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:
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.
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:
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:
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.
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:
CAF Personnel must act in accordance with the principles outlined below:
Before hiring an employee, CAF must carry out due diligence in accordance with the following minimum criteria:
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:
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:
Use of CAF assets and information
The assets (physical or digital) and information CAF shall comply with the following treatment:
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.
All CAF Personnel must be aware of the importance and need for secrecy regarding the Company's confidential information. Examples of confidential information:
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.
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.
ENVIRONMENTAL AND SOCIAL RESPONSIBILITIES
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:
CAF, through its environmental commitment, shall:
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.
COMPLIANCE AND CORPORATE GOVERNANCE
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.
PROCEDURES AND COMPLAINTS
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.