Código de Conduta

Código de Conduta Developer 6 de February de 2020
Commitment to Ethics.

We present our Code of Conduct. He will support Let’s Water do Brazil’s Ethics and Compliance Program, assisting in our daily judgments.

This document is based on fundamental values such as inspiration, impact, intuition, innovation, integrity, inclusion, integration, communication, curiosity, courage, passion, freedom and responsibility, and aims to provide guidance on expected behaviors when faced with a set of situations, serving as a confirmation and formalization of our commitment to always act in an ethical and responsible manner.

This document should be understood as a guide, and not as a book of rules, due to its inability to cover the entire universe of situations that we may potentially face in our daily work.

Any suggestions on how to improve this Code of Conduct are welcome and will be considered and evaluated carefully and in depth.

The principles and guidelines established here must guide the activities of Let’s Water do Brazil and its employees and third parties.

This guide must be clearly understood by our employees and third parties, who are required to know and comply with this Code of Conduct, as well as with all internal rules and regulations and legislation applicable to the topic.

1. What is a Code of Conduct?

It is a document that brings together the fundamental principles that support the purpose of our business. All people who work at Let’s Water do Brazil must act in an integrated, correct and efficient manner in the search for results, always based on the values expressed in this Code, internal rules and regulations.

2. What are the objectives of the Code of Conduct?

Provide understanding, respect and practice regarding the business values of Let's Water do Brazil, by all partners, employees, service providers, partners, suppliers and customers, in the locations where we operate, so that everyone acts correctly, respectful and fair towards the community in general and the environment.

3. Who does the Code of Conduct apply to?

The Code of Business Conduct applies to all professionals who work, provide services, supply products, individuals and legal entities that are in any way related to Let’s Water do Brazil.

4. Mission, values and principles.

Let’s Water do Brazil’s mission is to be a reference in the area of communication. Provide specialized services with excellence and agility. Develop internal values that enable the intellectual and professional growth of our employees, based on three pillars:

  • Credibility: we must work so that our technical capacity makes us a reference in our area of activity.
  • Independence: we base our solutions on neutrality, independence and technical rigor.
  • Integration: we offer solutions that combine expertise in different areas of knowledge.

Our daily work is guided by fundamental values that guide our relationships, whether with customers or with the people who share the work environment. We act, in all spheres, with integrity, in accordance with the laws and we value:

In the work environment:

  • Promote a system of meritocracy and respect;
  • Value diversity and specific contributions, fostering an inclusive, open and trustworthy environment;
  • Never allow discrimination and harassment of any kind.

In customer relations:

  • Privilege your interests over the interests of Let’s Water do Brazil;
  • Preserve your confidentiality;
  • Act professionally.
5. Our conduct in relationships.

5.1. With collaborators

A Let’s Water do Brazil atua em conformidade com a legislação trabalhista e tem como objetivo criar um ambiente de trabalho seguro, isento de comportamentos abusivos, violentos, ameaçadores ou prejudiciais. Colaboração e confiança são fatores fundamentais para o sucesso do nosso trabalho.

Não toleramos nenhuma forma de assédio, discriminação, preconceito, bullying ou comportamentos desrespeitosos. Respeitamos e encorajamos o diálogo aberto e não toleramos represálias contra qualquer pessoa que se manifeste de boa-fé.

Our decisions regarding hiring, compensation, promotions, performance and task assignments are made based solely on the contributions and capabilities demonstrated by our employees.

5.2. Com os clientes

Let’s Water do Brazil always puts its customers’ interests above its own, providing services with integrity and competence. All customers are treated equally and the interests of employees must never prevail to the detriment of the interests of customers.

We only agree to provide services for which we believe we are qualified and when we believe they will benefit the client. We may occasionally recommend that other professionals participate in a specific job whenever their knowledge and skills better serve the client and we do not receive any financial advantage for this recommendation.

We do not promise any specific results nor do we create unrealistic expectations. If there is any relationship, circumstances or interests that could influence our judgment or impair the objectivity of the work, we feel obliged to immediately inform the client.

Our employees and third parties will not seek financial or any other advantage due to the knowledge acquired as a result of the relationship with the client.

We maintain confidentiality regarding any and all private information obtained from the client during the course of our professional work. All information relating to clients is the property of the company and our employees are committed to keeping this information confidential, even after leaving or leaving the Agency.

Our contracts are drawn up and negotiated in accordance with the law and ethically. We strictly comply with our contractual obligations under the agreed terms and conditions.

5.3. With competitors

Let’s Water do Brazil believes that free competition stimulates efficiency and innovation in the sector, benefiting our customers and society as a whole.

We do not enter into contracts with our competitors, formally or informally, to unlawfully restrict competition, set prices or allocate customers, markets, people or services.

5.4. With suppliers and service providers

We purchase goods and services based on price, quality, reputation, performance and suitability. We do not purchase goods and services from our customers just because they buy from us.

We expect our suppliers to comply with the law and we include anti-corruption clauses in strategic contracts.

We do not accept suppliers offering or promising personal benefits and/or bribes to our employees and third parties with the aim of gaining, maintaining business or relationship advantages.

5.5. With commercial partners

Our choice is based on objective criteria that involve complementarity of services, technical capacity, suitability, integrity and reputation.

We expect our business partners to comply with the legislation and rules applicable to their business and to act with integrity and constant effort to uphold the highest ethical standards.

5.6. With the press and other influencers

Our relationship with the press and influencers is guided by transparency, credibility and ethics.

We do not disclose information about our customers and partners to the press without due authorization.

6. Specific conduct policies.

6.1. Interest conflicts

Conflicts of interest can occur in different situations.

Employees and third parties who have relationships with Let's Water do Brazil must avoid activities, agreements, positions, investments in businesses or interests that are or may be in conflict with the interests of the office, whether or not causing harm to the agency's activities, or which may interfere with the performance of their duties within the office.

We ensure the right of employees and third parties to participate in business of a private or personal nature outside the office, as long as such business, in addition to being legitimate and legal, does not interfere or conflict with our interests and does not result from confidential information obtained in the course of carrying out its activity. professional at Let's Water do Brazil

If any situation of conflict of interest is identified, the employee or third party must inform their immediate superior.

6.2. Bribery, anti-corruption and money laundering

We do not offer or accept bribes, including inappropriate gifts or forms of entertainment. Even if our competitors offer bribes or make questionable payments, we have a zero tolerance policy for these practices and any other activities that violate these laws.

We do not allow our employees and third parties to offer or accept bribes, nor to make questionable payments on our behalf.

We obey anti-corruption laws without exception.

We do not carry out any money laundering or terrorist financing activities, nor do we assist third parties in doing so.

6.3. Political positioning

The political affiliations or personal opinions of our employees and third parties do not represent those of Let’s Water do Brazil. We do not use company resources to support, endorse or oppose any political position, party or candidate.

7. Gifts and gifts.

Any gifts, giveaways, meals and accommodation offered or received by Let’s Water do Brazil, its employees and third parties must be legitimate, that is, without the aim of corruption; they must be reasonable and not too frequent, and must be such that they are not mistakenly interpreted as bribery. Cases that do not fit this definition must be rejected.

Muitas empresas têm políticas específicas para seus colaboradores e terceiros sobre o que eles podem aceitar. Tais políticas devem ser observadas no tocante aos nossos clientes.

8. Conduta em relação ao poder público.

Any relationship with authorities, politicians and public agents must be based on the principles that govern public administration, namely, legality, impersonality, morality, publicity and efficiency and professional and correct attitudes. Let’s Water do Brazil repudiates any harmful act against public property.

Let’s Water do Brazil does not tolerate practices that involve undue advantages to public agents, fraud in contracts, in bidding procedures, obstruction of investigative or supervisory activities of public bodies. If anyone linked to Let’s Water do Brazil is aware of such attitudes, they must report them to their immediate superior or report the incident through the Ethics and Compliance Channel. (compliance@letswater.com).

Let’s Water do Brazil does not make any type of contribution or donation to candidates or political parties. Possible personal contributions or donations made by employees or third parties of Let’s Water do Brazil in this regard cannot, under any circumstances, include resources from Let’s Water do Brazil.

Donations, contributions or sponsorships to institutions, bodies and associations, whose objective is philanthropy, must be made in a transparent manner and always respecting the legislation.

Donations and sponsorships for events must be made transparently, for a legal purpose and linked to Let’s Water do Brazil business and must be documented in a specific sponsorship contract.

We do not allow donations that aim to obtain an undue advantage.

9. Remuneration.

Let’s Water do Brazil charges reasonably for its services. Your remuneration is determined based on the nature of the services; in the required time; in your experience, skill and reputation; the degree of responsibility assumed and the benefits received by the client.

We do not accept commissions, gratuities or any other advantage from people and organizations whose services, supplies or equipment we recommend during the course of our work.

Reimbursable business expenses are sent to our customers in an accurate and documented manner.

10. Confidentiality, data privacy and privileged information.

We respect the privacy and confidentiality of the information of our customers, our employees, third parties and other parties with whom we interact professionally, in compliance with data privacy laws.

We protect personal and confidential information in any format.

We gather, store, use, transmit and work with personal and confidential information in a transparent and trust-inspiring way. We use and maintain personal information of employees, third parties and customers, and other confidential information, only if we have a legitimate reason (determined purpose) for doing so. Access to this information is also only provided if there is a legitimate reason to do so.

The duty of confidentiality of our employees and third parties does not end when they leave Let’s Water do Brazil. We expect employees and third parties to continue to respect the confidentiality of information even after they leave.

We are cautious when discussing client issues in public places and do not disclose confidential information inappropriately, including when using social media.

We protect the information and electronic physical assets to which we have access, including from malicious threats and accidental loss.

We securely store all paper and electronic records and only keep them for periods agreed or determined by law.

We retain material information when we know or anticipate that there may be an investigation, litigation or other matter, or when we are instructed to do so.

Nunca negociamos ou divulgamos de forma inapropriada informações privilegiadas.

As listas de clientes e demais informações comerciais são de propriedade da Let’s Water do Brazil. Não é permitido que colaboradores e terceiros as divulguem ou utilizem para qualquer fim diverso.

Employees and third parties must maintain strict confidentiality regarding any confidential or strategic information from Let’s Water do Brazil.

11. Intellectual property.

We protect and honor the intellectual property rights of third parties, as well as the intellectual property of Let’s Water do Brazil, including our accumulated knowledge.

We require our employees and third parties to honor their commitments to former employers and we do not allow them to use, disclose or bring to Let’s Water do Brazil any electronic or physical documents from companies for which they previously worked.

We do not allow contributors and third parties to download or use copyrighted content without the appropriate licenses.

Our intellectual property is an important differentiator and, therefore, must be protected and kept safe by everyone, both employees and third parties. All content produced by employees and third parties, in the course of their work, is the property of Let’s Water do Brazil.

Our employees and third parties authorize Let’s Water do Brazil to use the content of their photographic image, registered by us and for an indefinite period, for commercial dissemination and all legal purposes, and the content of the content presented must be maintained and respected.

12. Use of social media.

We expect our employees and third parties to publish their opinions on social media based on the principle of good faith and loyalty, acting with common sense and doing so only in their own name, avoiding associating any type of personal opinion with Let's Water do Brazil

We recommend that employees and third parties:

– Be thoughtful and never publish content that is disrespectful, discriminatory or hostile;

– Protect private information related to your professional activities at Let’s Water do Brazil;

– Protect Let’s Water do Brazil’s intellectual property and respect the rights and privacy of third parties.

We do not authorize our employees and third parties to post or disseminate derogatory or offensive comments about the company, the work environment, their colleagues, customers, competitors or partners.

We do not authorize employees and third parties to publicly identify a company as a customer, unless they have the necessary authorization to do so.

14. Use of company assets and resources.

Employees and third parties must make responsible use of the equipment and tools in their possession, as well as common-use assets, doing everything possible to avoid accidental loss, damage or damage.

The sharing of passwords to access the network and internal systems of Let’s Water do Brazil is prohibited, as these are for personal and non-transferable use.

It is prohibited to install and duplicate software or modify settings that compromise the security of our technology. We only use third-party web-based services and data backup solutions approved by Let’s Water do Brazil.

The use of telephones, computers and the Internet must be responsible and, mainly, for legitimate professional purposes. Personal uses must be made using the principles of good faith and common sense.

In order to protect the company, members and assets, Let's Water do Brazil may request inspection of personal properties, within the limitations established by law, and may monitor, at any time, all office assets, including personal computers, and -emails, instant messages and Internet use.

15. Accounting records.

Let’s Water do Brazil has a transparent accounting and financial records system that completely and accurately reflects all transactions carried out. We comply with regulatory, accounting standards and applicable legislation.

We do not carry out financial or asset transactions outside commercial or tax books.

16. Cooperation with authorities.

We promptly respond to requests from government authorities and professionals for information, in accordance with applicable laws and professional obligations.

17. Moral and sexual harassment.

Moral and sexual harassment are unacceptable practices at Let’s Water do Brazil, which values a respectful and dignified environment to work in.

18. Hiring friends and relatives.

Recommending friends for existing vacancies at Let’s Water do Brazil is an encouraged and traditional practice. It is the responsibility of the contracting area to decide, after regular selection, whether to hire the indicated professional, and any type of pressure to influence the admission, promotion or dismissal of these professionals is not permissible. Hiring a family member is prohibited, regardless of the existing relationship.

19. Unauthorized Payments.

Let’s Water do Brazil does not make payments to anyone unless said expenditures have been approved in advance by at least two directors. The practice mentioned here will result in summary punishment, in addition to applicable legal measures.

Let’s Water do Brazil does not make payments for services provided in favor of Let’s Water do Brazil in third-party accounts, accounts of individuals or legal entities to anyone other than the invoice drawn in favor of Let’s Water do Brazil.

20. Child labor and negative and limiting discrimination practices.

Let’s Water do Brazil does not use child labor and must ensure that its suppliers follow the same principle.

It also does not use negative discrimination practices that limit access to the employment relationship or its maintenance, such as, but not limited to, reasons of gender, origin, race, color, physical condition, religion, marital status, age, situation family or pregnancy status.

21. Political-Party Activities.

Let’s Water do Brazil does not carry out any political activity. Professionals with ties to Let’s Water do Brazil who are interested in participating in this process must do so individually, without involving the Society’s name or resources. No professional is authorized to request support, financing, participation or involvement from other professionals with any candidate or political party, nor to carry out political activities within the work environment or during the period.

22. Environment.

Let’s Water do Brazil carries out its work in compliance with legislation and environmental standards, seeking the rational use of natural resources and the preservation of the environment.

23. Responsibility for the Code of Business Conduct.

A responsabilidade pelo presente Código de Conduta Empresarial é da Comissão de Ética da Let’s Water do Brazil. Cada líder de equipe é um representante da Comissão de Ética em relação aos profissionais que lidera e tem as seguintes obrigações:

23.1. Know this Code and clarify your team's doubts about the content of this document. If you have any doubts, you should forward the questions to the Ethics Committee and then return to your subordinate, making sure that there are no points left to be addressed.

23.2. Follow this Code so that your behavior and attitudes correspond to the content of the document, serving as an example to your employees

23.3. Disclose it to your team members (employees and third parties).

23.4. If you identify violations of this Code, take whatever is necessary to ensure that the violations are corrected and eliminated, informing the Ethics Committee about the actions taken and making sure to take additional actions, all in accordance with the instructions provided by it.

24. Code violations

All employees and third parties must know, disclose and comply with the Let’s Water do Brazil Code of Conduct for the good performance of their activities. We encourage everyone's collaboration in combating any irregularities committed.

Our employees and third parties have the right and duty to report any violation of this Code or any illegal practices. In these cases, you should contact your immediate superior, the Ethics and Compliance Committee. ( compliance@letswater.com ).

We will take all possible measures to investigate what happened and clarify any doubts raised, acting discreetly, preserving the identity of the complainant and ensuring that there is no retaliation.

We emphasize again that this Code does not intend to address all situations that may occur during the activities of each Let's Water do Brazil employee or third party, which is why it is extremely important that, in case of doubt about how to act in a situation specific situation, the employee or third party should consult their immediate superior.

25. Disciplinary Measures

All Let’s Water do Brazil employees and third parties, without exception, who fail to comply with this Code will be subject to the following sanctions, with no gradation to be followed. Failure to comply with the commitments contained in this Code of Conduct will be treated as a matter of extreme seriousness, and may result in:

For your partners

– Exclusion from society for just cause, in accordance with art. 1,085 of the Civil Code, without prejudice to applicable civil, criminal and/or administrative liability.

For your collaborators

– Verbal or written warning;

– Suspension; or

– Termination of the employment contract with or without just cause.

For third parties

Third parties who commit any violation of this Code will be subject to the specific sanctions provided for in the respective contracts, such as, for example, the termination of said contract or the termination of the contractual relationship, without prejudice to applicable civil, criminal and/or administrative liability.

26. Reporting channel

All employees and third parties who have ties with Let’s Water do Brazil and who have doubts about how to act or are aware of any illegal act or in non-compliance with this Code of

Conduct must be immediately communicated to the company through the Ethics and Compliance Committee. ( compliance@letswater.com ).

Messages sent to the Reporting Channel are guaranteed by absolute confidentiality of identity, protecting the anonymity of the complainant and preserving the information so that a fair investigation can occur. When deciding to report, we ask that as much information as possible be provided that can prove it, enabling a fair investigation of the conduct.

No one will be punished or retaliated against for sending information provided in good faith about suspected behavior contrary to this Code.

27. Terms and expressions used in this document.

Administrators: members of the Board of Directors, Fiscal Council, Committees, Directors and President.

Something of value: is cash, gifts, meals, entertainment, sponsorships, donations, job openings, goods or properties, inside information and tipping (types of confidential information that can impact the value of the share of a company, such as news of mergers, acquisitions or sales of subsidiaries, planned offering or sale of company securities, etc.).

Moral harassment: repetitive attacks through rude and inappropriate words or gestures, malicious comments, bullying, prejudiced or discriminatory insults, intimidation, rumors, jokes that may humiliate any person who maintains a legal relationship with Let's Water from Brazil.

Sexual harassment: harassment by someone who seeks to obtain sexual advantage or favor or who places you in an unwanted sexual context. It occurs through inappropriate sexual advances, lewd comments, or lewd remarks. This includes promising or providing employment, promotion, pay, or special treatment in exchange for sexual favors. It also includes inappropriate or unwanted touching, as well as posting or sharing obscene images, objects or materials

Code: set of rules, laws or norms.

Conduct: behavior, moral procedure.

Employees: are individuals who work at Let’s Water do Brazil, under the CLT regime.

Ethics: set of customs, habits and behaviors.

Family: Family members are considered to be the spouse, partner, father, mother, children, siblings, grandparents, grandchildren, uncles, nephews , cousins and relatives such as in-laws, daughter/son-in-law, brothers-in-law, stepmother/stepfather, stepchildren.

Suppliers: commercial partners, legal entities with which Let’s Water do Brazil has relationships.

Code of Conduct: standards and behaviors that regulate the operations of Let’s Water do Brazil and that indicate the conduct that must be followed by its employees, suppliers, service providers and partners.

Partners: are legal entities that maintain a commercial relationship with Let’s Water do Brazil.

Professionals: are people who work at Let’s Water do Brazil regardless of their position, function, activity or working time.

Values: are Let’s Water do Brazil’s commitments to society in general, to its employees, service providers, professionals in general and partners.

Bangkok, Thailand, august 2023.

Let’s Water do Brazil