CAF Code of Business Conduct and Ethics

Guiding Principles 

CAF.IO (“CAF” or the “Company”) conducts its business in compliance with the law and in accordance with a rigorous standard of business ethics. 

CAF’s Code of Business Conduct and Ethics (“Code”) speaks to our values and policies and sets out the set of behaviors to which members of the organization are required to adhere.

Basis for the Code 

Our Code sets out the terms and conditions which ensure we act ethically and in accordance with the applicable law and regulations. It sets forth our core standards and describes the values and ethical conduct required of all CAF personnel. 

The Code also contains guides our day-to-day behaviours.  Although the Code does not speak to or address every possible issue, it provides a basis to ensure continued proper and ethical conduct.  

Application of the Code 

Our Code applies to all CAF personnel, be they CAF Personnel, contractors, or directors (collectively “CAF Personnel”). The Code also applies to all CAF subsidiaries and affiliates.

Adherence to the Code 

All CAF Personnel must comply with the Code.  This includes taking the following steps: responsibilities include:

  • Familiarizing her/himself with the content of the Code;
  • Each year, certifying that s/he has adhered to the requirements set out in the Code;
  • Complying with the terms and conditions of the Code;
  • Escalating known violation of the Code to the appropriate individuals within CAF; and
  • Cooperating with any investigation of issues related to the code.

Scope of the Code 

While CAF is based in Brazil, there are CAF Personnel and CAF customers located in various parts of the world.  As mentioned above, the Code applies to all CAF Personnel, no matter where they are located.   CAF Personnel are expected to familiarize themselves with the key laws and regulations related to her/his jurisdiction.  Questions or concerns can be sent to the CAF legal and compliance organization.

Legal Compliance

Compliance with applicable laws is an essential aspect of our ethical standards. By virtue of its operations, CAF is subject to legal requirements that are as numerous as they are complex.

Violation of the Laws can seriously damage the reputation of the Company and its CAF Personnel, even subjecting them to legal proceedings. Leadership must fully support each employee in this responsibility and provide the resources necessary for compliance.

Compliance with laws and care for our Company's reputation requires that CAF Personnel engage the following conduct:

  • Fully comply with the applicable laws and other regulatory requirements;
  • Respect diversity of all nature and the personal dignity, privacy and rights of all human beings. Therefore, any kind of discrimination, racism, moral or sexual harassment is prohibited;
  • Maintain and promote the good reputation of CAF;
  • Act transparently, honestly and in the interest of the Company and society's well-being, considering bribery and corruption behaviors unacceptable;
  • Do not promote or engage in any activity that can be characterized as money laundering.

CAF does not tolerate any form of exploitation of child or slave labor on its premises or operations, nor those of its suppliers. Likewise, it repudiates any act that involves prostitution or sexual exploitation.  Any such activities will result in the immediate termination of the CAF Personnel.

Due to the complexity of some laws, questions about any legal obligation should be clarified immediately with CAF's legal team.


CAF’s relationship with competitors must comply, at least, with the following rules and guidelines of behaviour:

  • Ensure fair competition and not engage in activities or business that are harmful to the consumer, the public administration or society;
  • Refrain from
  • retaliating against competitors, colluding on prices, production capacities, market sharing, sales territories or production programs; and
  • demonstrating attitudes that imply unfair competition;
  • Refrain from entering into agreements with competitors that serve to restrict business with suppliers, or present fictitious offers in the context of bids;
  • Refrain from improperly obtaining and using confidential information of competitors.

CAF's success is due to the quality of its products and services, but above all, to the quality of its customer relations. All transactions with customers must be conducted legally, ethically and in good faith.

CAF personnel should be permanently focused on the needs of the customers, with the commitment and will to satisfy them.

CAF Personnel

The ethical and transparency principles that guide our relationships determine, as previously mentioned, that we shall not obtain any advantage through improper use of courtesies or other commercial incentives. A Collaborator is defined as any employee, service provider, supplier, intern, partner or natural or legal person who maintains a legal and/or commercial relationship with CAF (Clients are not classified as Collaborators). Therefore:

  • Moderation and common sense must be used to avoid damage to the reputation of CAF or its CAF Personnel;
  • CAF Personnel must refuse any kind of favour or advantage offered by people or organisations that do or seek to do business with CAF, especially if offered by a public official, with the exception of promotional gifts that have no commercial value and cause no embarrassment to the employee or CAF. Gifts received by an employee must be delivered to CAF's Human Resources department.
  • CAF Personnel performing any type of activity on CAF's physical premises or in its virtual environment must comply with CAF's internal guidelines and respect its policies.

CAF Personnel must act in accordance with the principles outlined below:

  • Comply with all applicable laws;
  • Refrain from engaging in acts of corruption, fraud, money laundering and other illegal acts;
  • Refrain from engaging in the implementation of mechanisms to combat corruption, fraud, money laundering, cartels and other illegal practices in the public administration;
  • Respect the basic human rights of other CAF Personnel;
  • Take responsibility for the health and safety of their CAF Personnel;

Before hiring an employee, CAF must carry out due diligence in accordance with the following minimum criteria:

  • Evaluate the qualifications and reputation of these third parties prior to contracting;
  • Ensure that partners understand and align with our Company's principles;
  • Monitor the activities of partners to ensure that they comply with the principles of ethics and integrity;
  • Refrain from using the partners, under any circumstances, to carry out any illicit activity or that goes against the requirements of these Regulations;
  • Refrain from influencing resale prices and do not impose illegal restrictions on trading counterparties;
  • Comply with additional Due Diligence standards requested by the competent sector or provided in other CAF policies.

Accounting and Financial Statements

The bookkeeping of CAF will be kept in permanent records, in accordance with commercial, tax and corporate regulations and the fundamental principles of accounting.

CAF has accounting control rules and procedures to ensure that assets are protected and used properly, and that records and reports are accurate and reliable. CAF Personnel share responsibility for complying with and maintaining required internal controls.

All CAF Personnel must ensure that accounting records, created by them or under their responsibility, whether financial reports, accounting records, research reports, sales reports, purchase reports, expense accounts and other CAF documents, are complete, accurate, honestly reflect each transaction, income or expense, and are generated in a timely manner and in accordance with applicable accounting rules and standards.

Conflict of Interest

Any situation that may generate a conflict between CAF Personnel's personal interests and the interests of CAF must be avoided.

CAF Personnel who have direct and/or indirect relatives in the line of subordination, or who reside with a person who works for a competitor organization or public/governmental entity, shall communicate this situation by e-mail to [email protected], which will reserve the right to analyze it.

It is the CAF Personnel’s duty to inform the head of his/her sector of the existence of a potential conflict of interest.

Granting or Receiving Benefits

CAF Personnel must not offer or grant undue advantages, directly or indirectly, to any person or organization, nor take advantage of their position to demand, accept, seek to obtain or promise undue advantages. Gifts may only be granted if they comply with internal policies and procedures, the applicable laws and do not give the appearance of improbity or bad faith.

Relationship with Government and Political Parties

CAF Personnel have the responsibility to maintain a dignified relationship with public agencies, state companies, autarchies, mixed economy companies and others linked to public power.

The duties of management and CAF Personnel are as follows:

  • Respect the applicable legislation and the ethical principles of these Regulations in the relations established with the direct and indirect public administration in general;
  • Establish relationships with authorities, politicians and public agents based on ethics, professionalism and transparency, reporting immediately to CAF any form of pressure, offer or request by a public agent contrary to these principles;
  • Do not offer gifts, presents or any kind of financial or non-financial advantage to any public or political agent, or to persons related to them, in exchange for private benefits or for Combating Fraud;
  • Do not use an intermediary natural or legal person to hide or disguise interests or the identity of anyone who may benefit from any illicit acts committed;
  • Do not make agreements or prior arrangements with competitors or associations that represent competitors, which have the purpose of defrauding the competitive nature of procedures involving the direct and indirect public administration.

CAF will not engage in any political activity, although it may take a public stand on issues that are relevant to its interests. CAF Personnel are forbidden to engage in any party-political activities, using CAF's funds, installations, bodies or other means to support, directly or indirectly, any candidate or political party.

Donations are prohibited:

  • To individuals, organizations that represent a risk to CAF's reputation, political parties, candidates for public office, religious institutions and any institution that represents a risk of improper application of the donated resource;
  • Through deposits in private accounts.
  • All sponsorship contributions must be transparent, based on a written contract, have a lawful business purpose and be appropriate to the compensation offered. It is not permitted to promise, offer or provide contributions for the purpose of securing unfair competitive benefits and contributions may not be made to events organised by persons or organisations with objectives that are incompatible with our business principles and/or that could damage CAF's reputation.

Use of CAF assets and information

The assets (physical or digital) and information CAF shall comply with the following treatment:

  • Use CAF’s assets (assets, property, equipment, software, hardware, etc.) exclusively for professional purposes and in the Company's interest;
  • Do not generate or transmit information that incites racial prejudice, glorification of violence or other criminal acts or sexually offensive content;
  • Do not to make video or audio recordings, which relate in any way to CAF, without the consent of the superior;
  • Ensure the security of the information and the conscientious use of the data at their disposal, so as not to harm the rights of the company and of each individual, especially as to privacy;
  • Handle personal data only when necessary and only for legitimate, clear and predetermined purposes;
  • Maintain confidentiality with regard to internal business matters that have not become public knowledge. This obligation shall remain in force even after the termination of the employment or provision of services;
  • Not to use privileged confidential information for personal purposes;
  • Generate accurate and true records and reports, whether external or internal.

The guidelines on the use of information resources are clearly specified in the policies related to information security and the proper use of CAF information.

Internal Information

All CAF Personnel must be aware of the importance and need for secrecy regarding the Company's confidential information. Examples of confidential information:

  • Accounting data;
  • Personnel data;
  • Personal data of CAF Personnel, collaborators and shared by clients or third parties;
  • Commercial data;
  • Data on software codes;
  • Data on corporate sale or purchase;
  • Confidential information defined in policies, contracts or confidentiality agreements (NDA);
  • Data from proceedings in the context of arbitration;
  • Conditions of commercialisation with suppliers or customers.

Any request for this type of information by anyone outside CAF, or even by CAF Personnel who do not require it for their activities, must be immediately reported.

Archived information on former CAF Personnel may only be supplied by Human Resources or people authorized by them.

Personal Reputation

CAF expects from all CAF Personnel, without exception, the caution and diligence that all successful professionals usually employ in the management of their personal finances, as well as conduct that is dignified, honest and in accordance with the ethical standards of the professional environment in which they work.

CAF Personnel have an image to preserve with customers, suppliers and the community. Therefore, they must always offer their best at every moment, being courteous, attentive and caring towards everyone, as well as showing serenity, patience, optimism and accessibility.

It is essential to be careful with the personal image on social networks (messages, blogs, photos, videos, etc.). CAF understands that everyone is responsible for what they expose of themselves.

It is essential to build a reputation with caution and respect, considering that information is perpetuated in the virtual environment and may have inappropriate or uncomfortable repercussions for those involved.

Leaders must be careful not to compromise their personal image and that of CAF and must also avoid malicious comments.

At CAF, diversity is valued and respected. Therefore, discrimination of any nature is strictly prohibited.


CAF carries out activities in harmony with environmental aspects, exercising conscious use. Therefore, it is the organization’s culture to engage in the practice of cost reduction and waste elimination, and mainly diminishing the negative impact on the environment.

We seek in this way to ensure that possible environmental impacts and risks are controlled in accordance with legislation throughout the development of our business.

CAF complies with the applicable environmental legislation and is committed to the preservation of the environment. There are objectives and targets that must be met and aim to:

  • Integrate principles of environmental preservation and sustainable development into strategic business decisions;
  • Observe and ensure the lowest degree of environmental impact in the production processes;
  • Comply with legislation and ensure high standards of environmental quality;
  • Quickly resolve any occurrence that may harm the environment, CAF Personnel and/or the community, and if it occurs, it will be reported to the responsible bodies, truthfully and immediately, acting quickly to correct the problem.
  • CAF is committed to protecting and preserving the environment, as well as preventing and eradicating practices that are harmful to it, implementing efforts so that these conducts are also adopted by all their respective suppliers of products and services.
  • CAF shall monitor: (i) its activities so as to identify and mitigate unforeseen environmental impacts; and (ii) its direct and relevant suppliers with regard to environmental impacts, social and labor laws, occupational health and safety standards, as well as the inexistence of slave or child labor.

CAF, through its environmental commitment, shall:

  • Comply with the provisions of the legislation referring to the National Environmental Code, adopting measures and actions aimed at avoiding or correcting damages to the environment and safety, which may be caused as a result of their actions;
  • Keep, where applicable, its obligations in good standing with the environmental agencies;


Social Responsibility is a practice incorporated into management processes and a factor present in the Fight against Fraud.

CAF recognizes the importance of eradicating negative discrimination and racial segregation in society through the corporate dissemination of respect for differences and also through the inclusion of people with special needs in its workforce and recommends the same Code to its CAF Personnel and suppliers.

All CAF Personnel commit to making efforts for the total eradication of the maintenance of workers in conditions analogous to slavery in the national territory and declare that they comply with the provisions of art. They do not employ, either directly or indirectly, even through subcontracted companies, minors under 18 years of age in nocturnal, dangerous or unhealthy activities and/or minors under 16 years of age in any type of work, except in the condition of apprentice, from 14 years of age.

CAF, its collaborators, and other members who have any relation with CAF's business, shall not use, in their commercial activities and linked to its corporate purpose, harmful forms or exploitation of forced labor and or harmful child labor. Forced labour is understood as all work and services, performed in a non-voluntary way, which are obtained from an individual under threat of force or punishment. Child labour means employment of children, economic exploitation, or that is likely to be hazardous, to interfere with the child's education, or to be harmful to the child's health or physical, mental, spiritual, moral or social development.



CAF’s Legal and Compliance team are established with the purpose of contributing to meeting the guidelines of this  Code.   They determine the conformity with the rules, that is, the respect for the law and norms, and the Code.


It is the duty of all CAF Personnel to support and engage in the activities, processes and internal controls, in order to keep them constantly effective. If invited to contribute, they must be willing to do so, with emphasis on internal investigations and audits.

In particular, it is forbidden to grant or offer bribes, kickbacks, facilitation payments or any other benefits that could constitute improper advantages, either directly or through third parties. Any type of fraud, dissemination of false information, formation of a cartel and engagement in illicit activities, such as money laundering, unfair competition and non-compliance with the laws and codes in force are also prohibited.

Sensitive cases are treated confidentially, and retaliation of any kind is prohibited. Only those persons who have a mandatory need to know the information shall have access to it.

For complaints, the content of the complaint through [email protected] is important, as well as the evidence and logs collected as long as they are legal.

CAF Personnel shall be periodically trained in the Company's practices, procedures and policies, as well as in relation to the themes dealt with in this Code and the need to comply with them, as set forth in full.

The sector heads are primarily responsible for compliance in their areas. They may be called upon by Senior Management to provide clarification on compliance with these Regulations.



All areas, through the sector heads, shall be responsible for the application of this Code. It is the responsibility of each employee to inform his/her immediate superior formally or by e-mail: [email protected], whenever he/she becomes aware of a possible violation of the terms of these Regulations or other policies.

All complaints received will be treated confidentially and in confidence, with the exception of those in which there is a legal obligation to inform government authorities.

It is the responsibility of the legal department of CAF to investigate breaches of these regulations.  Violations of these Rules shall be subject to disciplinary measures and/or penalties based on the applicable legislation.

CAF does not allow any form of retaliation for reports made in good faith by its CAF Personnel or third parties.

Administering Our Code

Waivers, Amendments & Availability

Any waivers (including any implicit waivers) of the provisions in the Code for our executive officers may be made only by the Audit Committee and, in the case of a waiver for members of the Audit Committee, by the Board of Directors.

Waivers of this Code for any other CAF Personnel are to be made by the Executive Chairman and Chief Executive Officer or by the General Counsel and Compliance Officer.

No Rights Created

This Code is a statement of the fundamental principles that govern the conduct of the Company’s business. It does not constitute an employment contract or an assurance of continued employment. It is not intended to and does not create any obligations to or rights in any employee, client, supplier, competitor, shareholder or any other person or entity.

Index of contact information

Internal Contact Information
CAF Personnel and Collaborators may notify CAF of their concerns through via the following email addresses:  
[email protected] | [email protected]
External Contact Information
CAF has implemented a third-party whistleblower channel.  The channel can be accessed at: