Code of Ethics and Conduct

GUEP has a Code of Ethics and Conduct that aims to consolidate our principles and values ​​and serve as a guide for our professional actions, within our organizational environment and in relations with customers, suppliers and business partners.

The commitments below reveal GUEP's way of thinking, seeing and acting.

2.1 COMPLIANCE WITH THE LAW It is our duty to follow all laws and regulations applicable to our activities and operations.

At GUEP we do not prohibit offering or receiving business courtesies. We believe that they are a valid means of strengthening relationships. However, the value of these courtesies must be reasonable. No GUEP employee is allowed to accept anything extravagant or exaggerated, as well as offering or accepting cash. Redoubled attention is required when dealing with government officials, as it is a different public and with very specific rules, it may be illegal to offer or receive anything.

Justice and Integrity are fundamental to sustainable business growth. GUEP does not maintain its business through unethical means, using instruments such as bribes, kickbacks or other corrupt payments. It is illegal to offer, promise, give or accept any undue advantage or anything of value to any business partner, especially to Government officials, in their various instances, who may influence them and constitute an act of corruption or analogous TO corruption in accordance with with ARTICLE 5 OF BRAZILLIAN LAW 12.846 / 2013. GUEP always acts diligently and is adamantly against all forms of corruption and financial crimes, money laundering, fraud and financing of illegal actions, whether in our value chain, clients and suppliers, or in government agencies and regulators.

All employees have the responsibility to make decisions that are in GUEP's best interest, and so they must act with integrity, avoiding conflicts of interest, real or apparent, between their responsibilities and their personal and professional activities. Conflicts of interest can happen in professional relationships, in kinship relationships between company professionals, in customer relationships and in the use of confidential information. All GUEP employees are prohibited from: Use the employment relationship with GUEP to obtain benefits for yourself or someone else in your relationship. Examples: being the manager responsible for hiring relatives or own private companies; take advantage of the work environment for the sale of goods without express authorization, among others. Hire relatives, suppliers or service providers with whom there are conflicts of interest. Examples: hiring a father, mother, sons or daughters, siblings, spouses, uncles, aunts or cousins ​​under the same management or in functions in which one relative controls the other; hire companies whose controllers or directors are related to the person responsible for hiring; Accumulate conflicting functions. Examples: being responsible for simultaneously executing and controlling tasks; be responsible for the management of proprietary and third party resources; having access to privileged information and influencing the market; having private businesses that compete with GUEP or interfere with working time, etc .; Request from collaborators private services, not related to their functions; Make or apply for cash loans to co-workers. Such a situation can generate conflicts and interfere with the continuity of the work.

Information is one of the most important assets for GUEP, so we treat any information that is not publicly known as confidential. We never disclose information outside the company without express approval.

GUEP prohibits the use of privileged information by its employees, trading in shares or other securities held by non-public information is not allowed. The use of insider information is illegal.

GUEP does not tolerate discrimination of any kind, whether by color, age, gender, disability, religion, sexual orientation or other characteristics provided for and protected by law. Managers have a direct responsibility to ensure a fair and respectful work environment that promotes equal opportunities.

All GUEP employees must base their actions on respect for others. This is a fundamental issue for creating a productive and inclusive work environment. GUEP does not tolerate conduct that shows psychological violence, exposure to humiliating situations or embarrassment and is and is expressly contrary to any action or attitude that can be characterized as harassment.

GUEP repudiates any form of slave and child labor or similar to slavery and we are committed to refusing or not to do business with suppliers, partners or customers who use these expedients.

If you identify a GUEP employee acting in a manner different from that contained in our Code of Ethics, report it through one of the channels below. The complaint will be treated anonymously and confidentially. E-mail: Telephone: +55 11 44527101 - Legal and Compliance Guep Soluções Corporativas S / A