Code of Conduct
CODE OF CONDUCT
INTRODUCTION
The Asperbras group, of which Greenplac is a part, has always been committed to quality, dedication, and responsibility since its foundation, and is proud to build its trajectory based on high ethical standards of integrity and respect for all. To maintain this performance, it is essential that the conduct of all Employees is guided by ethics, integrity, and transparency, and in compliance with current norms and laws.
In this context, Greenplac presents its Code of Conduct and Policies that will govern its practices and relationships, aiming to provide guidance on applicable guidelines and rules.
The Code of Conduct is the foundation of Greenplac's corporate values and defines the ethical and behavioral standards expected of all Employees, regardless of their position or function. Integrity, transparency, and responsibility are guiding principles for Greenplac's daily operations, and each Employee must incorporate these values into their daily work.
Greenplac invites all Employees to carefully review the Code of Conduct and Policies, familiarizing themselves with the established principles and guidelines. Understanding and applying these documents are fundamental to strengthening the company's ethical culture and reputation.
Sincerely,
Board of Directors
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SUMMARY
1. General Principles..................................................................................................................3
2. To whom this code applies................................................................................................3
3. Expected behavior and conduct of Employees......................................................................3
4. Relationship with customers...............................................................................................4
5. Relationship with partners and suppliers.............................................................................4
6. Harassment, discrimination, and inclusion.........................................................................5
7. Health and safety at work.....................................................................................................6
8. Environmental policy..........................................................................................................6
9. Exercise of political rights...............................................................................................6
10. Conflict of interest.........................................................................................................7
11. Prevention of corruption.......................................................................................................7
12. Accounting books, records, and internal controls...................................................................8
13. Privacy and data protection........................................................................................8
14. Investigations and disciplinary sanctions......................................................................8
15. Changes..........................................................................................................................9
16. Omitted cases....................................................................................................................9
17. Policy management...............................................................................................................9
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1. GENERAL PRINCIPLES
1.1. This Code of Conduct aims to establish the principles, concepts, and values that guide Greenplac's ethical standard of conduct in its internal operations, with the market, and its relationships with various stakeholders.
1.2. Its issuance represents the company's commitment to the values that characterize its culture, based on integrity, trust, loyalty, high ethical principles, and corporate moral values, in compliance with all applicable norms, including those related to the prevention of harmful acts against public administration, whether national or foreign, as established in Law nº 12.846/2013.
1.3. It also establishes the strengthening of an ethical culture, raising the level of trust, respect, and solidarity in all its internal and external relationships.
1.4. The constant pursuit of the development of all involved will be guided by the general principles presented in this Code, as well as preventing and managing conflicts of interest in preserving the company's image and reputation.
1.5. Like any Code, in addition to the concepts, it also includes sanctions for non-compliance with the defined principles.
1.6. Adherence to this Code is mandatory and occurs at the time of establishing the contractual relationship with Greenplac.
1.7. The dissemination, propagation, updating, and verification of its compliance will be the responsibility of the Compliance Department.
2. TO WHOM THIS CODE APPLIES
2.1. This Code of Conduct is valid and applicable to all team members, including partners, shareholders, directors, administrators, employees, outsourced personnel, interns, apprentices, messengers, correspondents, suppliers, consultants, as well as any individual who acts directly or indirectly for or on behalf of the company. Collectively, these parties will be referred to as Employees hereafter.
3. EXPECTED BEHAVIOR AND CONDUCT OF EMPLOYEES
3.1. When performing their duties, it is imperative that Employees follow ethical principles, especially regarding integrity, morality, clarity of positioning, and decorum. The objective is to foster respect and trust among colleagues, customers, and society in general.
3.2. In this sense, Greenplac Employees must:
3.2.1. Know and follow this Code of Conduct;
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3.2.2. Read, understand, and put into practice all the company's guidance materials, as well as follow current laws, with the support of their manager and the Compliance and Legal Departments if they have questions;
3.2.3. Complete mandatory training;
3.2.4. Maintain integrity inside and outside Greenplac's facilities, while working, acting on behalf of the company, and when their actions can be associated with the company's names and brands, to avoid damage to its reputation;
3.2.5. Be aware that deviations from the company's policies and its provisions, whether by action, omission, or complacency, can harm society, violate laws, and damage Greenplac's image and reputation;
3.2.6. Report any doubts or situations that may represent or be interpreted as contrary to legislation and/or the Code of Conduct.
3.3. Any uncertainty about the legality and compliance of conduct or any ethical concern must be communicated to the company's Compliance Department or the Whistleblower Channel.
4. RELATIONSHIP WITH CUSTOMERS
4.1. In relation to customers, one must:
4.1.1. Ensure product quality;
4.1.2. Act with courtesy and efficiency, offering accurate and truthful information, so that they choose the best product and/or service option according to their needs;
4.1.3. Serve according to the best commercial practices and without discrimination;
4.1.4. Act with clarity and conformity with the production process, according to technical specifications, commercial conditions, delivery, and quality;
4.1.5. Respect the customer's freedom of choice.
4.2. Any and all contact with the customer, whether via email, in person, or by phone, must be marked by courtesy and effectiveness, with clear, objective, and quick information, even if it is negative or merely for confirmation of receipt.
5. RELATIONSHIP WITH PARTNERS AND SUPPLIERS
5.1. Greenplac's contracting of suppliers and establishment of partnerships must be guided by the following criteria:
5.1.1. Suppliers with a questionable reputation and/or those not in agreement with ethical principles compatible with Greenplac's stance and/or the market in which it operates shall not be contracted, nor shall partnerships be established with them;
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5.1.2. The contracting of suppliers and the establishment of partnerships must always be based on technical and professional criteria;
5.2.3. The contracting of suppliers and the establishment of partnerships with third parties who have any degree of kinship, as well as a close or intimate relationship with Greenplac employees, will not be permitted without prior knowledge of such relationship and approval by the partners;
5.1.4. Whenever possible and necessary, the contracting of suppliers and the establishment of partnerships must respect the principles of free competition, which includes, whenever possible, a price quotation procedure and quality assessment, ensuring a cost-benefit ratio.
5.2. All relationships linked to service providers or suppliers should preferably be subject to written contracts, leaving no room for ambiguity or omission.
6. HARASSMENT, DISCRIMINATION, AND INCLUSION
6.1. Diversity, equity, and inclusion generate benefits for the company, employees, and society. Greenplac seeks to provide equal opportunities without prejudice or discrimination in the treatment of employees, including their hiring, promotion, remuneration, and training.
6.2. Greenplac does not tolerate discrimination, including that based on gender identity and sexual orientation, religion, race, culture, nationality, social class, age, physical or intellectual characteristics, or disabilities of any kind.
6.3. It is not permitted to use or abuse one's functions to solicit favors or personal services, nor is it permitted for the abuse of power or authority by any Employee to result in actions conflicting with existing laws and regulations.
6.4. Harassment and discrimination are not tolerated at Greenplac. Such occurrences can be of various types (e.g., verbal, physical, visual, psychological, or sexual) and can take many forms, such as intimidation, humiliation, bullying, catcalling, racial insults, sharing offensive material, offensive jokes, comments or requests, retaliation, threats.
6.5. Greenplac recognizes the human rights of all people, as described in the United Nations Universal Declaration of Human Rights and the United Nations Guiding Principles on Business and Human Rights.
6.6. Greenplac also supports all internationally recognized human rights, including, without limitation: the right to dignity and privacy; the right to life and liberty; freedom of opinion and expression; freedom of association; the right to work and education; freedom from slavery, forced labor, and child labor.
6.7. As an Employee, you are responsible for maintaining a respectful work environment where everyone feels welcome and free from harassment, discrimination, or other improper conduct.
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7. HEALTH AND SAFETY AT WORK
7.1. Greenplac constantly invests in equipment, resources, standard development, and training, promoting the necessary efforts to preserve the health and safety of everyone. Employees must demonstrate personal commitment to safety, complying with all laws, policies, practices, and procedures related to the topic.
7.2. If you become aware of any health or safety incident, you must immediately notify your manager and the Occupational Health and Safety Department.
8. ENVIRONMENTAL POLICY
8.1. Greenplac recognizes the importance of environmental preservation and is committed to integrating sustainable practices into all its operations, such as:
8.1.1. Constantly seeking ways to reduce, reuse, and recycle materials to minimize environmental impact;
8.1.2. Implementing measures to optimize energy consumption, promoting efficiency and the transition to renewable sources whenever possible;
8.1.3. Complying with all applicable environmental laws and regulations, maintaining practices that exceed minimum required standards;
8.1.4. Seeking to educate and raise awareness among employees about the importance of environmental preservation, encouraging responsible actions inside and outside the workplace.
8.2. By adopting this policy, Greenplac aims not only to meet regulatory requirements but also to contribute to a sustainable and ecologically balanced future.
9. EXERCISE OF POLITICAL RIGHTS
9.1. Greenplac does not adopt any political party position and cannot be linked to any political party activities. Likewise, Employees are not authorized to engage in partisan activities or solicit votes, directly or indirectly, on behalf of or using Greenplac's resources or facilities.
9.2. Employees may participate, in their private lives, in the political process, and must respect the choices and personal exercise of citizenship of others, including freedom of thought and individual choice of political participation, party affiliation, and candidacy for public or political office.
9.3. Employees who choose to run for political or public office, or who wish to express themselves politically and publicly outside Greenplac, should not take advantage of their position or use any Greenplac resources or means to do so. Such activities must be clearly dissociated from Greenplac and their working hours for the company.
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10. CONFLICT OF INTEREST
10.1. A conflict of interest can occur when personal objectives interfere with an Employee's evaluation and objectivity regarding the development of work with Greenplac.
10.2. Examples of circumstances where there is a conflict of interest:
10.2.1. The existence of a direct or indirect financial advantage for the employee;
10.2.2. A relationship with a competitor, supplier, customer, partner, or consultant that influences the Employee's professional work;
10.2.3. A situation involving a family member or friend of employees that compromises their professional work for and on behalf of Greenplac;
10.2.4. Requesting or accepting gifts or any undue advantage from a supplier, customer, or others who are doing business with Greenplac or seeking to do so;
10.2.5. Misuse of Greenplac's assets (including tangible assets, confidential information, non-public information, or business opportunities).
10.3. No decision or action, whether taken within or outside business relations with Greenplac, shall conflict with responsibilities to the company, and it is prohibited to misuse company resources or the prerogatives of one's position.
10.4. Employees should always consider how their decisions will be interpreted by others, inside or outside the company.
10.5. Any conflict of interest, whether personal or known, must be reported to the company's Compliance Department or the Whistleblower Channel.
11. PREVENTION OF CORRUPTION
11.1. Greenplac does not tolerate and prohibits its Employees or third parties from acting in its interest or benefit to engage in any act of corruption or bribery with public officials or business partners.
11.2. In view of this, it urges all its Employees to always act in compliance with the Public Officials Relationship and Anti-Corruption Policy, an integral part of this Code of Conduct.
11.3. In it, they will find the guidelines and rules applicable to the following matters: relationship with public officials; corruption; travel, hospitality, and entertainment; gifts and presents; conflict of interest; third parties; donations, sponsorships, and political contributions; sanctions.
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12. ACCOUNTING BOOKS, RECORDS, AND INTERNAL CONTROLS
12.1. Greenplac's accounting records must be transparent, accurate, and faithfully reflect the transactions and movements carried out. Established internal controls must be executed to ensure that accounting and financial records are accurate and comply with regulatory bodies, applicable legislation, accepted accounting principles, and legal market practices.
12.2. Financial data (e.g., books, records, and accounts) must comply with internationally accepted accounting principles and those adopted by Greenplac. All issued data, financial or operational, must correctly reflect the transactions and events that occurred in terms of correct value, timing, and heading.
12.3. Intentional inaccuracy is considered a serious failure and contrary to the Code of Conduct. There is no justification for the adulteration or manipulation of records or false statements of facts. Such conduct may result in the Employee's dismissal, as well as civil and criminal liability.
13. PRIVACY AND DATA PROTECTION
13.1. Greenplac understands that the processing of personal data must be protected based on the fundamental rights of freedom and privacy, as provided in Law No. 13,709/18 – General Personal Data Protection Law (“LGPD”).
13.2. In view of this, it urges all its Employees to always act in compliance with the Privacy and Personal Data Protection Policy, an integral part of this Code of Conduct.
13.3. In it, they will find the guidelines and rules applicable to the following matters: concepts; information subject to the policy; personal data collected; form and purpose of collection; relationship with third parties; data security and confidentiality; data subject rights; cooperation with regulatory authorities; consequence management; responsibilities.
14. INVESTIGATIONS AND DISCIPLINARY SANCTIONS
14.1. Should any action contrary to the Code of Conduct occur, based on evidence and manner of conduct, disciplinary sanctions proportionate to the severity and gravity of the infringements will be applied, potentially including dismissal for just cause or contract termination, in addition to civil and/or criminal liability, and the application of fines.
14.2. Everyone must adopt the positions determined by this Policy in their daily lives. Adherence to this Policy is not optional, and non-observance of any points defined herein will be subject to appropriate measures.
14.3. Should any deviations from the guidelines of this Policy be observed, they should be reported to the company's Compliance Department or the Whistleblower Channel, with or without identification.
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14.4. The independent Whistleblower Channel, available 24 hours a day, seven days a week, to internal and external public by phone or internet, allows the interested party the option of making a report anonymously.
14.5.
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