This Code of Ethics applies directly to all employees and reflects our values and our culture. Compliance reveals a commitment to professionalism and transparency in all of our workplace activities.

codigo de etica

Values

Commitment is one of the most important values for the growth and proper functioning of a company. Therefore, it is essential that every employee acts and thinks as if he or she owned the business – on a daily basis, sharing responsibilities, contributing ideas and caring for the improvement and development of the Company’s processes.

Orientation

We are oriented to service both internal and external clients, building and maintaining effective personal and professional relationships with them. We constantly seek options that will improve the services and products offered and achieve the highest levels of satisfaction.

Knowing Our Business

Through a profound understanding of our market and acting as a leader, we have the flexibility to respond quickly to changing needs.

Teamwork

In our work within each business unit and for CSU as a whole, we seek to be highly integrated and results-oriented, building interpersonal relationships based on mutual trust and respect.

Workplace Environment

Creating and maintaining a pleasant working environment depends on everyone’s participation. Therefore, it is important to note how the attitudes we adopt influence others. We need to act professionally, ethically and with respect, contributing to the climate around us. To guide our employees towards proper workplace attitudes, CSU has developed standards that must be strictly adhered to. Thus, we have set forth that those who work for CSU may not:

  • Be involved in any other trade or participate in partisan political or religious campaigns while working within the Company.
  • Be inadequately focused while attending meetings, training sessions, negotiations and other company events (i.e. becoming distracted, skipping out during meetings, leaving phones unanswered). This reinforces the importance of exhibiting a professional comportment to the marketplace.
  • Be verbally or physical aggressive with colleagues, inside or outside of the company.
  • Hire 1st and 2nd degree family members or other such relatives:, i.e. mother, father, siblings, spouse/partner, cousins, aunts, uncles, etc.
  • Engage in activities that involve the manipulation of data, tampering with or forging documents.
  • Misuse or vandalize company property. Employees are responsible for their maintenance and preservation.
  • Engage in any type of discrimination.
  • Be under the influence of drugs or alcohol while on duty, inside or outside CSU premises.
  • Engage in any action that may be considered bullying. If such behavior is suspected, employees are encouraged to inform the Personnel and Management department.
Conflicts of Interest

These include situations such as an individual or family member (i.e.relatives of 1st and 2nd rows: mother, father, siblings, spouse/partner, cousins, aunts, uncles, etc.) participating in the business of suppliers, the Company’s partners or organizations that will be negotiating with CSU.

Excellence

The pursuit of excellence is what leads to the constant improvement of individuals and companies. CSU believes in offering ongoing incentives to its employees to encourage them to always exceed limitations and surmount new challenges.

Ethical Principles

Because CSU believes that appreciation and respect for individuals is one of the paths to the evolution of business and society, the company is guided by ethical principles in its daily activities.

CSU’s Quality Policy

Through its creative and effective solutions, CSU provides products and services that serve the needs and exceed the expectations of its customers.

Our Culture

Knowledge of CSU’s Culture is the first step to understanding its Code of Ethics. CSU’s Culture is the manner by which CSU employees work, day by day, within the Company.
And as part of our culture, we have employees with the skills we value most, which directly impacts their performance in the Company.

Competencies

A particular set of behaviors, skills and attitudes can generate better results within an organizational culture.

Think and Act Like a Business Owner

Our employees should demonstrate pride in being a part of CSU. Be as committed a business owner. Act in the short term without losing sight of the Company’s long-term interests.

CSU Confidentiality

Any exchange of information related to the cCompany or its businesses with the employees of competitors is prohibited.

Employees are to restrict the disclosure of Ccompany facts to the environs of the workplace. They are not to speak about the Ccompany on airplanes, or in taxis, restaurants or bars, as one never knows who may overhear such comments.

Employees are not to disclose, internally or externally, any type of unofficial information (rumors).

Employees are prohibited from removing, from the Ccompany’s premises, internal CSU materials that include information about the CSUcompany’s operations, even if a given employee has participated in the development of the same. Examples include copies of documents, electronic files or other confidential material, as well as data related to customers, suppliers and partners that addressed their area of expertise activities.

Employees are to destroy, as appropriate, hard copies of documents and to keep desks clean and paper-free, with file drawers and cabinets properly locked.

CSU ‘s People

Our people are the company’s greatest asset.

Employee commitment is critical to ensuring productivity and efficiency in the services offered by CSU. It’s also very important for the development and professional success of all.

Accordingly, the following attitudes and behaviors should be adopted:

Punctuality throughout the work week.

Visibly displaying one’s ID badge while on CSU premises.

Protection of CSU’s image. If one is wearing clothing bearing the company’s logo, one should avoid improper behavior in public.

Take care in the use of the Company’s materials, documents and general assets, being sure to use them for appropriate activities.

Respect those members of the public one encounters in the course of conducting CSU business – workplace colleagues, customers, suppliers, investors, financial institutions, local communities and government.

Customers

Maintaining good relationships with all of our stakeholders and, in particular, our customers, is essential to the growth of our Ccompany. Therefore, it is important that everyone has an ethical and responsible attitude, ensuring cordiality, clarity, sincerity and flexibility in the exchange of information.

It is important to always remember that:

  • Customers are the reason our Ccompany exists and we must treat them with courtesy, efficiency and sincerity.
  • Being open-minded to Rreceivinge their suggestions well is a good way helps to strengthen relationships with them.
  • Speed, flexibility, quality and appropriate responses are all a part of a good service.
  • If clients request to use the name of the CSU group in external communication channels, those requests should be directed to the Ccompany’s PressMedia Relations department.
Partners/Suppliers

Quality work is directly connected to competence and a good relationship with suppliers. Therefore, it is important to establish a strong partnership with them, based on respect, ethics and professionalism. For this to occur, it must be clear that:

  • Before any work begins, the Ccompany’s Sales area should be involved in contracting.
  • By encouraging continuous improvement in the work of our suppliers, it will enrich the relationship and bring improvements to our services.
  • Our Ccompany encourages partners and suppliers to adopt management practices that respect human dignity and ethics.
  • CSU seeks out people and companies that are aligned with the ethical standards of our Company.
Shareholders

CSU shareholders and investors are betting on the cCompany’s future. Accordingly, it is important to know that:

  • When shareholders or investors make a request for any type of communication, this should be passed along to the Investor Relations department, which is prepared to communicate information about the Ccompany’s activities and performance in a manner that is appropriate, accurate, transparent and secure.
  • Caution should be exercised to protect the security and confidentiality of information that is not yet public knowledge, and thatwhich may affect the value of the Ccompany’s shares or influence the movements of the market or investors’ decisions.
  • CSU’s rules related to its Disclosure policies and Securities Trading have been constructed to assist in the conduct of the company’s officers and employees.
Government Agencies and Regulators

As a part of the society, CSU contributes to justice and democracy by engaging in the following norms of conduct:

  • Being aware of and obeying the rules and laws.
  • Disallowing the contribution, donation or provision of favors or the sending of gifts to public institutions or officials as a means of soliciting favors.
Press

The Company maintains a transparent relationship with the press, communicating confidence in our information and veracity of the facts provided. Nevertheless, it is important to highlight some recommendations:

  • Information is not to be passed along to the press, nor interviews granted without prior permission from the Company’s PressMedia Relations departmentivision.
  • If an employee is contacted by a member of the press, this should be forwarded along to the PressMedia Relations department, which is best prepared to handle such requests.
  • Partners and suppliers should be directed to not disclose information to the press about any project that is in the process of being carried out. No service provider is permitted to speak on behalf of CSU without the prior authorization of the contracting area and the PressMedia Relations departmentivision.
  • CSU personnel should be properly informed about procedures related to the press.
  • When any incorrect data or news has been published that impacts CSU’s image, the PressMedia Relations department should be made aware of this immediately.
  • When contacted by the media for interviews related to an employee’s personal life, individuals should not expose the name of the company nor associate the image of CSU with their opinions.
Contact

PressMedia Relations: ML&A Comunicações Approach Comunicação
Ademir Morata Nara Neri
Tel: +55-11-3811-2823 / 3147-7402 / 8980-2538

Community/Environment

CSU considers the community to be among its stakeholders. Accordingly, the Ccompany plans activities to contribute to the growth of the community through a variety of means.

Through the CSU Institute, the Ccompany is responsible for the development and support of social activities whose goal is to provide comprehensive training to young people and adults who are served by the Institute.

Develop, promote and support social awareness and education in partnership with customers, suppliers, employees and community programs.

Promote, in our day-to-day activities, campaigns for the conscientious use of resources, eliminating waste and preserving nature.

The Ccompany does not tolerate child labor or any form of exploitative work in our business or by our suppliers or partners.

We are concerned about the safety of our people and we ensure the protection of our employees through the proper use of equipment and the implementation of protective measures.

Competitors

Treating competition in a responsible and ethical manner is key to the image and growth of any company.

In this regard, the principal behaviors that CSU employees will engage in are:

  • Be ethical. Do not make any third party comments that might damage the image and business of the competition, or its customers.
  • Have integrity.
  • Do not participate in any activity that might be construed as being anti-competitive, monopolistic or contrary to the laws, national or local, which regulate competitive practices in the market.
Violation of the Code of Ethics

Any breach of the Code of Ethics must immediately be reported to the Personnel and Management area.

Failure to follow the rules and regulations outlined in the Code, the falsification of records or any other behavior that represents a lack of ethics can lead to severe disciplinary action, including termination of the employee and legal action being taken.

Recommendations

Gifts and Payments

It is prohibited for CSU employees to receive gifts from customers, suppliers, partners, shareholders, investors and competitors or from individuals seeking to have a relationship with the Ccompany.

It is also forbidden to use the name of the CSU in conversations with customers for their own benefit.Exceptions:

  • Acceptable are those items considered to be a part of standard business practices, which have symbolic values of up to R$ 25.00 (twenty -five Brazilian reails).
  • If an employee receives a gift, a thank you note should be sent, along with an explanation that, in accordance with CSU’s Code of Ethics, acceptance of such a gift is prohibited. If possible, the gift should then be returned. Another suggestion is to donate the gift to a non-governmental institution, which has been approved by the Personnel and Management division .in that employee’s locality.