Code of Ethics and Business Conduct

1 – Objective

The Code of Ethics is a document that establishes principles, norms, and appropriate procedures with rules of conduct to guide the actions of all employees of the Company.

The purpose of the Code of Ethics, among others, is to strengthen the commitment to appropriate behavior among employees and company managers towards both internal and external publics.

The purpose of this Code of Ethics and Business Conduct is to serve as a practical guide for personal, professional, and compliance ethical conduct to be observed by all employees of 2R Datatel Teleinformatics Ltd., in their daily relations, making clear the ethical principles of the company and affirming its core values, ensuring also compliance with Brazilian laws and compliance rules.

The Code aligns with the mission, values, and vision that define the identity of 2R Datatel and together reinforce its status as a company committed to digital transformation, innovation, and excellence in all services, always guided by ethics in the conduct of relations with both internal and external publics.

2 – Introduction

2R Datatel has always conducted its business by observing principles of honesty, transparency, correctness, and integrity and formalized them in this Code of Ethics and Business Conduct.

The provisions contained in the Code of Ethics and Business Conduct apply to all employees under any type of contract or assignment and for any reason, as well as to senior management, and any temporary or permanent employees.

The provisions of the Code of Ethics and Business Conduct have deep reference to the principles and duties of correctness, diligence, and good faith, which all recipients must comply with in the exercise of their activity.

All employees and members of senior management are therefore required to know the content of this document and apply it correctly, without delaying, limiting, or preventing the verification of its application and implementation.

Employees, in addition to having to adjust their behavior to the Code of Ethics, have the specific duty to report to the Managers any violations of the Code of Ethics by employees and members of senior management, for the prevention of corruption.

This Code of Ethics, due to its relevance, is also made available through its publication on the company’s website and sent by email or another equivalent tool to all employees.

3 – Scope and Recipients

This Code of Ethics and Business Conduct is applicable to the following recipients, who must faithfully comply with it:

(i) Employees of the company, from all departments

(ii) Senior Management

(iii) Business Partners (consultants, commercial agents, and affiliates)

(iv) Suppliers

All must use the provisions of this Code as an ethical and conduct reference to be observed in their relationship with 2R Datatel and in activities in any location where 2R Datatel operates.

4 – Fundamental Ethical Principles

The dissemination and absorption of this Code of Ethics and Business Conduct depend on the commitment and collaboration of all 2R Datatel employees, who must follow the ethical standards for which they are encouraged and held accountable, observing the following principles:

Respect the dignity of people, the integrity and privacy of customers, directors, colleagues, service providers, suppliers, competitors, and public entities, without any prejudice related to gender, color, race, religion, sexual orientation, age, or any other characteristic or choice.

Comply with internal regulations, as well as the general principles of integrity, fairness, good faith, objectivity, transparency, and reasonableness.

Since the pursuit of the interests of ownership, the company, or individuals can never justify conduct contrary to principles of uprightness and honesty, activities are developed in full respect of current laws, professional ethics, and regulations.

The Company requires compliance with current legislation on the prevention and combating of corruption from all employees acting on its behalf.

Absolutely prohibits conduct that may be construed as corruption or an attempt at corruption or induction to corruption.

In relations with internal and external publics, it must be considered not only what is legal and illegal, what is fair and unfair, what is convenient and inconvenient, what is opportune and inopportune, but mainly what is honest and what is dishonest.

It is imperative that ethics be the foundation of conduct, given that not all laws, norms, and policies exhaust ethical reflections and, thus, everyone must:

Avoid and repudiate any form of coercion or harassment to people in the workplace or outside.
Act with respect to human rights and the environment.
Preserve the assets and image of 2R Datatel.
Repudiate any fraudulent or corrupt practices (bribery, influence peddling, money laundering, concealment of assets, undue advantages, and others) or of illicit or criminal acts of any kind.
Act responsibly, to gain and maintain the trust of all.
Combat the use of illegal drugs.
Cooperate to achieve the objectives and missions of 2R Datatel.
Condemn illicit conduct such as forgery of documents, tax evasion, tax fraud, among others.
Use information received from third parties exclusively in the exercise of the business objectives of 2R Datatel.
Maintain confidentiality on the operations and strategies of the company and its clients, suppliers, and partners.
Refuse advantages that aim to influence decisions in professional performance.

Considering that a code of conduct and professional ethics can hardly cover all situations encountered in practice, we rely on everyone’s good judgment, according to the judgment in their inner forum, encouraging everyone to consult, in case of doubts, the managers of their respective departments.

5 – Mission, Vision, Rules, and General Principles

The mission of 2R Datatel is to provide innovative and secure information technology and cybersecurity solutions for our clients, protecting their digital assets, promoting operational efficiency, and driving their success. We are committed to offering high-quality services based on solid ethical and technical principles, to protect and strengthen the digital infrastructure of our clients.

The Vision of 2R Datatel is to work with a confident, resilient, and creative team transforming the market with effective solutions, harmonizing advanced technology, security, and professional ethics, providing well-being to all its clients and employees, and increasingly guaranteeing credibility, solidity, and excellence in the market.

2R Datatel, active in the professional information technology services market, seeks to continuously meet the highest applicable regulatory requirements, maintaining effectiveness and quality.

Develop services and products of maximum quality, that meet market needs, based on the strong commitment to do the best, but with full adherence to values, current laws, and internal norms. Therefore, it is imperative:

To be competitive and active to achieve its growth targets, guiding its actions by moral and ethical principles that are shared by all company employees.

Employees and senior management must maintain the reputation of being an upright and trustworthy entity, aware of their social and corporate responsibility, always acting in an honest, fair, legal, and transparent manner.

The actions of 2R Datatel must always be guided by honesty, integrity, transparency, and loyalty in human relations, with respect and appreciation of the human being, in their privacy and dignity. Repudiating any attitude guided by prejudices related to origin, race, religion, social class, education, gender, color, age, physical disability, and any other forms of discrimination.

2R Datatel repudiates the use of slave labor or analogous conditions, as well as the use of child labor and the exploitation of labor without fair remuneration, both within the company and in relation to its suppliers, customers, and other business partners.

All employees must nurture a common, intrinsic feeling of safeguarding the values and image of the company, and always maintain a posture compatible with such an image, whether in public or in private and personal environments, healthily maintaining their moral values and aiming for success and the best results for the company.

2R Datatel values its team and will always strive to provide opportunities for horizontal and vertical growth within the organization to reward the dedication and successes of each professional, also adopting talent retention programs, which also consider the joint result of the team to stimulate teamwork for the development of the business.

6 – Code of Conduct

Employees and members of senior management must always act in the best interests of 2R Datatel, always preserving the secrecy and confidentiality of the company’s business and operations and those of its clients and suppliers.

The attitudes and behaviors of employees must reflect their personal and professional integrity, and must not put at risk their own safety, as well as those of 2R Datatel.

Employees must evaluate beforehand and meticulously situations that may potentially configure a conflict between their personal interests and those of the company or conduct that may not be acceptable from an ethical point of view, even if they do not cause financial or image damages to the company, always acting diligently, responsibly, and loyally.

7 – Examples of Reprehensible Conduct (non-exhaustive list)

Using one’s position, function, or information about business and matters of the company and/or its clients, which one has access to, to influence decisions that favor one’s own interests or those of third parties.

Selling products or services of 2R Datatel through one’s own company or that of another, or otherwise through some business relationship in which one profits personally and unduly burdens the supply chain of 2R Datatel.

Accepting or offering, directly or indirectly, favors or other personal benefits resulting from a relationship with 2R Datatel that may influence decisions, facilitate business, or benefit third parties.

Using for personal purposes, or passing on to third parties, technologies, methodologies, knowledge, or information owned by the company, or developed or obtained by it.

Speaking on behalf of the company without having official authorization from the administration to do so.

Use of unlicensed software.

8 – Relations with Public Administration or Public Officials

Public Administration means, in addition to any public body, any independent administrative agency, physical or legal person, acting as a public official or responsible for a public service.

2R Datatel cannot be represented by third parties in relations with public administration if there is a conflict of interest or if there are serious reasons for convenience. It is prohibited, directly, indirectly, or through a third party, to promise or offer money, gratuities, gifts, remunerations, or other benefits in any form or promise any object, service, performance, or favor to representatives of public administration (managers, public administration officials), to their relatives or related persons or cohabitants or to public service managers, to induce the practice of an act contrary to their official duties.

All employees must strictly comply with anti-corruption and anti-bribery laws governing relations with national and international public agents from all spheres of power, including public service concessionaires, as well as members of political parties and candidates for political offices.

2R Datatel condemns the offer of any monetary or non-monetary resource, aimed at the fulfillment of legal obligations of public agents or the hastening of routines, as any act may characterize facilitation or bribery and, therefore, constitute a bribe or corruption.

9 – Relations with Commercial Interlocutors, Private Parties, and Suppliers

Employees must not assume any behavior that may harm the corporate image and/or reputation; therefore, the following criteria and conducts must be respected:

Ensure, in relations, full equality of treatment under equal conditions, abstaining from arbitrariness or that imply discrimination based on sexual orientation, nationality, ethnic origin, genetic characteristics, language, religion or creed, personal or political beliefs, belonging to a minority, disability, social or health conditions, age, or other diverse factors.

In the conclusion of contracts as well as in their execution phase, 2R Datatel does not resort to the mediation of third parties, nor correspond or promise any benefit through intermediation, to facilitate the conclusion or execution of the contract, ensuring that any hiring, regardless of the value, does not have the possibilities of being used for illicit practices.

Suppliers must be treated with respect and loyalty, but with exemption from favoritism, their information must be treated with caution and confidentiality.

The choice and hiring of suppliers must be based on a combination of ethical criteria and the company’s needs, and must be conducted through predetermined processes through competition, which guarantee the best cost/benefit ratio, both technically and in terms of conditions and economic results.

Safeguard the security of data and confidential information, in physical or digital form, adopting the necessary precautions to keep them confidential.

Abhor deceptive, unfair, and fraudulent commercial practices.

10 – Relations with Clients

Our relations with our clients are long-term and professional.

Conduct criteria must treat clients in a fair and respectful manner, always acting in a transparent and ethical manner.

The technological and business needs of our clients are foremost in our minds; therefore, we will provide our clients with reliable and professional information about our services and our capabilities.

The company’s employees are obliged to maintain the confidentiality of all information disclosed to them in the course of their work with a client. In this context, the collaborator must not share information to which he was exposed during his work, including to other employees and/or third parties.

Must safeguard the information used and the results obtained in the projects, studies, and solutions to third parties, protecting them from undue leaks and treating them with the standards of confidentiality and the norms in force in the country.

11 – Confidentiality

Any information that, if disclosed, may negatively interfere with the interests of the company, as well as the information and personal data of its clients, suppliers, employees, administrators, shareholders, and business partners, infringing pertinent Legislations such as LGPD, must be kept confidential.

In compliance with the law, 2R Datatel ensures the confidentiality of the information in its possession and relating to all interlocutors (employees, clients, suppliers, etc.).

Any information may be provided to third parties only in full compliance with the legislation in force or based on precise and specific agreements between the parties.

All who operate on behalf of and for the account of the Organization are prohibited from using confidential information for purposes unrelated to the exercise of the professional functions assigned.

12 – Gifts, Giveaways, and Courtesies

2R Datatel does not request, for itself or for others, gifts or other benefits.

It is strictly prohibited for a company employee to offer or receive gifts, favors, loans, services, payments, or special treatments of any kind, from individuals or organizations that provide services or seek to provide, that do or seek to do business with 2R Datatel, whether as a supplier, client, contractor, investor, partner, government and public entities, or of any other nature.

13 – Mode of Application of the Code of Ethics and Business Conduct

To increase its visibility, the Code of Ethics is published, with due prominence, on the website of 2R Datatel.

This Code and any future updates are defined and approved by senior management and departmental managers.

2R Datatel commits to disseminating the principles of the Code to all interlocutors with whom there is or is about to formalize a commercial relationship.

The Company commits to enforcing the rules of this Code through departmental managers.

They must monitor the application of the Code by the recipients, including through the collection of any reports, even anonymous ones, which can be sent through the Reporting Channel.

All those who report in good faith any infractions to this Code are guaranteed utmost confidentiality.

This Code is valid for 12 months, counted from the date of approval by Senior Management.

At least once a year it is reviewed, complemented, and updated, if necessary.

In the event of the need to update this Code, departmental managers may do so within a reasonable time and submit it for approval by senior management.

2R Datatel, in the event of a confirmed violation of the Code of Ethics and Business Conduct, adopts the most appropriate sanctioning measures to protect social interests in observance of current regulations and collective labor agreements. The applicable sanctions include:

Disciplinary sanctions.
Contract termination.
The application of any pre-established penalty clauses.
The claim for compensation for damage, including to the image.

14 – Reporting Channel

A reporting channel is available so that reports can be made about improper or inappropriate behavior by its collaborators that contrast with the provisions of this Code of Ethics and Business Conduct.

Identification of the whistleblower is not necessary.

Reports can be made through email messages (email) to canaldedenuncias@2rdatatel.com.br.

The Company commits to enforcing the rules of this Code through the Corruption Prevention Committee, formed by departmental managers and senior management.

The Committee monitors the application of this code by the recipients, including through the collection of any reports, even anonymous ones.

All those who report in good faith any infractions to this Code are guaranteed utmost confidentiality.