are aligned with its values, strategic objectives and budgetary limits. In this sense, it makes donations and sponsorships according to clear concession, monitoring and accountability criteria and does not make donations to political parties or projects of a political, racial, discriminatory or any other nature that are not in legal compliance.

Your duty
  • Comply with the Donations and Sponsorship Policy, if you are involved with the topic.

 

Relationship with competitors

The Softplan Group complies with all laws and regulations applicable to free competition and works with professionalism and respect towards competitors, as it understands that a fair and competitive market generates a healthy competitive environment that brings benefits to everyone.

Aiming at the common objective of fulfilling public contracts, the Softplan Group may, in certain situations, sign agreements with competitors, establishing additional relationships such as 'commercial partnership' or 'service provision', within the limits of the law. These situations are permitted, but they require care in the relationship, even if both parties deal with matters of common interest.

Your duty
  • Conduct negotiations in compliance with fair competition and antitrust laws and regulations.
  • Maintain the confidentiality of information belonging to the Softplan Group, such as prices, sales conditions, commercial strategy, as well as other strategic and/or confidential information of the organization.
  • Never use improper means, such as spying or hiring former employees, to gain access to competitors' confidential information.
  • Never spread rumors or false information to harm competitors.
  • Never engage in cartel practices or any type of price fixing.

 

Relationship with suppliers and service providers

The Softplan Group's relationship with suppliers and service providers is guided by ethics, transparency and impartiality in hiring, as all are considered important strategic agents in the Group's relationship with the market and contribute to the success of the business. Seeking to take care of the selection process, the Softplan Group applies a rigorous evaluation process that aims to analyze the reputation and compliance with the Law in all areas and mitigate any risks.

Your duty
  • Comply with the Purchasing Policy, if involved in hiring processes.
  • Do not get involved in hiring processes if you are in a conflict of interest situation.
  • Request due diligence for hiring, in accordance with the Softplan Group's Due Diligence Policy, and remain alert to possible signs of non-compliance (red flags) even after hiring, reporting them to the Compliance area whenever identified.

 

Third party intellectual property

The Softplan Group respects the rights inherent to the intellectual property of third parties, as well as protecting its own intellectual property, not admitting the unauthorized reproduction of any materials, systems and software, as well as piracy of any nature under penalty of civil sanctions (damages ) and criminal.

Your duty
  • Never use any type of piracy or unauthorized reproductions of any materials, source codes, systems or software. Failure to observe this item exposes the offender to the penalties provided for in the legislation.
  • Check in advance whether you have proper authorization to copy, disclose or use protected information in any way.

 

Environmental protection

The Softplan Group understands that preserving the environment is fundamental so that the next generations can develop on an increasingly better planet and is proud of the contribution it makes, together with its customers, when it develops technological solutions that have an impact on reducing the use of role, including other initiatives in the field of technology.

Furthermore, the Softplan Group respects applicable environmental legislation, minimizing risks and impacts on the environment, has balance and care in the use and reuse of natural resources, combating forms of waste, including the appropriate disposal of waste and preference for suppliers and service providers. of services that have the same objectives.

Your duty
  • Conscientiously use resources such as water, energy, paper and others, as well as giving preference to the use of recyclable materials.
  • Dispose of trash and waste appropriately and according to their classification.

Reporting concerns or violations

The Softplan Group is committed to integrity and truth, conducting its business ethically in all situations.

The Ethics Channel is the official means for secure and confidential communication, which can be used anonymously or confidentially, available to all people who wish to report concerns or report any unethical, illicit conduct or conduct that does not comply with the Code of Conduct.

All reports are received and analyzed in an impartial, safe and completely confidential manner, with the aim of seeking all necessary measures to investigate, prevent and punish inappropriate conduct, not admitting any type of retaliation against those who have reported irregularities in good faith. .

Your duty

Report any suspicion and/or evidence of non-compliance with the precepts established in this Code of Conduct, taking into account that the leader is generally in the best position to provide guidance on issues and should be contacted first. However, if you do not feel comfortable reporting a concern or have already done so and the issue still concerns you, use the Ethics Channel. For more information about this process, access the Ethics Channel Report Investigation Policy.

Applicable sanctions

Employees who are proven to be in breach of the Code of Conduct guidelines will be subject to disciplinary and legal measures provided for in the Consequences Policy, which may include warning, suspension, dismissal and legal action, depending on the severity.

In relation to suppliers and service providers, proven non-compliance with the guidelines established in the Code of Conduct may result in, in addition to the penalties provided for in the contract, termination, without prejudice to repairing the damage caused.

Ethics and transparency. Everyone's duty.

The Ethics Channel is exclusive for reporting/reporting facts related to inappropriate behavior that violate the values ​​and ethical principles defined in the Softplan Group Code of Conduct, as well as applicable legislation, in particular Law No. 12.846/2013 – Anti-Corruption Law Brazilian Law, Colombian Law No. 1778/16, and American Law – FCPA.
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We believe that the success of our business must be guided by ethical attitudes in all situations, in order to maintain our reputation of integrity in everything we do.

The Ethics Channel is the official channel for safe and confidential communication, which can be used anonymously or confidentially, and is available to anyone who would like to report concerns or denounce situations that violate the principles of our Code of Conduct or current legislation.

Once a report has been made, we make the commitment to take the necessary measures to investigate, prevent and punish inappropriate conduct, and we do not admit any type of retaliation against those who have reported irregularities in good faith.

Please do not use this channel to report service calls, general clarifications, compliments or suggestions. For such matters, visit: www.softplan.com.br/contato and learn about other communication channels with Softplan products.