Code of Conduct
Code of Conduct
I - HOW TO APPLY THE CODE
The Engevale Engenharia S.A. Code of Ethical Conduct (‘Engevale Engenharia’) applies to all members of the board of directors, management, fiscal sector, general employees, interns, apprentices, service providers, and any individual representing Engevale Engenharia (’employees’). It establishes the principles and values that guide professional conduct within the company, ensuring transparency, integrity, and respect in all internal and external relationships. As a signatory to the UN Global Compact – Brazil Network, Engevale Engenharia reinforces its commitment to human rights, environmental preservation, and compliance with current legislation, aligning its practices with the highest ethical and governance standards.
This Code will be revised and updated periodically, at least once (1) a year, under the responsibility of the Integrated Management System (IMS) and Compliance area, with the approval of top management. The company’s leadership is responsible for ensuring the application of this Code’s guidelines, promoting an ethical environment aligned with the company’s organizational values. Engevale Engenharia will conduct regular training, at least once (1) a year, to disseminate and reinforce the principles and rules established herein. Additionally, communication channels are available for clarifying doubts and reporting eventual non-compliance with norms, ensuring that all employees can act with security and confidence.
The guidelines of this Code must be observed in all company activities. However, in situations where the guidelines of this Code are not sufficient, your personal talent, creativity, and initiative to innovate for the benefit of Engevale Engenharia can assist you in making decisions, always evaluating the risks and consequences of your actions. Acting with responsibility and ethics strengthens the organizational culture and contributes to the company’s credibility in the market.
II - OUR MISSION, VISION, AND VALUES
Mission
Leading with innovation, our mission is to exceed the expectations of every client, providing solutions of excellence and reliability. We are committed to acting in an innovative, sustainable, and dedicated manner, generating a positive and lasting impact. We are deeply committed to understanding our clients’ needs, adapting our solutions to overcome challenges and ensure exceptional results that endure over time.
Vision
To establish standards of excellence in the engineering segment, committing ourselves to the total satisfaction of our clients and the continuous improvement of our processes. Our objective is not merely to meet expectations, but to surpass them, creating elevated and lasting standards. We do not seek only market leadership, but to be a transformative force, inspiring other organizations to adopt sustainable and innovative practices. We aspire to be recognized not only for the structures we build, but for the positive impact we leave on the communities where we operate.
Values
People First: We recognize people as our most valuable asset, promoting an inclusive and inspiring work environment. We are committed to developing the potential of our employees, providing opportunities for professional and personal growth.
Guardians of the Environment: We respect and preserve the environment, adopting controlled and sustainable practices in all our operations. Our commitment extends beyond mere compliance with environmental standards; we constantly seek ways to reduce our impact and promote the conservation of natural resources.
Integrity and Transparency: We are guided by the principles of honesty, transparency, and loyalty in all our interactions, both internal and external. We establish relationships based on trust, honoring our commitments and maintaining integrity in all transactions.
Innovation and Competitiveness: We are constantly seeking new business opportunities, maintaining our competitiveness and profitability while driving innovation in every endeavor. We encourage creativity and value adaptability in a constantly evolving world.
Excellence and Client Satisfaction: We are committed to ensuring exceptional quality and total satisfaction for every client who chooses our company, exceeding their expectations with each project. We invest in research, technology, and training to ensure that every delivery reflects not only our technical expertise but also our unwavering commitment to excellence.
III - OUR PRINCIPLES
As a signatory to the UN Global Compact – Brazil Network since 2021, the company is committed not only to technical excellence but also to the practice of ethical and transparent management, dedicated to social and environmental responsibility. These principles guide our actions and behaviors in all our activities, and are always focused on ethics, respect for human rights, and the fight against corruption.
1. Commitment to human rights.
Engevale Engenharia has an undeniable commitment to human rights, ensuring dignity and respect for employees, partners, and communities. As an integral part of the UN Global Compact – Brazil Network, we reinforce our responsibility to combat discrimination, promote inclusion, and prevent any form of exploitation, including child and forced labor. Furthermore, we ensure freedom of association and collective bargaining, in accordance with International Labour Organization (ILO) conventions, and maintain an ethical work environment, free from harassment and abuse.
2. Ethics and integrity.
Engevale Engenharia adopts high standards of ethics and integrity, guiding our attitudes, practices, and decisions based on principles that prioritize transparency, honesty, and mutual respect. We are committed to acting with integrity and transparency in all relationships, avoiding conflicts of interest and communicating any relevant situation. Likewise, we ensure the confidentiality of internal information and client and partner data, guaranteeing their exclusive use for agreed purposes and in accordance with current data protection legislation.
3. Fair and responsible labor practices.
Considering that Engevale Engenharia is a signatory to the UN Global Compact – Brazil Network, we reaffirm our commitment to the well-being and appreciation of our employees. For this reason, we are committed to strictly complying with labor and safety laws, ensuring fair remuneration, adequate working hours, and a safe environment for all employees. We support and promote freedom of association and the right to collective bargaining, recognizing their relevance for building fair and balanced labor relations. We repudiate all forms of forced or compulsory labor, as well as any practice involving child exploitation, reinforcing our commitment to the dignity and fundamental rights of workers. Our commitment to diversity, inclusion, and equal opportunities is reflected in all stages of the professional journey, ensuring the elimination of any form of discrimination in recruitment, selection, promotion, and career development processes. Furthermore, we prioritize the health and safety of our employees, continuously investing in training, adequate infrastructure, and good practices that ensure a safe, responsible work environment conducive to the professional and personal growth of all.
4. Environmental responsibility.
As a signatory to the UN Global Compact – Brazil Network, Engevale Engenharia recognizes that sustainability is a shared responsibility that goes beyond compliance with environmental legislation. Therefore, we commit to adopting a preventive approach to environmental challenges, respecting applicable norms and regulations, and seeking continuous improvement of our practices. We develop initiatives that strengthen our environmental responsibility and encourage the development and dissemination of sustainable technologies.
5. Compliance and legal conformity.
We ensure compliance with all applicable laws and regulations, respecting the regulations of where we operate, with total respect for local, national, and international rights and laws. To this end, we adopt ethical and responsible practices, maintain rigorous internal controls to ensure legal compliance, and implement compliance policies to prevent and mitigate risks, aligning with the highest governance standards. Furthermore, we promote an organizational culture based on transparency and integrity, encouraging our employees and partners to act responsibly. We regularly review our processes to ensure adherence to market best practices and constantly seek to improve our corporate governance guidelines.
6. Combating corruption and anti-bribery practices.
Engevale Engenharia, as a signatory to the UN Global Compact – Brazil Network, reaffirms its commitment to ethics and transparency, adopting a rigorous policy to combat corruption in all its forms, including extortion and bribery. The company prohibits any undue advantage, in addition to encouraging and protecting reports of irregularities, ensuring an ethical and safe environment for all. To reinforce this commitment, we continuously invest in training and awareness programs for our employees and partners, promoting a culture of integrity. Furthermore, we have secure and confidential reporting channels, ensuring that any ethical violation is treated with due seriousness. In this way, we strengthen our governance and contribute to a fairer and more responsible corporate environment.
IV - OUR COMMITMENTS TO CONDUCT
1. Example.
Top management and leadership at Engevale Engenharia are responsible for promoting the principles and values of this Code, always serving as an example for their teams. They must ensure employee integration and consistency between discourse and practice. Inspiring leadership strengthens the sense of belonging and promotes an ethical and transparent environment, ensuring that organizational values are lived daily. Additionally, it is up to leadership to encourage open communication and engagement, strengthening the culture of integrity and corporate responsibility.
2. Responsibility.
All employees must act with diligence and account for their actions according to internal standards and whenever requested. Each individual is responsible for their actions and, where applicable, for decisions made in the exercise of their duties. The commitment to individual responsibility strengthens the reliability of internal processes, ensuring that adopted practices are aligned with the company’s strategic interests. Furthermore, the transparency and commitment of each employee contribute to an ethical and high-performing organizational environment.
3. Trust.
Engevale Engenharia trusts in the integrity and good faith of its employees, guiding them to follow norms and standards. The company’s interests and objectives must prevail over individual interests, just as content must outweigh form. Transparency and mutual respect are essential for building an environment of trust, promoting solid and ethically based relationships across all levels of the company. To this end, the company encourages open communication and cooperation, ensuring that everyone feels valued and engaged. In this way, we reinforce our commitment to an organizational culture based on responsibility and professionalism.
4. Courage.
We value the determination and proactivity of our employees in facing challenges. They are encouraged to express their opinions and act with firmness to achieve results, always respecting the company’s values and commitments. The courage to innovate and face adversities contributes to an environment of learning and growth, where effective solutions are developed with resilience and commitment.
5. Unity.
Our teams are formed with commitment and alignment to strategic objectives, maximizing individual skills and aptitudes to achieve collective success. Collaboration and respect among teams strengthen organizational synergy, allowing challenges to be overcome jointly and goals to be achieved with excellence.
6. Cooperation.
Engevale Engenharia encourages cooperation and a supportive work environment, where the sharing of knowledge and experiences strengthens the team and drives the company’s performance. The culture of mutual support and empathy among employees contributes to a more productive and harmonious environment, favoring the exchange of ideas and the professional growth of all.
7. Innovation.
Stimulating creativity and the search for new solutions is essential for the evolution of the company and society. Innovation is a strategic pillar that propels us towards excellence. We invest in the development of new technologies, encourage experimentation, and continuously seek ways to improve processes and services, ensuring long-term competitiveness and sustainability.
8. Continuous improvement.
Work processes must add value and be in constant improvement, being monitored and adjusted according to the analysis of concrete situations. The culture of continuous improvement drives operational efficiency and the quality of services provided, promoting increasingly effective solutions aligned with industry best practices. To this end, the company invests in innovation, technology, and training, encouraging the search for new methodologies and tools that optimize performance.
9. Results.
We seek high performance and a focus on goals to generate value for society and stakeholders, forming teams oriented towards excellence. The commitment to solid and sustainable results drives the company’s growth, ensuring a positive impact for its stakeholders and the consolidation of Engevale Engenharia as a benchmark in the market.
10. Reputation.
The image and reputation of Engevale Engenharia are reflected in the conduct of its employees, both inside and outside the company. Any act that violates the company’s values, whether in the workplace or on social media, may result in disciplinary sanctions, including contract termination. Maintaining an ethical and responsible posture is essential to preserve the company’s credibility, ensuring the respect of clients, partners, and society as a whole.
11. Transparency.
Engevale Engenharia and its employees commit to transparent, respectful, clear, and accessible communication. Furthermore, they ensure accurate and complete accounting records, guaranteeing full transparency in audits and in relationships with public bodies. Access to information and clarity in processes are fundamental to strengthening trust and stakeholder engagement, promoting an ethical and reliable corporate environment.
V – OUR DUTIES
It is the duty of Engevale Engenharia, as a participating company in the UN Global Compact – Brazil Network, to conduct its business and activities with social and environmental responsibility, contributing to sustainable development. The company must act preventively in identifying and evaluating environmental risks, mitigate and remedy impacts caused, and promptly communicate with its publics of interest about the occurrence of environmental damage. It is also the duty of Engevale Engenharia to preserve and promote the health, well-being, and safety of its employees, considering aspects such as quality of life and psychological safety. To this end, the company continuously invests in improving processes, management practices, new technologies, and in the maintenance of equipment and facilities, strengthening a solid culture of safety, environment, and health (SMS). Engevale Engenharia must also ensure that all employees working in its facilities have access to the same healthy and safe working conditions offered to its own employees.
Therefore, it is the duty of all employees:
1. to know, follow, and disseminate the SMS policy, guidelines, and orientations in all their activities;
2. to care for their own safety and that of colleagues, and to allow themselves to be cared for when necessary;
3. to perform their activities only when they possess the necessary knowledge, are capable, and duly authorized, always using appropriate procedures and equipment;
4. to know how to act in emergencies, immediately communicate any unsafe act or condition, and operate in a psychologically safe environment where the right to refuse is ensured if they identify a serious and imminent risk to their physical integrity or that of their colleagues;
5. to undergo occupational medical examinations within the established deadline and keep their Occupational Health Certificate (ASO) valid;
6. to comply with all legal, regulatory, and normative requirements related to their activities within Engevale Engenharia or on behalf of the company. In case of doubt, report immediately to their direct superior;
7. to respect all forms of life and the environment, preventing damage and ensuring that potential impacts are duly considered in decision-making processes;
8. to identify, communicate, and control environmental, climatic, and health and safety risks to people, always in accordance with current legislation, standards, and norms of Engevale Engenharia;
9. to maintain standards of excellence in respect for life, people, and the environment, ensuring that results, products, and services meet the expectations of clients, investors, local communities, and other stakeholders, as well as applicable legislation in Brazil and in the countries where Engevale Engenharia operates.
VI - PRIVACY AND PERSONAL DATA PROTECTION
It is the duty of Engevale Engenharia to guarantee all personal data subjects processed by the company the right to privacy and the protection of such information, ensuring them the full exercise of their rights. To this end, all employees have the following responsibilities:
1. to process personal data exclusively for specific, necessary, legitimate, and duly defined purposes;
2. to rigorously comply with internal and legal norms and guidelines related to privacy and personal data protection;
3. to ensure that collected data are proportional, not excessive, and limited to the minimum necessary for the performance of their activities, ensuring that their use is always aligned with previously established purposes;
4. to protect and preserve the quality of personal data at all stages of their processing, adopting security and prevention mechanisms to avoid or mitigate risks both for data subjects and for the company;
5. to be aware that, when using equipment and resources made available by the company, there is no expectation of privacy, and Engevale Engenharia may access content produced or transited on them, always in accordance with applicable norms.
VII - PROTECTION OF CORPORATE INFORMATION
It is the duty of Engevale Engenharia and all its employees to ensure the confidentiality, integrity, availability, and authenticity of corporate information and personal data under their responsibility, as well as those obtained in meetings or negotiations. All information must be treated with the highest level of security, in accordance with internal norms and applicable regulations. To this end, employees must:
1. strictly follow the information security norms and guidelines established by Engevale Engenharia;
2. use and share corporate information only within the context strictly necessary for the performance of their professional activities, respecting information security guidelines;
3. access company services and information exclusively through corporate or authorized private technological resources, always in accordance with information security norms;
4. preserve the confidentiality of their access credentials, not disclosing or sharing them with third parties, nor using third-party credentials to access corporate information or systems;
5. adopt all recommended precautions when treating and sharing company information, both in and out of the corporate environment, especially those that may impact strategic decisions, finances, legal compliance, image, and reputation;
6. respect professional, commercial, and industrial secrecy, avoiding unauthorized disclosure, transmission, or sharing of information or personal data obtained in the exercise of their professional activities, always in accordance with information security norms;
7. ensure that information entered into documents and communications is true, duly classified according to its level of confidentiality, and restricted to persons whose function requires access, respecting company norms;
8. immediately report, through appropriate corporate channels or to their direct superior, any incident, violation, or non-compliance related to information security, as well as the disappearance or suspicion of loss of information, personal data, or equipment containing sensitive data;
9. safely discard documents and information, following corporate guidelines, and never voluntarily alter or destroy original documents of probative value, keeping them archived, preferably in digital format, according to legal deadlines and requirements.
VIII – PERSONAL CONDUCT
1. always comply with the norms, policies, processes, and procedures established by Engevale Engenharia;
2. only do what you are sure you can do. If in doubt, seek guidance from your immediate manager or departmental manager;
3. cultivate cordiality in relationships and try to resolve disagreements or misunderstandings with care, respect, and acceptance;
4. practice dialogue, not the imposition of a point of view, listening carefully and respecting others’ opinions, even if you disagree with them;
5. help colleagues do a good job and guide those who seek you with patience and interest;
6. never intentionally mislead anyone or cause them any kind of damage;
7. give due credit to colleagues’ ideas and achievements and do not present personal ideas, opinions, and preferences as if they were those of Engevale Engenharia or its administrators or employees;
8. do not use Engevale Engenharia’s name, position, or influence to obtain personal benefits or for relatives, friends, or third parties;
9. do not discriminate against anyone based on their ethnicity, gender, political, sexual, religious, cultural preferences, or disabilities;
10. do not engage in offensive conduct, whether verbal, physical, or gestural;
11. do not spread rumors and gossip;
12. if you make a mistake, do not hide the fact; be transparent and truthful and strive to mitigate its consequences and learn from them;
13. participate punctually and with dedication in the education and training actions offered by Engevale Engenharia;
14. take care of facilities, resources, equipment, and work materials, and only use them for personal purposes in case of an emergency that does not jeopardize the integrity of Engevale Engenharia’s assets;
15. adopt the precepts of conscious consumption, not wasting water, energy, paper, plastic objects, office supplies, etc., and practice selective collection;
16. avoid financial imbalances, as they entail personal and professional losses;
17. present yourself at the workplace in a full state of normalcy (without intoxication, drug use, medication use, etc.);
18. do not use illicit drugs, as their use constitutes a crime and compromises professional performance, by severely harming the lives of users and their families, disturbing the work environment, and potentially causing risky situations for others;
19. take care of your personal appearance, dressing appropriately for the role performed;
20. present yourself to work in accordance with the company’s standards of excellence, as professional image and personal presentation are essential elements for Engevale Engenharia’s reputation with its clients and business partners;
21. the use of low necklines, short skirts, exposed midriffs, transparent fabrics, beards, mustaches, or goatees longer than two (2) centimeters, long male hair, as well as the use of soccer team shirts, is prohibited;
22. do not disclose Engevale Engenharia information or comment on daily work situations on social media;
23. use your official time in a responsible effort to fulfill your tasks, performing your functions or assignments efficiently and effectively;
24. employees in leadership positions must not encourage, demand, or request their subordinates to use official time to perform activities not required for the performance of their duties or job responsibilities;
25. be responsible in the correct use and preservation of machines, equipment, landlines and cell phones, vehicles, and other materials used for your activity, with improper and non-transferable use by third parties through loans, rentals, or exchanges;
26. landlines and cell phones are work tools, and their use must be restricted to this purpose; in case of a personal emergency, use must be done within the shortest possible time;
27. the use of cell phones in production and/or service areas is prohibited, and they must remain turned off along with personal belongings.
IX – PROFESSIONAL CONDUCT
1. perform your work with diligence, focus on Engevale Engenharia’s interests, and in accordance with the company and this Code of Conduct;
2. stay updated on advances in your professional area and, when applicable, obtain the necessary certifications for your position;
3. do not engage in any illicit or criminal activities, including, but not limited to, corruption, bribery, money laundering, fraud, and other harmful practices;
4. never advise, disseminate information, or negotiate based on rumors or unreliable data;
5. fully know and comply with Engevale Engenharia’s policies and other norms;
6. in relationships with clients, suppliers, and other publics, seek the competent channels to attend to requests or resolve conflicts outside your attributions;
7. ask for guidance from your immediate manager and the corporate communication area before participating in interviews and programs in conventional or virtual media;
8. do not speak on behalf of Engevale Engenharia without prior authorization;
9. do not use social media or software not provided by Engevale Engenharia to perform your professional activities.
X – FORM OF OFFICIAL COMMUNICATION
Engevale Engenharia believes that effective and documented communication is essential to ensure transparency, traceability, and compliance with the company’s guidelines and regulations. In this sense, to ensure proper formalization and record-keeping of interactions, corporate email is established as the sole official means for conducting institutional communications, especially those involving negotiations, approvals, contracts, technical and commercial definitions, and any other strategic matters. Therefore, it is prohibited to conduct negotiations related to commercial matters, acquisition processes, and other topics linked to the scope of projects through informal communication platforms, such as instant messaging applications or social media. Furthermore, it is essential that all involved and interested parties are kept in copy on emails, ensuring broad visibility of information, avoiding communication failures, and ensuring the traceability of decisions made. The use of informal channels must be strictly limited to the transmission of specific and operational information, without a decisive or contractual nature. Any deliberation or negotiation that impacts the execution of projects, contracts, or internal processes must be recorded and formalized by email, ensuring legal security and the integrity of information.
XI – CONDUCT WITH EMPLOYEES
1. Engevale Engenharia commits to ensuring the health and safety of its employees, providing all necessary PPE free of charge, guiding, and training everyone to comply with norms and regulations.
2. Engevale Engenharia commits to providing adequate physical facilities for the performance of its employees’ duties and to making the necessary adaptations for the inclusion of people with disabilities.
3. Engevale Engenharia will treat everyone equally, without discrimination based on color, sex, origin, ethnicity, social class, age, physical ability, sexual orientation, or religion, distinguishing only those who, by competence and merit, deserve special treatment (awards, honors, spontaneous salary adjustments, etc.).
4. The management of Engevale Engenharia also commits to being an example of good relationships, always promoting a climate of tranquility, harmony, and respect in relations with employees.
XII – CONDUCT WITH LABOR UNIONS
1. Engevale Engenharia maintains a respectful relationship with labor unions and does not practice any type of discrimination against unionized employees.
2. Engevale Engenharia respects the free association of its employees with labor unions, as well as recognizes and complies with all Collective Bargaining Agreements and Conventions signed with the category.
XIII – CONDUCT WITH CLIENTS
1. Client satisfaction is the responsibility of all employees, without distinction.
2. The commitment to our clients’ satisfaction must be reflected in the search for solutions that meet their needs, presenting clear, objective information, provided that contractual conditions are observed and in accordance with the company’s principles.
3. Maintain fair, transparent commercial practices in compliance with all applicable laws and regulations.
4. Relationships with clients must be guided by honesty, respect, courteous, and efficient service.
5. Any employee who observes an attitude of disinterest, impatience, or even disrespect towards Engevale Engenharia clients must immediately communicate the fact to their immediate leader and/or the company’s Human Resources department.
XIV – CONDUCT WITH PROVIDERS, SERVICE PROVIDERS, AND BUSINESS PARTNERS
1. The selection and hiring of service providers and/or acquisition of materials, inputs, and equipment are based on technical, professional, ethical, and legal criteria, aligning with the company’s needs. These processes must be conducted in partnership with the company’s headquarters Procurement Department, ensuring the best cost-benefit ratio for Engevale Engenharia.
2. The relationship with our suppliers is guided by courtesy and efficiency, with all requested information provided appropriately, when necessary and authorized, and fulfilling agreed commitments.
3. Any doubt regarding the appropriateness of fulfilling any request must be immediately submitted to the direct superior.
4. Confidential information related to the relationship between the company and service provider is respected, and unauthorized reproduction, distribution, or alteration of materials is prohibited.
5. Engevale Engenharia does not establish service provision and material supply relationships with companies that use child labor and/or forced labor.
6. We must give preference to doing business with suppliers who are committed to the best environmental, social, and governance (ESG) practices.
7. The practice of improper business, such as piracy, smuggling, adulteration, counterfeiting, tax evasion, prejudiced, disrespectful, or risky advertising, and unfair competition, is prohibited.
8. No practice of corruption, bribery, kickbacks, personal favors, and other forms of illicit or criminal acts in our supply chain will be tolerated.
XV – CONDUCT IN FINANCIAL OPERATIONS
1. Any payment or commitment assumed must be authorized by the competent level and supported by relevant legal documentation.
2. All financial operations must be accurately, completely, and reliably recorded in official accounting records, respecting the principles set forth in corporate legislation and current accounting procedures in the country.
3. Any commercial contacts related to the company’s business, made by banks or other financial institutions with any employee or sector, must be immediately informed and forwarded to Engevale Engenharia’s Financial Directorate, which will determine the procedure to be adopted.
4. Employees must keep confidential relevant financial information to which they have access, not using it to obtain advantages for themselves or for third parties.
5. Regarding the use of Engevale Engenharia’s financial resources for travel, with the use of personal cash for reimbursement, or the use of corporate credit/debit cards or other related expenses, employees must use them with austerity, in a sensible manner, and accurately report expenses when submitting their expense reports.
6. The preparation of expense reports containing errors intended for fraud is considered a serious misconduct.
XVI – CONDUCT WITH INFORMATION SECURITY, NETWORK USE, INTERNET, AND USER ACCOUNTS
1. Engevale Engenharia, with the objective of fully complying with the guidelines of the General Data Protection Law (LGPD), carries out its business activities based on the pillars of transparency and responsibility in the processing of personal data, ensuring the privacy and security of this information.
2. Engevale Engenharia will systematically promote awareness about the importance of privacy and continuous improvement of its internal practices, aiming at respecting the principles and legal requirements of the LGPD.
3. It is prohibited to disclose personal passwords for corporate network access to third parties.
4. The use of equipment, printing machines, and copiers must comply with internal usage norms.
5. The use of writable media (pen drives, CDs, DVDs, etc.) must be limited to professional purposes and company premises, and if it is necessary to use these same media outside this environment, the employee will be responsible for maintaining network integrity, avoiding the transfer of files with viruses, and being responsible for the confidentiality of stored information.
6. Engevale Engenharia cannot be held responsible for any password thefts that may occur due to access to banking and/or other financial institution websites through its own network.
7. File servers should only be used for storing work-relevant files and should not be used to store personal files, and the user should evaluate the real need for files to remain on these servers.
8. The user is solely responsible for the use of their login on the network and internet, and any actions that may occur that harm other users will be the sole responsibility of the user.
9. Access by any user to sites with the following content is prohibited:
- File storage
- Chat
- Blogs/photoblogs
- Software downloads
- Eroticism, nudity, and pornography
- Hackers
- Games
- Music and videos
- Anonymous Browse
- Radio and TV
- Social media
- Dating and relationships
XVII – CONDUCT WITH EMAIL USE
Engevale Engenharia employees may not use the email service to:
1. Modify file authorship or assume, without authorization, the identity of another user.
2. Intentionally harm Internet users by sending programs and unauthorized access to computers, and/or by altering program files.
3. Use the email service in any way to participate in commercial research activities, contests, chain letters, junk mail, or any periodic or unsolicited messages (commercial or not) or abusive messages, also known as SPAM.
4. Use email for participation in electoral campaigns, civic-social activities, or to disseminate electoral information, whether personal or from third parties.
5. Defame, offend, disturb others’ tranquility, persecute, threaten, or, in any other way, violate the rights of third parties.
6. Publish, post, upload, distribute, or disseminate any topics, names, materials, or information that encourage discrimination, hatred, or violence concerning a person or group due to their race, religion, or nationality.
7. Use any materials or information, including images or photographs available on websites owned by Engevale Engenharia, in a way that infringes any copyrights, trademarks, patents, trade secrets, or other proprietary rights of third parties.
8. Send files containing viruses, malicious codes, corrupted files, or any other similar software or programs that may damage the operation of other computers or the property of third parties.
9. Send messages with personal purposes related to religious chains, obscene messages, fundraising, and others with inappropriate purposes for work.
10. Disseminate, incite, or encourage pornographic, pedophilic, and similar content.
11. Email messages are confidential, and can only be accessed by the sender and recipient(s); however, they may be accessed by the Information Technology area upon request from user leaders in an eventual situation.
XVIII – CONDUCT WITH THE COMMUNITY
Engevale Engenharia acts with social responsibility, committing to the development of the local community, respecting and complying with legal and regulatory requirements. Therefore, we aim for:
1. The implementation of social actions based on economically viable and socially productive operations.
2. Maintaining permanent channels of communication and dialogue with the communities where we operate, with the objective of preventing, monitoring, evaluating, and controlling the impacts of our activities.
3. Adopting a transparent and democratic sponsorship process, through public selection of social, environmental, and cultural projects.
4. Promoting employee volunteer initiatives, with the objective of mobilizing and enhancing their resources and competencies in an integrated and systemic way, for the benefit of the communities in which we operate.
XIX – CONDUCT IN CONFLICT OF INTEREST
A conflict of interest occurs when an employee acts guided by personal interests, to the detriment of a public interest (including Engevale Engenharia’s interests), thereby compromising the collective interest or unduly influencing the performance of their function.
It is the duty of Engevale Engenharia to prevent and avoid any situation where there is a conflict between public and private interests that could compromise the company’s interests, harm its reputation, or improperly influence the performance of the respective professional activity. To this end, it is the responsibility of all its employees:
1. To know and avoid conflict of interest situations provided for in internal and legal norms, both during and after the exercise of their activities.
2. Not to directly or indirectly engage in any activity that conflicts with the interests of Engevale Engenharia.
3. To seek impartiality, performing their activities impartially, without using their position as an employee to obtain undue advantages for Engevale Engenharia, for themselves, or for third parties.
4. Not to use information accessed in the exercise of their activities to trade stocks or other securities, or to obtain personal advantages or for third parties, nor to share such information with third parties for these purposes.
5. To report any conflict of interest situation they become aware of through the Whistleblower Channel.
6. To declare themselves impeded from deciding or performing certain activities whenever the act could generate a conflict of interest.
7. To refrain from performing external activities whose promoters, contractors, or sponsors have a direct or indirect interest in decisions related to the employee’s duties.
8. To know and comply with applicable internal and legal norms that address the prohibition of nepotism.
9. Not to carry out reciprocal hiring, appointments, or designations between the company’s organizational units or between Engevale Engenharia’s equity participations, constituting cross-nepotism.
10. Not to hire a legal entity whose administrator or managing partner is a family member of a company employee who holds a trusted position in the organizational unit responsible for the demand or hiring ; or of an immediate hierarchical superior to the company employee who holds a trusted position in the organizational unit responsible for the demand or hiring ; or even of an occupant of a trusted position responsible for authorizing the hiring and signing the contract.
11. Not to use the position, mandate, function, employment, or activity performed in the company, nor facilities, friendships, time, position, and influences, to obtain any type of favoritism for themselves or for third parties.
Furthermore, all Engevale Engenharia employees are prohibited from:
12. Having a family or affective relationship with a direct or indirect subordinate or manager.
13. Having a family or affective relationship with company suppliers or clients that could influence the terms of these commercial relationships.
14. Using the company name, position, function, activity, facilities, position, and influence to obtain benefits or personal advantages, including for their family members, relatives, or related persons.
15. Allowing personal relationships to influence impartiality in decision-making regarding clients, suppliers, partners, and competitors.
16. Providing services to supplier companies, clients, competitors, and others that present a conflict of interest while the employment relationship with the company continues.
17. Selling goods, products, and services in the workplace.
18. Maintaining professional activities parallel to those performed at the company at times coinciding with their work schedule.
XX – PREVENTION OF FRAUD, CORRUPTION, MONEY LAUNDERING, AND TERRORISM FINANCING
Engevale Engenharia is committed to promoting integrity in the public and private business environment, acting in full compliance with applicable national and international legislation, especially the Administrative Probity Law (Brazil), the Corporate Anti-Corruption Law (Brazil), the FCPA – Foreign Corrupt Practices Act (USA), the UK Anti-Bribery Act, and the SOX – Sarbanes-Oxley Act (USA), among other legal norms in combating corruption. For this reason, it is a signatory to anti-corruption initiatives both in Brazil and abroad. In addition to this Code, Engevale Engenharia’s Integrity System is guided by the Compliance Policy, which describes the company’s commitments to promote ethics, integrity, and transparency, and by the Compliance Program, which is the set of mechanisms designed to prevent, detect, and correct misconduct and harmful acts committed against the company, including those related to fraud, corruption, money laundering, conflict of interest, and violation of competition defense. In this context, Engevale Engenharia repudiates all forms of fraud and corruption, including bribery, money laundering, or insider trading, at all its hierarchical levels.
Therefore, it is absolutely prohibited for all its employees to:
1. Request, obtain, receive, promise, offer, or give undue advantages of any nature for themselves or for third parties, including facilitation payments due to the public function performed.
2. Induce or persuade colleagues to act improperly or illegally on behalf of or in favor of the company.
3. Omit themselves in the face of situations of fraud and corruption (national or transnational), in any form, direct or indirect, active or passive, whether or not involving monetary values.
4. Finance, cost, sponsor, or, in any way, subsidize the practice of illicit acts.
5. Adopt, in relation to the public sector, national or foreign, any initiative that may be interpreted as influence peddling or an act harmful to Public Administration, as described in Article 5 of Federal Law No. 12,846/13 (also known as the Corporate Anti-Corruption Law).
XXI – COMMUNICATION
For Engevale Engenharia, it is very important that every employee is aware of the need to communicate a doubt about the Code of Conduct. Decision-making in this context can be challenging, especially when involving colleagues. However, it is of utmost importance to remember that the absence of immediate communication in the face of an ethical misconduct can lead to serious consequences for the safety, health, and well-being of the employee themselves, colleagues, clients, the environment, and the community in which the company operates, as well as fines and/or imprisonment for infringing employees in more severe cases. For this reason, the main motive for communication is not to harm a colleague, but rather to ensure individual protection, safeguard the company’s identity, and preserve clients, suppliers, the environment, and the surrounding community. This communication can be personalized or anonymous, through the following channels:
• By phone – (12) 3621-1335
• By email – denuncia@engevale.com
• https://engevale.com/denuncia
XXII – PENALTIES
Employees who, in any way, violate this Code of Conduct or compromise the company’s image will be subject to legally applicable disciplinary measures. Such measures will be analyzed case by case, considering the severity, intent, and impact of the conduct, and may vary from warnings to employee dismissal. We ensure that all penalties will be applied fairly, transparently, and in accordance with current labor legislation. In the case of suppliers, service providers, and business partners who fail to comply with the precepts of this Code, measures will be evaluated individually and, depending on the severity of the infraction, may result in the termination of the commercial relationship. In this sense, Engevale Engenharia considers the following as violations:
1. Acting contrary to this Code of Conduct.
2. Soliciting another person to violate it.
3. Having knowledge of acts that violate the Code of Conduct and not immediately communicating them to superiors.
4. Retaliating against employees who have communicated an ethical concern or a violation of the Code of Conduct.
Menu
Units and Contacts
- Office Taubaté/SP
- (12) 3621-1335
- Office Tremembé/SP
298 Rodrigues Alves St, Room 02, Centro, Tremembé/SP, 12120-000, Brazil.
- (12) 3621-1335
- Office São Paulo/SP
- (12) 3621-1335
- Email: comercial@engevale.com
- Phone: +55 (12) 3621-1335
