Carnaúba do Brasil

Code of Ethical Conduct

INTRODUCTION
Our Code of Conduct, Ethics and Anti-Corruption is a guide to how we conduct our actions in the industrial environment to ensure a high level of quality in our relationships with our employees, suppliers, customers, shareholders, competitors, government and society in general. This code sets out our principles and guidelines, which are aimed at continuous development in the generation of sustainable growth conditions, a commitment to doing our best and respecting all people who Carnaúba do Brasil Ltda has a relationship with for the performance of its governance.

Quality Policy:
Provide Carnauba Wax with quality, product safety and respect for the environment, meeting customer, employees, partners and society needs and regulatory and statutory requirements, always in total commitment with continuous improvement in the Management System.

Organizational Culture:
Reflects our values of commitment to the business, client focus, punctuality, efficiency, courtesy, friendship, ethics, respect for human and individual rights, with the offer of fair work and respecting biodiversity.

Our Mission:
Meet the needs of the foreign and local Carnauba Wax market with efficiency and ethics and always take into consideration the quality and safety of the product, as well as the customer and his/her preferences. We offer this with assistance that meets the needs of social, environmental, human rights, fair trade and sustainable purchases.

Our Vision:
Become a benchmark in the Carnauba Wax market by meeting all the needs of the players in our productive chain, respecting people and the. Each leadership is responsible for the supervision and guarantee of procedures to ensure knowledge and dissemination of the ethical principles applicable to internal and external relationships under their responsibility. For such they will establish and maintain open channels to hear and act on matters related to possible violations of the policy and ethical practices of the Carnaúba business in Brazil. The Code of Ethical Conduct is not intended as a comprehensive guide to all situations and cases that may arise. The internal regulation tools complement the principles set out in this guide. In case of doubts that may arise in regard to their application, directors (managers) are the first source for advice for ethical issues. The image of Carnaúba do Brasil Ltda and its trademarks must be built and preserved daily by all employees and partners as their most important asset. Any individual or collective action or attitude that compromises the reputation and credibility of this image will be considered a serious violation and will result in penalties.

GOAL
This Code of Ethical Conduct aims to provide a clear understanding of the conduct that guides the business and relationships of Carnaúba do Brasil Ltda, through its governance and its collaborators in relation to:

  • Ethical and honest conduct in situations of conflict of interest between personal and professional relationships.
  • Appropriate, accurate and correct information of the documents kept and disclosed internally or in different media.
  • Compliance with the laws, rules and regulations applicable to the business of Carnaúba do Brasil Ltda.
  • Immediate manifestation of any proven violation of the Code of Ethical Conduct.
  • Minimization of subjectivity of interpretation regarding moral and ethical principles.

SCOPE
This Code of Ethics applies to all administrative, technical and senior structure, as well as all suppliers and service providers of Carnaúba do Brasil ltda.

COMMITMENT OF LEADERSHIP

  • Treat all employees, partners and third parties with respect, repudiating discrimination of any nature.
  • Preserve the health and physical integrity of employees and partners and ensure quality of life in the workplace.
  • Foster a healthy work environment, encouraging civility and courtesy in relationships with colleagues, superiors, clients and third parties.
  • Not take advantage of a position to request or accept personal favors or services from subordinates or third parties.
  • Uphold truth, loyalty, probity and responsibility as foundations of personal dignity.
  • Exercise, with authority and efficiency, the roles assigned as a result of the position.
  • Respect the dignity of the human being.
  • Comply and enforce the laws, regulations, instructions and orders of the authorities to which you are subordinate.
  • Be fair and impartial in the judgment of actions and the analysis of the merits of the subordinates.
  • Treat subordinates with dignity, that is, civility, justice and courtesy, without compromising discipline and hierarchy.
  • Lead by personal example, with kindness and respect for your colleagues, at all levels, as an incentive for all to adopt correct attitudes.
  • Care for your own moral and intellectual training as well as that of your subordinates, with a view to fulfilling the common mission.
  • Not mistake rigor for bad treatment, nor kindness with nice-guyism.

COMMENTS

The following are meanings for:
  • Loyalty: sincerity, frankness, upholding the truth, loyalty to commitments, that is, not have the intention to deceive superiors, peers or subordinates.
  • Probity: integrity of character, honor, honesty, sense of justice.
  • Nice-guyism: those who manifest generous feelings in an exaggerated way.
  • A violation of the Duties, Values and Ethics of Carnaúba do Brasil Ltda usually constitute a disciplinary violation and is an impediment to some promotions and other concessions.

COMMITMENT OF EMPLOYEES

  • Not consume alcoholic beverages and illegal drugs, as well as be under the effect of such during the workday and/or at the workplace.
  • Not remove, use and/or take assets and resources belonging to Carnaúba do Brasil Ltda for your own benefit, except for the performance of professional activities, provided such is duly authorized by the superior.
  • Use the assets and property of Carnaúba do Brasil Ltda with care, ensuring their proper conservation.
  • Not make use of a position, job or role to obtain any courtesy, whether in the form of gifts, presents or any other services offered, such as money in exchange for any favor, etc., and in the case of embarrassment to refuse such, the items must be handed over to the Ethics Committee, using the email etica@carnaubadobrasil.com
  • Preserve the image and reputation of Carnaúba do Brasil Ltda by following the principles of integrity, respect and honesty.
  • Treat any professional relationship with respect, repudiating any kind of discrimination and prejudice.
  • Not request financial resources and/or materials from third parties for any activities without prior permission from the Management.
  • Dedicate oneself fully to the accomplishment of your duties.
  • Encourage camaraderie and develop, and at all times the spirit of cooperation.
  • Be discreet in your attitudes, manners and in your written and spoken language.
  • Refrain from discussing, outside the proper scope, any matters of a confidential nature.
  • Respect intellectual property and recognize the work merits of colleagues, regardless of their hierarchical position.
  • Fulfill your duties as a citizen.
  • Proceed in a transparent manner in all situations.
  • Comply with the internal rules of Carnaúba do Brasil Ltda and the rules of politeness.
  • Practice discipline and respect for hierarchy.

COMMENTS

The following are meanings for:

  • Camaraderie: solidarity, understanding between people who have common interests
  • Transparent: untarnished, immaculate, pure, free of corruption: untarnished reputation
A violation of the Duties, Values and Ethics of Carnaúba do Brasil Ltda usually constitute a disciplinary violation and is an impediment to some promotions and other concessions.

RELATIONSHIP WITH CLIENTS

The clients are the reason and the inspiration for Carnaúba do Brasil Ltda to always offer better and incomparable services, with the aim of constantly increasing credibility with a commitment to:

  • Offering products and services with honesty and respect and in strict compliance with the laws and regulations established by the Consumer Protection Code.
  • Keeping information received confined to those involved in the performance of the service.
  • Maintaining absolute confidentiality of the information received by clients, disclosing such only with the client's formal consent.
  • Complying with the commercial policies of Carnaúba do Brasil Ltda and all conditions established therein.
  • Being sincere in its relationships, always serving with efficiency and courtesy.
  • Being open to criticism and suggestions in the permanent search for continuous improvement in the quality of our services.
  • Offering quality products and services, with cutting-edge technology, in a service standard that is transparent, efficient, effective, courteous and respectful with the full satisfaction of the client in mind so as to maintain lasting relationships.
  • Remedying possible loss or damage resulting from damage to clients under its responsibility with utmost speed and within feasible deadlines.
  • Analyzing and answering all questions addressed by customers within a period of time that is compatible with their expectations and needs.
  • Analyze 100% of the Carnauba Wax output manufactured within the standards of quality, health and security, before sending the product to the customer.
  • Keep the relevant analysis and reports filed for the period of validity of the product.

RELATIONSHIP WITH SUPPLIERS AND SERVICE PROVIDERS

Carnaúba do Brasil Ltda in its relationship with suppliers, service providers and partners strives for transparency and impartiality, basing its technical and legal decisions on ethical principles to maintain mutual trust, and committing itself to:

  • Selecting and contracting based on duly predefined, objective and legal technical criteria, such as: quality, price, term and capacity of supply, technical ability, without the approval of favors.
  • Entering into contracts with suppliers, service providers or partners who comply with the law.
  • Complying with the quality technical standards and procedures recommended by the Quality Management System of Carnaúba do Brasil Ltda.
  • Giving equal opportunity to all.
  • Seeking transparency and impartiality by basing its technical and legal decisions on ethical principles to maintain mutual trust.
  • Selecting and contracting based on duly predefined objective and legal technical criteria, such as: quality, price, term and capacity of supply, technical ability, without the approval of favors.
  • Entering into contracts with suppliers, service providers or partners who comply with the law.
  • Promote in-house procedures to favor suppliers and service providers, who adopt social and environmental policies.

RELATIONSHIP WITH COMPETITORS

Carnaúba do Brasil Ltda believes fair competition is a constant driver for innovation and the pursuit of excellence, therefore, it binds itself to:

  • Maintaining a relationship with its competitors based on the principles of honesty and respect, adopting explicit and established rules about its competitive procedures.
  • Acting with respect in matters that are related to competitive products or services, avoiding unnecessary and abusive exposure of such and constantly encouraging innovation and the pursuit of excellence.

RELATIONSHIP WITH THE COMMUNITY AND THE ENVIRONMENT

Carnaúba do Brasil Ltda encourages the dissemination of the sustainable development concept and, as its main supporter, it knows it must be economically viable, socially fair and environmentally correct, binding itself to:

  • Allowing and supporting the volunteer initiatives of its employees, with the purpose of creating awareness and enhancing their abilities and skills in an integrated and systemic way, to the benefit of the communities in which they operate.
  • Encouraging the dissemination of the sustainable development concept and, as its main supporter, it knows it must be economically viable, socially fair and environmentally correct.
  • Practicing environmental awareness with a view to the sustainable use of natural resources in order to preserve the nature located around the place where the activities are performed, thus avoiding possible damage to the local community.
  • Keeping collaborators aware of the maintenance of continuous improvements to the environment.
  • Monitoring the amount of energy being used on the premises of Carnaúba do Brasil Ltda.
  • Using clean energy (solar and cashew tree waste) on the premises of Carnaúba do Brasil Ltda.
  • Recycling the water used in the lab and in the production line for landscaping and/or steam generation.
  • Treating 100% of the disposable effluents generated in the production line before dumping them into the environment.
  • Controlling combustion gas emissions arising from the boiler into the atmosphere.
  • Encouraging a culture of environmental preservation.

FIGHT HARASSMENT AND SLAVE-LIKE LABOR CONDITIONS

Child Labor And Forced Labor
Carnaúba do Brasil Ltda does not use child labor or labor under slave-like conditions, which includes not only forced labor but an exhausting workload, degrading conditions or debt-enforced servitude. In addition, the company binds itself to not accepting nor employing any suppliers or service providers that are confirmedly or under suspicion of doing so. In the event of any situation of bad working conditions, either internally or by any supplier and/or service provider, the fact must be reported to the complaint channel.

Prejudice
Collaborators, suppliers or service providers will not be discriminated against in the workplace for race, religion, age, gender, political conviction, nationality, marital status, sexual orientation, physical conditions, among others. Thus, as in internal opportunities, candidates will be assessed solely and exclusively for their technical skills and their suitability for the job. No discriminatory acts against any professional or job candidate will, therefore, be tolerated.

Harassment And Abuse Of Power
Carnaúba do Brasil will not accept nor allow any type of harassment, sexual or moral, or any other situations that may be construed as intimidations or threats to any relationship between collaborators, suppliers and service providers, regardless of their hierarchical level. Harassment is a practice that is categorically undesired and inadmissible because it has no place in a workplace that is respectable, pleasant, dignified and humane and will not be tolerated. Should any intimidation or aggressive situation arise, the fact must be reported to the complaint channels.

Political Orientation
Carnaúba do Brasil respects the individual right of collaborators to get involved in civic matters and take part in political activities. However, the participation must occur during their free time and at their own cost. In this event, the collaborator, supplier and service provider must make it clear that the manifestations are his/her own and are not linked to the company in any way. Therefore, all employees, service suppliers or providers are forbidden from making any contribution on behalf of Carnaúba do Brasil in value, goods or services for campaigns or political causes. The company’s resources, area and image cannot be used to serve personal political or party interests.

Recursos, espaço e imagem da empresa não estão autorizados a serem utilizados para atender interesses políticos pessoais ou partidários.

HUMAN RIGHTS

Carnaúba do Brasil Ltda has officially applied to join the United Nations Global Compact, which is the company's formal and public endorsement of foreign principles related to social and environmental responsibility policies. It is worth noting that Human Rights are the basic rights and freedoms of all human beings. Its concept is also linked to the idea of freedom of thought, of speech, and equality before the law. The United Nations has proclaimed the Universal Declaration of Human Rights, which is respected worldwide. Carnaúba do Brasil Ltda is in favor of equal opportunities in all work-related activities and in all other aspects that favor professionals, regardless of race, color, religion, creed, ethnic affiliation, nationality, sex, age or political affiliation. Suppliers and service providers of Carnaúba do Brasil Ltda must being themselves to the principles below, as well as the company itself: In light of the 1948 Universal Declaration of Human Rights, they are based on three principles:

  • Principle of sanctity of life: sacrifices cannot be imposed on an individual to benefit another person.
  • Principle of autonomy: every person is free to carry out any conduct, provided that their acts are not prejudicial to third parties..
  • Principle of human dignity: the true nucleus of all other fundamental citizens’ rights, through which “all people must be treated and judged in accordance with their acts and not in relation to their other properties, which may not be attainable by them.“

INFORMATION SECURITY

Information security is the concept of protection of data, details and the like to ensure such are accessible only to those entitled to them or to the people they have appointed. Like any corporation, Carnaúba do Brasil has a lot of data of its own and of third parties within the organization. Therefore, special care needs to be taken with this information. Carnaúba do Brasil binds itself to:

  • Fully integrate the pillars of information security: confidentiality, integrity and availability.
  • Follow data protection principles (customers, suppliers, service providers and employees) established by Brazilian law (Law no. 13.709/18), as well as those from other countries and regions where Carnaúba do Brasil sells its products.
  • Participate in training related to Information Security and the Data Protection Law, and in case of doubts, seek the Ethics Committee in the company in the channels informed in this Code.
  • Refrain from photocopying documents or confidential data of Carnaúba do Brasil and that of any of its employees, service providers, suppliers and customers.

ANTI-CORRUPTION

Corruption is a behavior that seriously harms the economy, sustainable development and the efficiency of the national and international market, distorting competition to the detriment of consumers and businesses. This is why corruption is illegal in virtually every country in the world. Corruption is: “the act of directly or indirectly soliciting, offering, giving or accepting an illegal commission or any other unfair advantage or the promise of such an unfair advantage, which affects the normal performance of a role or the required conduct of the recipient of the illegal commission or unfair advantage or the promise of such an unfair advantage.“ Carnaúba do Brasil Ltda does not authorize any person or organization acting on its behalf, whether as a representative, agent, trustee or any other connection, to use any immoral or unethical means in its relations with public and private agents. The company also undertakes to comply with laws and regulations in all spheres in countries where it operates. An act of corruption exists when:

  • a person offering the advantage acts through a third party (an intermediary, a commercial agent, a subcontractor, a supplier, a partner etc.).
  • the person receiving the benefit is not the ultimate beneficiary (the beneficiary may be a relative, a third party etc.).
  • the fraudulent action and the granting of the undue advantage do not occur simultaneously (the unfair advantage may be anticipated or agreed upon later).
  • the unfair advantage takes forms other than the delivery of money (it may be material objects, services to be rendered, a benefit in terms of reputation, etc.).
  • the beneficiary is a public or private-sector employee.

Brazilian Anti-Corruption Laws

  • Law 12.846 of 08/01/2013 - administrative and civil liability of legal entities who perpetrate acts against the public administration.
  • Decree Law 2.848 of 12/07/1940 - Brazilian Criminal Code - Articles 312, 316, 317 and 333 - Crimes of embezzlement, concussion, active and passive corruption, in addition to crimes against the Public Administration.
  • Law 10.406/2002 Civil Code

Conflict Of Interest

Any situation that causes conflict among the interests of Carnaúba do Brasil and the particular interest of its employees, service providers, suppliers and customers, and which interferes in the development of commercial and business activities, will be subject to sanctions.

Sanctions

In case of misconduct due to fraud or corruption, those involved, whether employee, partner, supplier, service provider or customer, will be subject to the application of a written warning, suspension, contract termination, and depending on the seriousness of the case, criminal proceedings.

Communication

Whenever there is an act or fact that may be construed as misconduct, every employee, supplier, service provider and customer is free and expected to report such fact immediately to the complaint channels, so that it may be duly forwarded and analyzed.

ACCUSATIONS

Accusations concerning the above issues may be made in three ways:

  • At the Carnaúba do Brasil website, www.carnaubadobrasil.com, ANONYMOUSLY, where the whistleblower will fill out a digital form without having to identify him/herself to ensure that his/her data and information is kept completely confidential.
  • By calling the number +55 85 3264-7111, an independent channel, which is distant from the daily activities of the company.
  • Or by e-mail etica@carnaubadobrasil.com, when an answer is required.
  • Carnaúba do Brasil ensures hereby to maintain the confidentiality and not retaliate against any whistleblower who chooses to identify themselves.
Itarema, Ceará, Brasil – january 2021

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