Code of Ethics and Conduct
Contributors
Work Environment
Relationships in the workplace must be aligned with AMAGGI’s values and be guided by mutual respect, maintaining the commitment to establishing an environment favorable to contributors job satisfaction, in a productive work environment, healthy, safe and with freedom of speech.
Managers, in addition to their function of guiding people, also account for educational activities related to ethics and conduct in the workplace. AMAGGI does not allow, under any circumstances, the use of one’s position to request personal favors from contributors.
Each person has their own values. It is important, to represent or defend AMAGGI’s interests, that contributors align their values with corporate values, observing the ethical principles and compliance with existing laws and regulations. If there is an incompatibility between one’s own values and corporate values, the provisions of this Code shall prevail.
WHO IS RESPONSIBLE FOR THE ETHICAL STANDARDS OF THE COMPANY?
All contributors are responsible. Every day, we represent AMAGGI and contribute and impact in relations with customers, suppliers, colleagues and the communities in which we operate. Every interaction is an opportunity to demonstrate that ethical conduct is essential to our success.
Gifts, prizes, presents and entertainment
Campaigns, presents or gifts, all institutional, that constitute the practice of kindness and cordiality between business partners and that are not characterized as obtaining benefits in any negotiations can be accepted by contributors, provided that the sum of all gifts received by the contributor does not exceed, annually, the amount of R$ 300.00 (three hundred Brazilian Reais) or equivalent currency.
Items above the stipulated value should be allocated as follows:
1) If the company can make use of this in their activities, the allocation and use shall be determined by the Area Manager that received the item and authorized by the Area Director.
2) If the company cannot use this in their activities, it should be referred to the Communications Department in order to include this item in an annual draw for all AMAGGI contributors. In the case Code of perishable items, they must be immediately drawn between contributors of the area that received them.
In both cases mentioned above, the result should be reported to the Ethics and Conduct Committee for proper registration.
Entertainment sponsored and/or promoted by third parties, with costs borne by customers, suppliers and other stakeholders, may be accepted when there is a real opportunity for development and/or maintenance of AMAGGI commercial relationships, where they have also been extended to professionals from other companies, and subject to the following: (1) the applicant must justify and request written authorization from the Area Director, informing all of event’s data, explain which is the opportunity for the development and/or maintenance of AMAGGI’s business relationships and what other companies will participate; (2) only after the authorization of the Area Director the contributor may confirm their participation. Should any doubts arise from the contributor or the Area Director, an inquiry can be made to the Ethics and Conduct Committee to be clarified.
It is forbidden to offer and/or receive cash for any reason. It is forbidden to offer and/or accept payments, services or benefits that have the purpose of influencing any contributor or AMAGGI on any trade negotiation.
Support for conferences, sponsorships and other events must follow the rules set forth in the applicable rules and procedures.
Objects received as a prize, directly or indirectly, in AMAGGI’s honor or distinction should be reported to the Communications Department to be dealt with and placed accordingly.
A SUPPLIER OFFERED ME A YEAR-END TRIP AFTER A CONTRACT WAS CLOSED. CAN I ACCEPT IT?
Our Code sets out the rules for receiving presents and institutional gifts from suppliers and customers. In the case of travel, it must be sent to the Communications Department to be included in an annual draw for all AMAGGI contributors. And in addition, it should be reported to the Ethics and Conduct Committee for proper registration.
For other conditions and details, consult the Group’s Code of Ethics and Conduct.
Political activities
Contributors shall not exercise any political activity in the workplace and/or during working hours, such as expression of political preferences and/or party, carrying out political campaigns, and any other activities as such that are incompatible with AMAGGI’s work environment and the purpose of one’s function.
AMAGGI does not authorize the support and participation in political campaigns or activities and/or party organization using AMAGGI’s name and prestige, even when out of office and working hours, without the permission of the Board. The use of any company assets for political purposes, including the use of election campaign materials, is also prohibited.
All contact on behalf of AMAGGI involving people, entities or public institutions must be previously authorized by the CEO.
Support, contributions, collaborations and donations involving people, entities or public institutions must be first assessed by the legal department, to verify if it is in accordance with the current legislation. After legality is confirmed, it must be authorized by the CEO, with respect for all legal requirements.
Legal Union
All contributors have the right to a labor union association and the right to collective bargaining. AMAGGI recognizes trade unions as legal representatives of union members and seeks constant dialogue. Negotiations and dialogue with those partners should be made only by persons formally authorized for such purpose.
Conflict of Interests
Conflict of interest exists when contributors use their influence or commit acts in order to benefit private interests that are contrary to AMAGGI’s interests or which may cause damage or loss to the company.
Arranging corporate commitments or relationships is not accepted, through contributors or their family members, with suppliers or competitors of AMAGGI’s companies, if the position the contributor holds gives them the ability to influence transactions or allow access to privileged information.
The occupation of any position in external entities by any of the contributors must also first be evaluated for possible conflicts of interest.
The evaluation of whether or not a conflict of interest exists observes the following procedure: (1) the contributor must inform the Area Director in writing, acts and facts he/she wants to practice that may constitute a possible conflict of interest; only after the authorization of the Area Director the contributor may confirm their participation. Should any doubts arise from the contributor or the Area Director, an inquiry can be made to the Ethics and Conduct Committee to be clarified.
The intention of hiring, transferring or promoting people with any degree of personal relationship to the same area or areas directly-linked should be informed by Human Resources and/ or immediate manager to the Area Director, CEO or Chairman of the Board for approval, according to the hierarchical level of the vacancy. Should any doubts arise from the contributor or the Conflict of interests Area Director; an inquiry can be made to the Ethics and Conduct Committee to be clarified.
The realization of external professional activities in parallel to one’s activity at AMAGGI, except of academic nature, is only allowed with the consent of the Area Supervisor and Area Director.
IN ADDITION TO THE ACTIVITY I PERFORM AT AMAGGI, I TEACH AT A COLLEGE. IS THERE A PROBLEM?
This is not a problem, since you do not disclose any information on AMAGGI through your classes. Moreover, AMAGGI does not allow the development of any activity that may conflict with your work schedule or with specific features of those activities delegated to you. The use of confidential and strategic information obtained through one’s role in the company as well as the use of any resources and working hours cannot be directed to carry out any activities other than that for which one was hired.
External Conduct
Contributors must be judicious with their conduct in public places, as well as social networks, whether in situations linked to their professional or personal activities, and always act with prudence and zeal. All business trips made by contributors must follow those rules set forth in the applicable rules and procedures.
Both in internal and external environments, such as participation in training, events or other situations, contributors should behave according to AMAGGI’s values and corporate image.
In lectures, presentations at public events, information confidentiality regarding AMAGGI must be respected.
Presentations and representations of events must be authorized by the immediate manager and must follow the official layout provided by the Communication Department.
Harassment and abuse of power
AMAGGI does not admit any kind of harassment, such as sexual, economic, moral or otherwise, as well as situations that constitute disrespect, intimidation or threats in the relation between contributors, regardless of their ierarchical level.
Any contributor who considers himself/herself discriminated, target to prejudices and abuse or in a disrespectful situation should report to their immediate manager and/or the Ethics and Conduct Committee, through any of the access channels. It is a duty of the manager who receives the complaint to formalize such to the Committee so that together they can assess the best course of action.
Strategic and privileged information
Contributors must maintain the confidentiality of any information that is privileged, strategic or relating to relevant facts, to which they have access and which have not yet been publicly disclosed except when authorized by the board or required by law. This obligation should be maintained even after the termination of an employment relationship.
Strategic and privileged information cover also all non-public information that might be useful to competitors or could cause injury or damage to AMAGGI if disclosed, such as financial data, information on customers, suppliers, and contributors, market strategy, costs, technical data, equipment and machinery, internal technology system, computer software, confidential documents, among others.
Leader´s commitment
Any leader is responsible for creating and maintaining a healthy work environment that encourages contributors and contributes to improve productivity and quality of life and well being.
Any leader must be an example of conduct and professionalism to his/her contributors. Leaders should encourage and enhance the personal and professional development of all of his/her staff, through the evaluation and recognition of each contributors conduct as well as the investment in training and qualification activities.
Use of information technology equipment
Electronic information systems and computer equipment and telephones are provided as tools to allow contributors to better perform their duties and for the exclusive use of the activities of AMAGGI’s interests, following current rules and procedures.
Internal or external disclosure of any messages containing information that is not related to business activities is strictly forbidden, as it is expressly prohibited the posting of pornographic and discriminatory messages or any other affront established in AMAGGI’s current Code of Ethics and Conduct and Values.
It is forbidden to release, exchange, and share or provide one’s personal password.
Information contained in all computer equipment and telephones provided by AMAGGI can be accessed and monitored, since they can only be used exclusively in the interest of AMAGGI’s activities.
Prejudice and discrimination
AMAGGI repudiates all forms of discrimination and does not accept attitudes guided by prejudice related to origin, religion, culture, color, race, gender, sexual orientation, social class, age, marital status, union ideology, political position and disability of any nature.
Respectful, friendly, fair and adequate treatment should be given to all contributors, regardless of their position and/or function.
For the processes of recruitment, hiring, promotion and internal transfers, people are assessed only on their skills in relation to the profile required for filling a specific position.
OFTEN IN MY AREA COMMENTS ABOUT RACE, HOMOSEXUALITY AND RELIGION ARISE. CAN THESE TYPES OF COMMENTS AND/OR JOKES BE CONSIDERED DISCRIMINATORY?
Yes, the conduct can be considered discriminatory and create a hostile work environment, even if colleagues did not intend to offend anyone. Contributors should not make jokes, derogatory and malicious comments; create nicknames or make any offensive reference in relation to race, color, age, sex, religion, marital status, place of
origin, disability, sexual orientation and/or physical appearance.
Use of the group´s patrimony
AMAGGI’s patrimony, including its assets and resources such as cars, motorcycles, trucks, tugboats, harvesters, computers, cell phones, among others, is intended for exclusive use in its operations, with contributors responsible for their proper use and maintenance. Any of AMAGGI’s resources and patrimony must be used in accordance to the current rules and procedures.
Confidential information and registration data
All contributors must preserve and deal with confidentiality any information and registration information related to customers, suppliers, contributors, service providers and other partners, obtained as a result of a business relationship. All information provided should follow the current rules and procedures.
Information relating to third parties may only be given with prior written consent or upon request from national public authorities.
Breach of confidentiality of information may be subject to specific legal or regulatory provisions. In these cases, the legal department should be consulted to carry out a thorough analysis and pass the necessary guidance.
Occupation health and safety
AMAGGI provides safe working conditions and promotes awareness and training activities to all contributors in relation to this topic. All contributors and companies providing contracted services have an obligation to meet the health and safety standards and procedures, as well as not to expose oneself to a situation of risk, properly use protective equipment and work for the prevention of accidents. Report unsafe situations that one has identified and seek their resolution are examples of this commitment.
No emergency, production or economic results can be used as justification for exposing contributors, contractors and the community to any risk.
I HAVE JUST IDENTIFIED AN UNSAFE SITUATION IN MY AREA. HOW SHOULD I ACT ON A VIOLATION OF RULES, AND HEALTH AND SAFETY WORK PROCEDURES?
If the situation presents a risk of accident, the action must be immediate and the manager must be notified. The manager and the Health and Safety Department staff are the closest resources to the fact and able to take immediate action to avoid accidents. It is for all contributors to comply with the requirements established for work performance, as it is for AMAGGI to provide safety equipment.
Alcohol, drug, gun possession and gambling
AMAGGI does not allow, under any circumstances, in the workplace, possession of firearms and bladed weapons, or the conducting of gambling. Likewise it does not allow possession or consumption of alcohol, drugs or any other equivalent substance in the workplace and it does not allow work to be conducted under the effect of the same.
The sale, use or possession of illegal drugs exposes its practitioner to the penalties of law. Weapons may be allowed only to duly registered security professionals and during the exercise of their function.
Environment
AMAGGI is committed to constantly keeping its Environmental Management System and Policy appropriate to its size and complexity of its operations in order to prevent damage and environmental costs that can directly impact the quality of life of contributors, the community, and especially future generations.
Commitment to the preservation and restoration of the environment is encouraged and stimulated by AMAGGI among its partners. All contributors and companies providing contracted services have the obligation to follow environmental legislation and comply with the prevailing rules and procedures, as well as not to expose AMAGGI and communities to any risk situation. Report situations that one has identified and seek their resolution are examples of this commitment.
Suppliers and business partners
Relationships with suppliers and business partners are based on mutual respect and ethics. The selection and contracting are based on technical, professional, business conditions, term and quality, as well as the requirement to comply with all and any legal matter, labor, environmental and safety at work. On equal terms with respect to the selection and contracting criteria, AMAGGI will choose to support the development of local suppliers.
AMAGGI requires from its suppliers and partners, ethical action and repudiates slave or degrading labor, corrupt practices, child labor, unfair competition and other practices contrary to the principles set forth in this Code of Ethics and Conduct and set out in the Institutional Commitments established with society, at any stage of its value chain.
Community
AMAGGI’s relationship with the communities in which it operates is based on respect, transparency and sustainable development. Communication and dialogue with these communities are in constant improvement, in order to assess, prevent, minimize, control and monitor the positive and negative impacts of their business activities characteristics.
André and Lucia Maggi Foundation is responsible for external social action and AMAGGI’s private social investment, through direct execution of projects, programs and social activities as well as supporting local institutions. All social investments take into account the local and human development and the respect for diversity. Contributors are agents of transformation of communities and, therefore, are encouraged to carry out voluntary work, either personally or in partnership with the André and Lucia Maggi Foundation.
Competitors
Competitiveness in business is based on planning, negotiation skills and ethical management. AMAGGI disclaims any unfair competition and considers serious misconduct any comments that discredit competitors, who deserve the same dignified and respectful treatment that AMAGGI expects to receive.
Customers
AMAGGI meets the needs of its customers with respect and transparency, ensuring reliability and confidentiality of any information provided and by maintaining and respecting all agreements and contracts, within the required standards.
The negotiations are conducted in an ethical, organized manner, preserving the confidentiality of business information, respecting current rules and laws to maintain a lasting relationship and mutual trust. Discounts, rebates, credits and subsidies of any kind can be offered to customers, provided they are in accordance with current legislations, with internal procedures and are competitively justified and documented.
Government and government bodies
The Group’s relations with the government or public authorities are based on transparency and ethics, to ensure the construction of intact and contributory relations.
Representatives of public agencies receive professional and free treatment, thus being available to them whenever information, data and relevant records are requested and required by law.
AMAGGI does not allow any act that may be configured as bribery, Government and government bodies corruption, favoritism, extortion, bribe, graft, administrative misconduct, fraud in public bidding, crimes against the economic and taxable order.
In the exercise of its activities AMAGGI commits not to promise, offer or give, directly or indirectly, undue advantage to a public servant, or a third party to them related, nor finance, sponsor or otherwise subsidize the practice or conduct any of the unlawful acts on behalf or for the benefit, exclusive or otherwise, direct or indirect of AMAGGI, and commits not to use a third party or entity, to conceal or disguise their real interests or the identity of the beneficiaries of the illicit acts practiced.
Also, commit to observe and make sure its contributors, intermediaries and agents perform their activities/duties in an ethical, fair and responsible manner, observing and complying with all applicable laws and regulations including, but not limited to any other anti-corruption laws in the countries where AMAGGI exercises activities.
It is the duty of all contributors of the Group to know and comply with the country’s current legislation, applicable to their activities, as well as meet current standards and procedures.
Media and press
Advertising and propaganda follow the ethical principles, legislation, current professional codes and standards of local and international references. All operations are conducted with transparency, truthfulness and respect to all involved.
Any and all internal or external promotional material must be approved by the Communications Department and follow current rules and procedures.
AMAGGI maintains a relationship based on respect to the media and the press, ensuring a relationship of trust with the media.
Any representation and/or statement to the press on AMAGGI’s behalf, as well as requests for interviews, recordings through photographs, films, research and information related to the AMAGGI’s activities must be previously authorized by the Communications Department.
Access channels
The established channels are intended to receive internal and external reports on violations of AMAGGI’s Code of Ethics and Conduct. Total secrecy and confidentiality are ensured to those who come forth:
a) Through the report channel through the telephone
Brazil: 0800-647-0004
Argentina: 0800-222-1019
Paraguay: 009-800-5420160
b) Electronic access by e-mail:
comite.etica@amaggi.com.br.
c) Electronic Access through AMAGGI’s website:
“Contact Us”.
CAN ONE CONTACT THE ETHICS COMMITTEE AND/OR THE CORPORATE SECURITY DEPARTMENT TO ASK FOR CLARIFICATION ON ANY ITEMS OF THE CODE OF ETHICS THAT ONE DOES NOT QUITE UNDERSTAND? WILL THE CONFIDENTIALITY OF MY QUESTION BE GUARANTEED?
Yes, it is a right and duty of all contributors to seek clarification of their doubts. All contact directed to the Ethics Committee and/or the Corporate Security department is kept in absolute secrecy.
