PURPOSE AND APPLICATION
The Code of Ethics and Compliance is a reflection of how Dakron relates and how it maintains its ethical commitment to society and to all its employees, customers, shareholders, suppliers and other interested parties.
This document is based on corporate principles and reaffirms the guidelines for conduct that must be followed with all publics with which the organization relates.
It is important that all employees reflect on the mission, vision and values, which define where we want to go as an organization and, consequently, the daily attitudes for everyone, as a group, to achieve this same objective.
We are convinced that everyone should perform their duties with the same attitude
and diligence which they would employ in the conduct of their private affairs, and therefore
putting into practice what we believe to be correct, fair and honest. In this way,
we guarantee a healthy corporate environment for all of us.
This Code of Ethics and Compliance was prepared to ratify Dakron's commitment to ethical conduct that guarantees the quality of products and services.
The information presented here makes clear what we seek from each professional and demonstrates how the company is structured to achieve the essential principles.
With this code, the organization seeks to contribute to the creation of long-term partnerships that are compatible with the most legitimate interests and aspirations of society.
It is expected that this document does not cover all situations of ethical conflicts that may arise on a daily basis.
The objective is to define basic principles that should guide the organization's relationships and activities, in addition to reinforcing the need to comply with current legislation.
When reading this document, read it carefully, and if you have any questions, please contact us by e-mail: email@example.com.
TERMS AND DEFINITIONS
• Conduct: conduct is a manifestation of the individual's behavior, it can be good or bad, depending on the moral and ethical code of the group where he is.
• Compliance: set of disciplines in order to comply with and ensure compliance with legal and regulatory standards, policies and guidelines established for the business and for the activities of the institution or company, as well as to avoid, detect and treat any deviations or nonconformities that may occur.
The term compliance comes from the English verb to comply, which means to act in accordance with a rule, an internal instruction, a command or a request.
• Ethics: part of the philosophy responsible for investigating the principles that motivate, distort, discipline or guide human behavior, reflecting especially on the essence of norms, values, prescriptions and exhortations present in any social reality. Set of rules and precepts of an evaluative and moral order of an individual, a social group or a society.
• Stakeholders: are those people, groups of people, institutions, organizations, society, suppliers, customers, financial institutions, government, employees; among others. That is, everyone who has a significant interest and who can interfere positively or negatively in the management of a business and its management.
the top management
• Ensuring a relationship with stakeholders based on the principles described in this code.
• Ensuring that all company practices are compatible with internal guidelines, respecting the laws and valuing the integrity of employees.
• Provide the necessary and adequate resources to comply with this Code.
• Keep the Code of Conduct, Ethics and Compliance updated, carrying out revisions whenever necessary to keep it in line with innovations and organizational culture.
• Comply with and enforce this code, serving as an example and reinforcing the values prioritized by the company with its subordinates.
• To assert its authority to promote an environment that values ethical attitudes, and to be committed to providing customers with services that comply with the company's internal policies and procedures.
Direct and indirect collaborators
• Comply with this code, serving as an example and reinforcing the values prioritized by the company with indirect employees.
• Communicate possible deviations identified.
MISSION, VISION AND VALUES
Build strong and lasting relationships with our Clients, ensuring the best services with Quality, Price and excellent Performance.
To have the recognition of our Clients as a Third Party Services Company that delivers services with the best Quality and Expected Time.
• Delivery of results based on Ethics.
GENERAL ETHICAL PRINCIPLES
Equal opportunities and non-discrimination
Guarantee the same opportunities for all employees in the hiring, promotion and other decisions, not tolerating any act of discrimination due to sex, sexual orientation, religion, race, social and cultural status.
respect for people
Respect for the personal dignity of direct and indirect employees must be a priority for the company. It is totally open to diversity, especially in terms of hiring, but we also improve every day to obtain the best practices of inclusion and well-being of LGBTQIA+ people at work, as we do not tolerate acts of discrimination.
Since its inception, Dakron has been concerned with social inclusion, especially regarding the hiring of Persons with Disabilities - PCD for our workforce, which is duly protected in our legal system through LAW No. 13,146, OF JULY 6 OF 2015.
It does not tolerate any forms of sexual and/or moral harassment, intimidation and disrespectful conduct in the work environment.
Respect for the environment
It is the company's commitment to assess all social and environmental impacts that may result from its activities before putting them into operation. Thus, consolidating a preventive approach in relation to socio-environmental impacts.
Personal and professional conduct
It is everyone's duty to collaborate so that the company achieves its objectives, always aiming at extraordinary levels of excellence and overcoming.
Each one must perform their respective functions with professionalism and respect for all others who, in some way, collaborate in the performance of their activities, always looking out for the good social reputation of the company, its customers and suppliers.
Dakron is committed to providing practices and a workplace free from discrimination, harassment or intimidation for any reason, including, without limitation, with respect to race, color, sex, sexual orientation, age, national origin, religion, physical disability or House.
It is the company's duty to provide professional development opportunities to all its employees, based on the meritocracy and commitment of each one.
Conflict of interests
Dakron does not condone conflicting relationships between the organization's businesses and its stakeholders. There is a conflict of interest when professionals use the company, function or internal influence for personal interests or to benefit third parties.
Interest must be understood not only as obtaining any advantage for oneself, whether material or not, but also for family members, friends or counterparties with whom the professional has political, personal or commercial relationships.
There is a conflict of interest in cases of personal or corporate relationship in any line of subordination or in the relationship with customers, suppliers or competitors that compromises impartiality in the business and that may bring benefits to those involved or damages to the organization or even compromise the exemption in the evaluation of performance of those involved.
All situations identified that may involve possible conflicts of interest must be immediately reported to the immediate manager and formalized by the employee through the HR Channel available on the company's Intranet.
Dakron representatives must act in the best interest of the company.
Personal considerations or external relationships must not interfere with the company's interests, therefore, the position held in the company should not be used for the benefit of oneself, relatives or friends.
When identifying an actual or potential conflict, such conflict must be immediately reported to the manager of the place involved, who will be responsible for resolving it.
Additionally, the Collaborator who identifies such real or potential conflict must withdraw from the discussions and must not participate in the decisions about it, unless requested by the manager, in order to provide more details about the case in question and the parties involved, abstaining, however, , of any decision on the matter.
If any Employee who may have a potential private gain resulting from a conflict does not express his/her conflict of interest, any other employee who is aware of the situation must do so.
In this case, the non-voluntary manifestation of the Collaborator in a conflict situation will be considered a violation of this Code of Conduct, Ethics and Conduct.
Dakron will not restrict party political activities and Collaborators who have the right to free association and to join labor, class or other associations of their choice.
The exercise of political activities or membership of any political party is an individual right.
Employees, if affiliated with political parties, must not use their working hours or company resources to carry out party activities.
A Dakron Employee who participates in political activity will do so as a citizen and never as a representative of the Company.
In this way, any political opinion of the Collaborators must never be expressed as a political position of Dakron.
Parental and collateral relationships
For purposes of conflict of interest, the following relationships may be considered:
• Parental and collateral relationships: spouse, common-law partner, parents, grandparents, siblings, children, grandchildren, brothers-in-law, cousins, nephews, uncles, sons-in-law, daughters-in-law, in-laws, stepmother/stepfather and stepchildren.
• Close relationships: those with which a corporate bond, affective relationship or habitual coexistence is maintained, whether through love or friendship, in which there may be an interest in benefiting the other.
• Relationship with other Dakron professionals where there is hierarchical subordination or when the independence of those involved is compromised.
• Relationship with professionals from companies controlled by Dakron, shareholders/partners and/or investors, business partners (such as banks), suppliers or competitors, in strategic positions, that is, managers or employees who have access to sensitive information;
• Relationship with Dakron's customers.
Extra-professional activities in the interest of managers, employees, interns and young apprentices may not have an employment relationship, except when the employee teaches classes, and may only be carried out if they do not contradict Dakron's interests.
In addition, they must be carried out outside the contracted working hours, as well as outside the Company's premises.
Volunteering, corporate actions, lectures with business motivations and teaching classes are allowed, as long as the content does not expose the company's strategy or performance.
If the content is related to Dakron, it must be approved by Senior Management before use.
PRACTICES AND BUSINESS
All those who act on Dakron's behalf must do so in accordance with the highest standards of integrity, loyalty, honesty and ethics, not engaging in conduct that is inappropriate or inappropriate in a professional business environment.
Any type of donation (including products, services or any type of gift) received from companies, suppliers, service providers and customers, may be accepted, provided that the requirements set out in 3.5.1 are cumulatively observed.
Acceptance and offer of gifts/courtesy
Dakron is against the acceptance and direct and indirect offer of gifts/courtesy that may affect decisions, facilitate business or benefit third parties. Acceptance and offer depend on usual market practices, however, anything that could influence impartiality in any negotiations should be avoided.
• Gifts - Gifts are objects or materials of no commercial value and of low unit value, personalized with the company's brand (such as pens, notebooks, diaries, calendars, etc.). The acceptance and offer of gifts is allowed, as long as it does not constitute a conflict of interest and does not fit into the situations prohibited in this Code.
• Gifts-Gifts are objects or materials with commercial value, received or offered as a courtesy, which do not qualify as gifts. In general, they should be avoided or limited to half the value of the national minimum wage in force on the respective date.
If the amount exceeds the established limit and it is not possible to refuse the gift, the employee must forward it for approval by the Senior Management, and keep a record of the approval (if approved).
• Events - Events are activities linked to marketing and relationship actions such as: branding, products and services (homages, among others); congresses or business forums for the dissemination of technology and techniques, knowledge sharing and networking; and invitations to sporting, cultural or artistic events sponsored by the company that offers them.
The acceptance of events must be previously authorized, by e-mail, by your hierarchical superior and, subsequently, communicated to the Senior Management.
The offer of events is allowed as long as it does not constitute a conflict of interest, does not fit into the situations prohibited in this Code and is part of marketing actions, approved by the Senior Management.
Expenses related to travel, accommodation, food and transportation should preferably be paid by the company that accepts this type of courtesy.
Exceptions must be approved by the immediate superior and analyzed by the Senior Management to ensure that there are no indications of conflicts of interest and deviations from the guidelines provided for in this Code.
Distribution of gifts and raffles of gifts occurred in events, as long as it is not intended to benefit a specific group, is allowed, considering that it does not constitute a conflict of interest.
Expenses aimed at strengthening customer relationships, such as meals, as long as they are for business purposes, are allowed, provided they are reasonable in value and are not prohibited by known business practices of the recipient's organization.
It is prohibited to accept or offer courtesies that:
• Involve Public Administration Bodies or Employees;
• Involve employees in the purchasing sector, with the exception of gifts;
• Whether in cash, check, representative security or equivalent, such as vouchers and gift cards;
• Involve a supplier, customer or partner by participating in a contractual negotiation process;
• Recurringly received from the same person or company; and
• Have a value above the market average of goods/services with similar characteristics.
RELATIONSHIP WITH PUBLIC BODIES, AUTHORITIES AND AUDITS
The Dakron company has a principle of information transparency both for internal and external audits, as well as for authorities and employees of public bodies with which the company maintains a relationship.
Representatives of public bodies, duly identified, must be received in a cordial and professional manner.
Dakron employees are prohibited from accepting and offering, directly or indirectly, to authorities and public agents, any payment in cash, gifts, services, entertainment or any other benefit of any nature.
Invitations to work lunches and dinners, events sponsored by the company, such as technical trips, congresses, seminars or celebrations, provided that the principles of reasonableness, ethics and common sense are respected, constitute an exception to the rule expressed in this section.
Dakron repudiates all forms of corrupt conduct, such as bribery, embezzlement and granting of undue advantages, as well as the concealment or dissimulation of these acts and the impediment to investigation and inspection activities.
You may not offer or deliver, directly or indirectly, any undue advantage, payment, gift or courtesy with the intention of influencing the impartiality of any authority, public servant, employee or executive of companies, in any act or decision in order to obtain benefit. inappropriate for the company.
Likewise, managers, employees, interns and young apprentices and Dakron must not accept undue advantages
Dakron does not accept bribes, kickbacks, or any other improper payment, even if refusing to do so would represent the loss of a business opportunity.
Dakron and its direct and indirect employees are committed to complying with applicable anti-corruption laws and regulations.
Dakron and its employees do not offer money or any other benefit directly, or through third parties, to any government authority or public agent to influence decisions, obtain or retain business or secure an improper advantage.
CONTRIBUTIONS AND AFFILIATIONS TO POLITICAL PARTIES
Dakron does not make contributions or disbursements related to political activities, candidates, politicians or political parties.
Neither is it allowed to use company resources to achieve political goals or use the position it occupies as leverage for those interests.
If employees run for political positions, after proof of candidacy, they must leave the company, without the right to remuneration, during the period between the registration of their candidacy before the Electoral Court and the day following the election.
Dakron works to prevent fraud in all its relationships, in line with current legislation and company values.
The organization repudiates the practice of illegal acts in the exercise of its activities or in any other way directly or indirectly related to it.
In the event of possible deviations, Dakron will investigate the facts and adopt the necessary measures to enforce its rights and values, including administrative sanctions and the filing of legal actions aimed at the civil or criminal liability of the participants.
MONEY LAUNDERING PREVENTION
Dakron does not condone money laundering practices, and all employees must pay special attention to suspicious situations.
Money laundering is the process that aims to hide the origin of illicit resources, as well as their integration into the financial system, with the objective of legitimizing such resources.
In order to avoid problems in this area, attention to suspicious behavior must be intensified by employees in their relationships with customers, suppliers and business partners, so that potential cases are evaluated and, when applicable, reported to Senior Management and/or competent authorities, as the case may be.
Dakron is committed to promoting free competition, market evolution and compliance with competition legislation.
In interactions with competitors, Dakron professionals must not share strategic information, establish agreements or act in a coordinated manner on prices, sales, standardization of contractual clauses, compensation, market division or any commercial strategies for approaching customers or suppliers.
Dakron's managers and employees must pay special attention to working in trade associations that bring together competing companies in terms of exchanging sensitive information, such as price, market strategy, customers, among others.
PRESERVATION AND SECURITY OF INFORMATION
Dakron values information security. Only information officially published by the company can be exposed or discussed with stakeholders, such as suppliers, customers, banks, brands, competitors, among others.
Dakron understands as “official” the information published on the institutional website, in public reports, in official profiles on social networks (if applicable) and in institutional materials.
All audiences with which Dakron interacts are responsible for ensuring the security of information, ensuring that it is stored, processed and transmitted only in secure environments.
It is forbidden to share or send any confidential, strategic and business information using private means such as e-mail, flash drives, cloud storage, among other resources.
This care also applies to sharing information via social media and verbally in public places such as buses, restaurants, bars, airports, planes, stadiums, taxis, among others.
Everyone must protect confidential information belonging to the company or to third parties that may make information available to Dakron, based on the General Data Protection Act (LGPD).
The use of technological resources, access to the internet and electronic mail (e-mail) are intended for the exercise of professional activities and must be used with common sense and prudence.
The Company reserves the right to monitor the use of these resources, whenever it deems necessary, thus objectionable, therefore:
a) use e-mail to send mass messages (spam) with offensive, discriminatory or contrary content to the law or to threaten or harass direct or indirect employees, customers and other interested parties;
b) store personal or third-party files in folders on the internal network;
c) use language, images or files that are offensive, unethical, immoral or induce any form of discrimination;
d) access pornography sites or sites with unethical or immoral content; or
e) use third-party e-mail to send messages.
Dakron reserves the right, at any time and without notice, to block or monitor the use of the internet (or specific websites).
Dakron does not have a record on social networks on the date of issuance of this Code, however, it may have one in the future.
Employees who choose to register on social networks must do so in their own name through private resources.
The publication of opinions must be completely personal, avoiding direct or indirect association with the company.
It is also forbidden to divulge rumors or any opinion that may compromise the image of managers or other employees of the organization.
The social network profiles associated with the company must only be registered and used by the IT area or by persons authorized by the Senior Management.
RESPECT FOR THE FUNDAMENTAL RIGHTS OF CHILDREN AND ADOLESCENTS
Dakron is committed to the rights of children and adolescents.
It is against any form of negligence, discrimination, cruelty, violence, sexual exploitation and pornography in the company's activities, in the use of its products and services and in its value chain.
The organization repudiates child labor and does not condone any situations that potentially involve the irregular work of adolescents under the age of 16 (except when in the condition of apprentices, from the age of 14).
Dakron is against slave labor and situations that potentially involve coercion, punishment on any pretext, degrading disciplinary measures or punishment for exercising any fundamental right.
The organization does not condone such practices in the use of its products and services and in its value chain.
USE OF RESOURCES, ASSETS AND PROPERTIES OF THE ORGANIZATION AND INTERESTED PARTIES
Dakron believes that the working relationship with its employees must be based on integrity, diligence and loyalty to the company's interests in order to avoid wasting resources.
Employees must take care of resources, facilities, equipment, machines, furniture, vehicles, among other work materials.
The organization's assets and resources must not be used to obtain unlawful or undue advantages, either personally or for third parties, directly or indirectly.
Internet and telephone access, as well as the use of e-mails, software, hardware, equipment and other Dakron assets must be restricted to professional activity and, if there is a need for use for private purposes, that the use be made with common sense and aligned with the immediate superior.
The company is entitled to access records of internet usage, e-mail and information stored on the company's computers, mobile and landline telephony.
SECURITY AND SOCIO-ENVIRONMENTAL RESPONSIBILITY
Dakron is committed to sustainable development.
By carrying out its activities, it seeks to ensure the success of the business in the long term, contributing to the construction of a just society, economic development and environmental conservation.
Environmental aspects must be respected during the development cycle of activities, products and services.
It is the duty of all direct and indirect employees to contribute to a safe workplace.
The use of personal protective equipment (PPE) or Collective Protection Equipment (EPC), when applicable, must be used correctly and in accordance with current laws and guidelines in the areas of occupational health and safety.
It is up to managers to supervise other employees and require the use of such equipment, as necessary.
Employees must be committed to carrying out their professional activities, ensuring the preservation of their physical integrity, that of third parties, property and the environment.
Dakron constantly seeks to contribute to the development of society, guiding its work towards actions that bring benefits not only to its companies, but to society as a whole.
Respecting and minimizing the impact of the company's activities on the environment is everyone's duty.
GUIDELINES FOR CONDUCT TO INTERESTED PARTIES
Dakron's commitment is to contribute to the trade associations that represent the public involved in the business, as well as to cherish ethics and the values of free competition and sustainable relationships, maintaining the confidentiality of information.
Banks and financial entities
The organization considers that this relationship must be valued and based on transparency and commitment to results.
It is Dakron's duty to add value and propose improvements in the products and services provided.
Ethics is a non-negotiable attribute and all information must be treated confidentially.
Dakron understands that the shortest way to make its mission a reality is to effectively contribute to the success of its customers.
The organization values the transparency and confidentiality of information, preserving the relationship of trust and harmony with its customers, fulfilling what was contracted and constantly seeking excellence in the provision of services.
Managers, employees in general, interns, young apprentices and outsourced workers
Dakron's relationship with its employees is based on values, ethical principles and labor legislation.
The organization values meritocracy, transparency, open dialogue and recognition of best practices, with inspired employees who make a difference, exposing ideas and perceptions aligned with business planning, in a way that contributes to results.
The guidelines of this Code should be considered as an addendum to the professional contracts signed.
It is the responsibility of each employee to care for Dakron's assets and its stakeholders (when acting on behalf of Dakron outside its facilities) and to take care of the company's image, respecting current legislation.
The attitudes of all managers, employees in general, interns, young apprentices and outsourced workers must reflect the commitment to the company's values and perpetuity.
community and society
Dakron reinforces the company's commitment to contributing to the sustainable development of society.
It is the company's duty to identify opportunities for improvement in processes, products and services in an attempt to minimize the socio-environmental impacts caused by the business.
The organization aims to contribute to public policies defined by all levels of government in order to cooperate with the advancement of Brazilian society.
Dakron respects its competitors and believes that fair competition contributes to the improvement of the market.
Strategic business matters must not be discussed or passed on, under any pretext, to competitors without proper authorization.
Dakron monitors the technological environment and may take inhibitory, preventive and punitive actions, if necessary.
The company is against any comment that could contribute to the spread of rumors about competitors.
Dakron competes lawfully on the merits of its services, consistent with the rules and spirit of antitrust and other laws designed to protect free competition.
Dakron will not enter into formal or informal agreements with its competitors to manipulate prices, bids or allocate markets, customers or suppliers.
Suppliers have a direct influence on the quality of products and services offered to Dakron.
Therefore, the company values the partnership relationship and takes into account what is good for the company, suppliers and other stakeholders involved.
The relationship with suppliers must be characterized by compliance with the precepts of this Code and standards defined in its internal controls.
Dakron practices free competition, transparency and impartiality in the process of contracting suppliers, as well as strict compliance with contracts.
Encouraging good practices, valuing sustainability issues, must be constantly sought.
Supplier practices regarding issues such as the environment, conscious consumption, child and slave labor, sexual exploitation of children and adolescents, social inclusion, compliance with legislation, among others; are considered in the selection of their suppliers.
Government and regulatory bodies
Dakron has a system for monitoring and complying with current legislation, operates in a transparent manner and is interested in contributing to the social and economic development of the country, playing an important role in the Brazilian payment system, for example, in helping to combat tax evasion. and money laundering.
Press and Opinion Leaders
Dakron values the reliability of the information transmitted to the media and guarantees that all comments, statements or pronouncements on behalf of the company are made only by authorized persons.
Dakron, in addition to complying with all the rules established in this Code, everyone who acts on its behalf must do so in compliance with all rules in force and applicable to the Company's activities, including in this concept all rules, regulations and standards of local, national or international scope.
In the event of any doubt, you should opt for abstaining from any act until such doubt is resolved or until there is guidance on the matter by the responsible manager.
MANAGEMENT OF THE CODE OF ETHICS AND COMPLIANCE
To ensure the proper handling of issues inherent to this Code, an Ethics and Compliance Committee is activated (formed by Senior Management, Human Resources and Legal (when necessary)) with the objective of ensuring:
• the constant improvement of the content of this Code;
• that the precepts in this Code are the reference for the organization's management process, that they are respected in the work routines through their dissemination and training of employees; and
• act as the last resort, in situations that are identified as deviations from the principles contained in this guideline.
Managers, employees, interns and young apprentices are responsible for applying the guidelines of this Code in all their professional relationships and must act as guardians, informing any and all situations that may indicate non-compliance with the guidelines/guidelines, under the condition of legal punishment. by the Company.
All professionals must sign the formal adherence to the code.
If there is any doubt about a situation being a deviation from the precepts established in this Code, professionals should, before formalizing the potential deviation, seek guidance from their immediate or mediate manager, the HR department or the workers' representative, or even through from the firstname.lastname@example.org.
If a situation of conflict with the Code of Conduct, Ethics and Compliance is witnessed, even if the employee is not involved, the situation can also be formalized through email@example.com.
The identity must be kept confidential if that is the rapporteur's wish. Dakron values the confidentiality of information and authorship of complaints and must guarantee absolute confidentiality.
CODE ADHERENCE AND MAINTENANCE MANAGEMENT
By acting on the basis of the conduct guidelines, the employee will reinforce the company's ethical principles and contribute to keeping this Code always alive and up to date.
Dakron wants its managers to act in the dissemination and instruction to the employees of its team, regarding the guidelines present in this Code, in order to preserve an ethical and collaborative work environment.
The evaluation and monitoring of adherence to the Code will be guided by communication through the HR Channel.
Any violations of the Code's precepts may result in disciplinary sanctions provided for in legal regulations.
VIOLATIONS AND COMPLAINTS
Violation of any provision of this Code may result in the taking of internal and external measures aimed at punishing the violator and minimizing negative impacts.
Internally, the legal representative will be authorized to take all measures based on law against the violator of any of the provisions of this Code, and such punishments may consist of a verbal or written warning to dismissal or termination of the contractual relationship for just cause.
In the external sphere, the legal representative will be responsible for taking all measures provided for by law in order to minimize the negative impacts to which the company and/or its interested parties and its management may be subject as a result of a breach of this Code, and such measures may consist from judicial measures to the indication of the violator to the competent authorities in judicial, arbitration or administrative proceedings involving the violating act.
In case of doubts related to this Code, interested parties must register their findings through the email firstname.lastname@example.org.
The information registered by the email email@example.com must be used by a professional specially designated for the investigation of the facts.
This professional must be trained according to the nature and origin of the potential ethical misconduct.
Top Management deliberates on violations and disciplinary sanctions.
The management of reports must be carried out considering:
• the confidentiality of the investigation will be strictly maintained;
• anonymity will be guaranteed to those who wish to do so;
• investigation will be conducted impartially and independently;
• complaints or accusations without a consistent basis will be disregarded;
• reports or accusations made in bad faith intended to harm someone will be subject to disciplinary sanctions; and
• Disciplinary sanctions are provided against any attempt at retaliation, as required by law.
This Code enters into force as of its communication and will remain in force for an indefinite period. It must be subjected to periodic analysis to ensure its suitability and relevance.
• DKN-PL-01-SGI Policy
• Legnet-Legal requirements management software
• Institutional website
• Data sharing network
• ANNEX I – Term of Acceptance of the Code of Ethics and Compliance
• ANNEX II - Term of secrecy and confidentiality
• Annex III - Equity Liability Term - Rev.00
• ANNEX III - LGPD Concession Term
Date Version Summary
Initial issue of the document.
Role Name Position Signature Date
Edson Luiz Pereira
Cleide L. de Carvalho
Code: Revision: Date: Developer: Approver: DK-DC-03 00 11/29/2021
Edson Luiz Pereira