Code of Conduct

Code of Conduct

Engevale Engenharia S.A.

I - What is Engevale Engenharia's Code of Conduct?
The Code of Conduct of Engevale Engenharia S.A. is a guide that directs the attitudes of employees towards various stakeholders. Its purpose is to establish clear ethical guidelines, promoting responsible behavior aligned with the company's values. The code encompasses a diverse audience, aiming to ensure integrity and reputation, strengthen relationships, and contribute to a healthy business environment. Additionally, it emphasizes the importance of social and environmental responsibility, reinforcing the company's commitment to sustainability and excellence.

II - The Code of Conduct of Engevale Engenharia S.A. was prepared with the following purposes:
1. define principles of behavior and ethics to be observed and followed by all members of the company's staff;
2. serve as a reference for all company collaborators, guiding them to behave in accordance with the established values;
3. Strengthen the image and reputation of the company and its professionals, contributing to its development;
4. define basic principles for the conduct of the company's business;
5. achieve, as a result, appropriate behaviors that are in perfect harmony with the rules described in this Code, without exceptions. In this way, it is understood that it is possible to ensure the integrity and well-being of individuals who constitute and, in some way, benefit from its workforce.

III - To whom does this Code of Conduct apply?
This Code of Conduct applies unrestrictedly to all Engevale Engenharia employees, including managers and employees of the administrative and operational sectors.

IV - Company Vision, Mission and Values ​​
Our Vision: To be among the 05 largest companies in the area of ​​civil construction in the Region by the year 2020, focusing on the pillars of quality, safety, customer satisfaction and operational efficiency.

Our Mission: We are among the 05 largest companies in the Engineering, Construction and Maintenance sector in the Region until the year 2021, focusing on the pillars of quality, safety, customer satisfaction and operational efficiency.

Our Values:
1. Priority in safety and quality of life at work; 2. permanent pursuit of growth and business excellence; 3. meeting the needs of each of our customers; 4. respect and commitment in relations with our suppliers and employees; 5. acting with social responsibility and respect for the environment.

V - Basic Conduct
We know that the way we perform our tasks, honor our commitments, and behave reveals the value we place on others and ourselves, as our habits and attitudes both positively influence the trust we receive and generate discredit, giving rise to personal and professional dissatisfaction. . Hence the importance of continually improving the quality of our work and cultivating motivating environments that encourage cooperation.

VI - Personal Conduct
1. Always adhere to established standards and policies, processes and procedures. Just do what are you sure you can do it; when in doubt, seek guidance from your immediate manager or sector manager;
2. Cultivate cordiality in relationships and seek to resolve disagreements or misunderstandings with care, respect and acceptance.
3. practice dialogue rather than imposing a point of view by listening carefully and respecting the opinions of others, even if you disagree with them;
4. help colleagues do a good job and guide those who seek it patiently and with interest;
5. never mislead anyone or intentionally harm them;
6. give due credit to the ideas and achievements of colleagues and do not present ideas, opinions and personal preferences as if they were from Engevale Engenharia or its managers or employees;
7. Do not use Engevale Engenharia's name, position or influence for personal benefit or for relatives, friends or third parties;
8. Do not discriminate against anyone for their ethnicity, gender or their political, sexual, religious, cultural or disability preferences;
9. do not adopt offensive conduct, whether verbal, physical or gestural;
10. Do not reproduce rumors and slander;
11. If you make a mistake, do not hide the fact, be transparent and truthful and strive to mitigate its consequences and learn from them;
12. participate with punctuality and dedication of the education and training actions offered by Engevale Engenharia;
13. take care of work facilities, resources, equipment and materials and only use them for personal purposes in the event of an emergency that does not endanger the integrity of Engevale Engenharia's assets;
14. Adopt the precepts of conscious consumption: Do not waste water, energy, paper, plastic objects, office supplies, etc., and practice selective collection.
15. avoid financial imbalances as they cause personal and professional damage;
16. present themselves in the working environment in the normal state (without drunkenness, drug use, etc.); the use of illicit drugs is a crime and compromises professional performance, as it seriously harms the lives of its users, disrupts the work environment and may cause risk situations for others;
17. look after personal appearance, dressing appropriately for the function performed, being forbidden the use of necklines, short skirts, bare belly, transparent fabrics and shirts of football teams;
18. do not disclose information from Engevale Engenharia or comment on situations of your daily work in social networks;
19. use their official time in a responsible effort to perform their tasks, performing their duties or tasks efficiently and effectively;
20. Employees who act as managers should not encourage, require or request their subordinates to use official time to perform activities other than those required for the performance of their duties or duties; 21. be responsible for the correct use, as well as the preservation of machinery, equipment, landline and mobile phones, vehicles and other materials used for its activity, and the improper and non-transferable use to third parties by means of loans, leases or barter; br> 22. landlines and cell phones are working tools and their use should be restricted to this purpose, and in the event of a personal emergency, use should be made within the shortest possible time;
23. The use of mobile phones in production and / or service areas is strictly forbidden and should remain unconnected with your personal belongings.

VII - Professional Conduct
1. do your job with zeal, focus on Engevale Engenharia's interests and in compliance with the company and this Code of Conduct;
2. Keep up-to-date on the advancements in your professional area and, where appropriate, obtain the certifications required to fulfill your position.
3. Do not allow Engevale Engenharia's business and operations to be used for illegal or criminal acts, such as corruption, bribery, money laundering, fraud, etc.
4. never advise, disclose information or trade based on rumors or unreliable data;
5. Know and comply with Engevale Engenharia's policies and other standards;
6. In relationships with customers, suppliers and other audiences, look for the appropriate channels to respond to requests or resolve conflicts that are outside their remit.
7. Ask your immediate manager and corporate communications for guidance before attending interviews and programs on conventional or virtual media.
8. do not speak on behalf of Engevale Engenharia without prior authorization;
9. Do not use social networks or software not available from Engevale Engenharia to perform their professional activities.

VIII - Conduct with Employees
1. Engevale Engenharia is committed to ensuring the health and safety of its employees by providing all necessary PPE free of charge, guiding and training everyone to comply with the Rules and Regulations;
2. Engevale Engenharia undertakes to provide the appropriate physical facilities for the performance of its employees' duties and to make the necessary adaptations for the entry of people with special needs;
3. Engevale Engenharia will treat everyone equally, without discrimination of color, gender, origin, ethnicity, social class, age, physical ability or religion, distinguishing only those who, by competence and merit, are entitled to special treatment (awards, tributes, spontaneous salary adjustments, etc.);
4. Engevale Engenharia's management is also committed to being an example of a good relationship, always promoting a climate of tranquility and respect in the relationship with employees.

IX - Conduct with Trade Union Entities
Engevale Engenharia maintains a respectful relationship with unions and does not practice any type of discrimination against unionized employees. In addition, it respects the free association with unions by their employees, as well as recognizing and complying with all Conventions and Collective Bargaining Agreements signed with the category.

X - Conduct with Customers
1. Customer satisfaction is the responsibility of all employees, regardless;
2. The commitment to the satisfaction of our customers must be reflected in the search for solutions that meet their needs, presenting clear, objective information, provided that the contractual conditions are observed and in accordance with the company's principles;
3. Customer relations should be guided by honesty, respect, courteous and efficient service.
4. Every employee who finds an attitude of disinterest, impatience and even disrespect towards Engevale Engenharia's clients should immediately report it to their immediate leader and / or Human Resources.

XI - Conduct with Suppliers, Service Providers and Business Partners
1. The selection and hiring of service providers and / or procurement of materials, supplies, and equipment is based on technical, professional, ethical and legal criteria in the needs of the company and shall be conducted in partnership with the Procurement Department of the Company's headquarters. company, through processes, in order to ensure the best cost-benefit ratio for Engevale Engenharia;
2. Relationships with our suppliers are guided by courtesy and efficiency, and all information requested in an appropriate manner is provided, when necessary and authorized, in accordance with the agreed commitments.
3. Any doubt as to the desirability of complying with any request shall be immediately referred to the superior;
4. confidential information relating to the relationship between company and service provider is respected, and unauthorized reproduction and distribution of materials or alterations thereof is prohibited;
5. Engevale Engenharia does not establish service relations and material supply relationships with companies that use child labor and / or forced labor exploitation;
6. We should give preference to business with suppliers that have good Social Responsibility practices.
7. the practice of improper business such as piracy, smuggling, tampering, falsification, tax evasion, prejudiced, disrespectful or risky advertising and unfair competition is strictly prohibited;
8. We will not tolerate any corruption, bribery, bribery, personal favoritism and other forms of illicit or criminal acts in our supply chain.

XII - Conduct in Financial Operations
1. any payment or commitment made must be authorized by the competent level and supported by legal documentation;
2. All financial transactions must be recorded in the official records accurately, completely and reliably, in compliance with the principles set forth in the applicable corporate law and accounting procedures.
3. Any business-related business contacts made by banks or other financial institutions with any employee or industry should be immediately reported and forwarded to the Finance Department, which will determine the procedure to be followed.
4. Employees should maintain confidentiality about relevant financial information to which they have access, not using it for the benefit of themselves or others;
5. With respect to the use of Engevale Engenharia's financial resources while traveling, using its own cash for reimbursement, or the use of corporate credit / debit cards or other related expenses, employees shall make their use with austerity, sensibly and report expenses accurately when accountable;
6. The preparation of an expense report containing errors that are intended to be fraud is considered a serious misconduct.

XIII - Conduct Information Security, Network Usage, Internet and User Accounts
1. It is prohibited to disclose personal passwords of access to the corporate network to third parties;
2. The use of equipment, printing machines and copiers must comply with the internal rules of use;
3. The use of recordable media (pen drives, CDs, DVDs, etc.) must be limited to the professional purpose and the company's facilities and, if it is necessary to use these media outside this environment, the employee will be responsible for maintaining the integrity. network, preventing the transfer of files with viruses and accounting for the confidentiality of stored information;
4. Engevale Engenharia cannot be held responsible for any password theft that may occur through access to websites of banks and / or other financial institutions through its own network;
5. File servers should be used only for storing work-relevant files, and should not be used for storing personal files, and the user must assess the real need for files to remain on those servers.
6. The user is solely responsible for the use of his / her login (login) on the network and internet, being certain that any actions that may occur that harm other users will be the sole responsibility of the user;
7. Any user is prohibited from accessing websites with the following content:
• File Storage;
• Chat;
• Blogs / Fotoblog;
• Download software;
• Eroticism, Nudity and Pornography;
• Hackers;
• Games;
• Songs and Videos;
• Anonymous Browsing;
• Radio and TV;
• Social Networks;
• Relationship and Dating;

XIV - Conduct Using E-Mail
Our employees will not be able to use the email service to:
1. modify the authorship of files or assume without permission the identity of another user;
2. intentionally harm Internet users by sending programs and unauthorized access to computers, and / or by changing program files;
3. use the electronic mail service in any way to engage in commercial research activities, contests, chain letters, junk mail or any periodic or unsolicited messages (commercial or otherwise) or abusive, also known as spam;
4. use the e-mail to participate in electoral, civic-social campaigns and even to convey electoral information, either of himself or others;
5. defame, offend, disrupt the tranquility of others, stalk, threaten or otherwise violate the rights of others;
6. Post, post, upload, distribute or disclose any topics, names, materials or information that encourage discrimination, hatred or violence towards a person or group due to their race, religion or nationality;
7. use any materials or information, including images or photographs available on Engevale Engenharia's proprietary websites, to infringe any copyrights, trademarks, patents, trade secrets or other proprietary rights of others;
8. upload files that contain viruses, malicious code, corrupted files, or any other similar software or programs that may damage the operation of other computers or the property of others;
9. send messages that have a personal purpose regarding matters related to religious currents, obscene messages, fundraising and other purposes that are inappropriate for work;
10. convey, incite or encourage pornographic, pedophile and similar content;
11. Email messages are confidential and can only be accessed by the sender and their recipient (s), however, they may be accessed by the Information Technology area at the request of the users' leaders.

XV - Conduct with Confidential Information and Data
Engevale Engenharia makes available to its employees data, information, information systems and documents with content that should be used for the sole purpose of the company's interest. Thus, Engevale Engenharia reserves the right to verify the use and monitoring of information systems, being able to access messages and electronic files of employees with the prior approval of the direct leader.

XVI - Conduct with the Environment
Engevale Engenharia aims at improving the quality of life and preserving the environment, based on the concept of sustainable development. Therefore, we seek:
1. achieve standards of excellence in the environment to ensure products and services that meet customer expectations and environmental legislation;
2. invest in the sustainability of their projects, products and services, maximizing their benefits in the economic, social and environmental dimensions and minimizing their adverse impacts;
3. promote sustainable use of water and energy, reduction of consumption and recycling of materials;
4. Maintain an environmental management system for continuous improvement of its processes, including the production chain and promote internal environmental awareness actions.

XVII - Conduct with the Community
Engevale Engenharia acts with social responsibility, committing itself to the development of the local community, respecting and meeting the legal and regulatory requirements. Therefore, we aim to:
1. realization of social actions based on economically viable and socially productive operations;
2. Maintain permanent channels of communication and dialogue with the communities in which it operates, in order to prevent, monitor, evaluate and control the impacts of our activities.
3. adopt a transparent and democratic sponsorship process through public selection of social, environmental and cultural projects;
4. Promote employee volunteering initiatives to mobilize and leverage their resources and skills in an integrated and systemic manner, to the benefit of the communities in which they operate.

XVIII - Conflict of Interest Conduct
Engevale Engenharia employees are prohibited:
1. have family or affective relationship with subordinate or manager, direct or indirect;
2. have a family or emotional relationship with a company's supplier or customer that may influence the terms of those business relationships;
3. use the name of the company, position, function, activity, facilities, position and influence to obtain personal benefits or advantages, including for family members, relatives or related persons;
4. let personal relationships influence impartiality in decision making towards customers, suppliers, partners and competitors;
5. provide services to supplier companies, customers, competitors and others that present a conflict of interest while the employment relationship with the company continues;
6. market goods, goods and services in the workplace;
7. Keep professional activities parallel to those developed in the company at times that coincide with their workday.

XIX - Communications
For Engevale Engenharia, it is very important that every employee is aware of the need to report a question about the Code of Conduct. Such a decision can be difficult as it may involve co-workers. However, it is important to remember that a lack of immediate communication, a lack of ethical conduct can result in serious harm to the safety, health and well-being of your person, co-workers, clients, the environment and the community at large. the company acts, as well as fines and / or arrests for wrongdoing employees in the most serious cases. Therefore, the main reason for communication is not to harm a colleague, but to take care of oneself, to safeguard the identity of the company and to preserve customers, suppliers, the environment and the surrounding community.
This communication can be personalized or anonymous through the following channels:
• In writing, by letter, ticket or the appropriate form;
• By post office to the address of the headquarters - Rua Jose Luís de Almeida Soares, 285, Central Park, Taubaté / SP;
• By phone - (12) 3621-1335;
• By email - faleconosco@engevale.co.;

XX - Penalties
Employees who violate this Code of Conduct in any event will be subject to disciplinary action, including termination of their employment contracts. In this sense, Engevale Engenharia considers as violations:
1. act in violation of the Code of Conduct;
2. ask someone else to violate it;
3. be aware of acts that violate the Code of Conduct and not immediately report to their superiors;
4. Retaliate against employees who have reported a concern for ethical conduct or a violation of the Code of Conduct.