CASA COR PROMOÇÕES E COMERCIAL LTDA.
Legal & Compliance Directorate
This Code of Ethics and Conduct ("Code") aims to express, highlight and reinforce the purpose and vision, ethical values, organizational identity and principles that guide the conduct of the activities of Casa Cor Promoções e Comercial Ltda. ("Casa Cor" or "Company"), guiding business, attitudes and individual behaviors.
This Code applies to:
All recipients of this Code must adopt it as an ethical and conduct reference to be observed in their relationship with Casa Cor and their colleagues, Partners, suppliers, Clients and communities, as well as in the conduct of their activities in any location where Casa Cor operates.
Casa Cor: Casa Cor Promoções e Comercial Ltda.
Public Agent: (i) any individual who acts officially or holds a position, employment or public function with a government authority, even temporarily or without remuneration and regardless of public service examination; (ii) any individual who works for a service provider company contracted or agreed to carry out typical activity of Public Administration; or (iii) any political party leader, their employees or other persons who act for or on behalf of a political party or candidate for public office. Examples of Public Agents include:
Harassment: may be configured as abusive conduct expressed through words, behaviors, acts, gestures, or writings that may cause damage to a person's personality, dignity or physical or psychological integrity, endanger their employment or degrade the work environment.
Promotional items: low commercial value items, normally used for advertising or promotion of a project, event, product or brand, among others. In general, promotional items bear the logo of the offering company for advertising purposes, are not directed exclusively to a specific person and have no commercial value. Examples: pens, t-shirts, caps, agendas, calendars.
Bullying: all forms of violence, physical or psychological, intentional and repetitive, exercised by one or more individuals, with the aim of intimidating or assaulting the victim, without them having the ability to defend themselves, within an unequal relationship of strength or power.
Reporting Channel: outsourced platform intended for receiving, via e-mail, phone or application, (i) reports related to possible ethical, legal or conduct violations, whether by employees or third parties related to Casa Cor, (ii) questions regarding the application of this Code, or (iii) any suggestions regarding this Code and ethical issues in general.
Women's Channel: communication channel that allows employees and any third parties to report, anonymously or not, via e-mail, phone or application, the occurrence of episodes of sexual harassment or any other form of violence against women in the workplace. In case of reports received by phone, assistance will be provided by a team of women from the company outsourced by Casa Cor, who will ensure absolute confidentiality of information and proper referral for handling each reported situation.
Client: natural or legal person who acquires a product or contracts Casa Cor's service, or who is evaluating the possibility of acquiring a product or contracting a Casa Cor service.
Code: this Code of Ethics and Conduct.
Employee: all employees, interns, workers and service providers of Casa Cor, who work or provide regular services to Casa Cor, cooperating with each other to achieve Casa Cor's common goals and contributing to the Company's growth, regardless of hiring model or hierarchical level. May include employees under CLT (Consolidation of Labor Laws), temporary workers, self-employed professionals and legal entity service providers, among others.
Compliance Committee: collegiate body advising the Board, of independent nature, responsible for evaluating, advising, supporting, regulating, deciding and monitoring issues involving ethical and conduct aspects and values of Casa Cor.
Courtesies: encompasses Promotional items, Gifts, Entertainment, Meals and Hospitality.
Personal Data: any and all information that, alone or together with other information provided, allows the identification and individualization of the natural person who provided it (e.g., ID, tax ID, name, address, IP).
Entertainment: cultural activities or events, parties, shows, sporting events, social gatherings and also activities that promote professional development, such as training, workshops, fairs, conventions, congresses, among others.
Hospitality: all expenses incurred with travel, including transportation/transfer costs, accommodation, vehicle rental, among others directly related to the purpose of the trip.
Anti-Corruption Law: Law No. 12,846, of August 1, 2013, and Decree No. 11,129, of July 11, 2022, as amended or regulated subsequently.
General Personal Data Protection Law or LGPD: Law No. 13,709, of August 14, 2018, as amended or regulated subsequently.
Partners or Business Partners: include, among others, distributors, suppliers, representatives, consultants, authors, licensees and licensing third parties who carry out commercial operations or business with Casa Cor, act on behalf of and/or in the name of Casa Cor or develop other projects in partnership with Casa Cor.
Politically Exposed Person (PEP): persons who hold or have held relevant public positions, employment or functions in the last five years, in Brazil or in other countries, as well as their representatives, relatives and close collaborators. Relevant public positions are considered those covered by COAF Resolution No. 29, of 12/07/2017.
Gifts: items that have commercial value given free of charge. They are characterized by items or services for personal use that have commercial value.
Meals: the concept of meal encompasses any and all expenses incurred with food (food and beverages), such as lunches, dinners, coffees.
Social and environmental responsibility: is exercised through, for example: (a) respect for environmental legislation applicable to operations and business; (b) optimized use of natural resources, such as water and energy; (iii) conscious use of work materials, avoiding unnecessary printing, use of disposable cups and waste of materials in general; (iv) contribution to selective collection and waste collection, properly disposing of discarded materials; (v) choosing suppliers who are also committed to sustainability; and (vi) encouraging and practicing diversity and inclusion.
Personal Data Processing: any operation performed with Personal Data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
At CASACOR, our purpose is to inspire and move, promoting experiences that reflect and shape the spirit of the times through the integration of professionals, brands and the public on a cultural platform dedicated to architecture, design, arts and landscaping. We are committed to integrity, operating within the law and maintaining transparent, good-faith communication. We value social responsibility and environmental sustainability, seeking to positively impact communities and the environment, rescuing the memory of the spaces we occupy. We expect everyone involved, from employees to partners, to adopt these principles, ensuring that every action connected to CASACOR promotes an innovative and sustainable lifestyle, aligned with our cultural and ethical values.
The Company repudiates any type of discrimination or prejudice based on creed, race, color, ethnicity, gender, religion, sexual or ideological orientation and socioeconomic condition, as well as rejects any and all aggression against the Universal Rights of the human being.
Casa Cor is us: everyone who works at Casa Cor or provides services to it in any capacity and in some way shares the same work environment and the day-to-day of the Company.
Our conduct must be based on the following fundamental principles:
Integrity in the conduct of business and relationships is the foundation of Casa Cor's corporate image. Everyone is responsible for building an ethical corporate environment through ethical actions and behaviors.
Therefore, it is everyone's duty:
The following is not permitted:
Casa Cor is committed to ensuring and encouraging the well-being of people in its work environment, seeking, through management policies and other measures, to provide high levels of satisfaction and professional fulfillment, in addition to ensuring a safe and healthy work environment.
Thus, the following are non-negotiable principles of Casa Cor:
It is everyone's commitment, when interacting with colleagues, Clients, suppliers and Business Partners:
Therefore, the following is not permitted:
Casa Cor is committed to the health and safety of all its Employees, third parties and visitors, paying full attention to legislation applicable to Occupational Safety and Medicine. No activity or process may be carried out without meeting the requirements set forth in the Regulatory Standards for Occupational Safety and Medicine.
It is everyone's duty to follow the norms, procedures and instructions related to health, safety and well-being, including:
The following is not permitted:
Casa Cor believes that Leadership is the main form of engagement and dissemination of its ethical values. People managers set an example of conduct for other employees, Employees, Clients and Business Partners.
Therefore, managers must:
Any type of retaliation against any Employee or service provider who has contributed to an investigative process or reported potential conduct deviation by the manager or another Employee or service provider is unacceptable.
Casa Cor maintains a firm commitment to fighting acts of corruption, which cause severe harm to society and can endanger the Democratic Rule of Law itself.
It must be a standard of conduct for all to comply with and require that everyone who relates to Casa Cor comply with all anti-corruption laws, especially the Anti-Corruption Law, and also:
Casa Cor does not allow the favor or personal promotion of Public Agents, public bodies or political parties in journalistic matters, events held or sponsored by Casa Cor or in any other way, with due regard for the editorial freedom of its communication channels, which may opine or inform about public managers within the limits of the exercise of freedom of opinion.
Contributions and donations to political parties regularly made by the recipients of this Code, within the scope of their private lives, may never be related or linked to their professional activity.
The promise, offer, solicitation or receipt of Courtesies cannot be considered as consideration for any preferential or favorable treatment in obtaining or maintaining business or to influence relationships in any way.
Delivery, offer, promise or receipt of Courtesies may be considered a violation of this Code, regardless of value, when the act may inappropriately influence any commercial decision and/or result in an undue advantage for Casa Cor, its administrators, Employees or third parties.
The promise, offer or receipt of Courtesies involving Politically Exposed Persons (PEP) and/or federal, state or municipal Public Agents is regulated and poses greater risks for Casa Cor, and may only be carried out after prior assessment by the Legal Directorate and approval by the Compliance Committee.
Any and all Courtesies offered or received by an Employee, service provider or partner of Casa Cor acting on behalf of Casa Cor must be reported by completing a form that is part of this Code as its Annex 6.1.
The promise, offer or delivery of Courtesies on behalf of Casa Cor, in addition to legitimate commercial purpose, must have approval from the area Director, must not be frequent and must comply with applicable local laws.
Any Courtesy that does not fall within this Code may only be offered or received after assessment by the Legal Directorate and approval by the Compliance Committee.
Receipt or offer of Promotional items or Gifts by Employees, service providers or Partners acting on behalf of Casa Cor is permitted, provided the value of such Promotional items and Gifts is up to R$500.00 (five hundred reais) and, in the case of receipt, is limited to 02 (two) times per year. Whenever the Promotional item or Gift is composed of more than one item, the sum of the values of each will be considered. For purposes of compliance with this Code, Employees, service providers and Partners of Casa Cor must value the Promotional items or Gifts offered or received applying reasonable judgment, when the value of such items cannot be consulted on the market. In case of doubts about the assessment, the case must be referred to the Compliance Committee via e-mail compliance@casacor.com.br.
Promotional items and Gifts received that do not comply with the rules established in this Policy must be immediately returned to the sender, accompanied by the Standard Thank You and Return Letter, the template of which is attached to this Policy (Annex 6.2).
In cases where return is not possible or would constitute an undignified act or that could cause discomfort in the relationship between Casa Cor and the provider of the Promotional item or Gift, it must be referred to the Compliance Committee via e-mail compliance@casacor.com.br for assessment and adoption of appropriate measures.
Payment of expenses related to Meals by Employees, service providers or Partners acting on behalf of Casa Cor is permitted in representation situations, for exclusively commercial and institutional purposes, without specific value limitations, but with reasonableness within the context, using as a recommended parameter the limit of R$400.00 (four hundred reais) per person in national territory, and between USD100.00 and USD200.00 (one hundred and two hundred US dollars) per person when in foreign territory.
For Entertainment, Casa Cor establishes the reference value of R$2,000.00 (two thousand reais) per person in national territory and USD150.00 (one hundred and fifty US dollars) per person when in foreign territory.
Entertainment of a corporate and institutional nature may be offered or received from third parties when Casa Cor's interest in providing commercial and institutional opportunities is configured. If it exceeds the value provided for in this Code, the Compliance Committee must be contacted.
Corporate events promoted by Casa Cor to its Employees, service providers and Partners to disseminate technical or scientific information, improve knowledge or stimulate engagement, performance or commercial matters may be sponsored by business Partners and/or suppliers, provided that it does not constitute any unusual type of consideration or preference in relation to the normal course of Casa Cor's business.
Offering or accepting trips that only aim at leisure situations for their beneficiaries will not be permitted.
Offering or receiving Hospitality to Public Agents and companions is strictly prohibited.
The following are common conduct criteria for all Employees and service providers in relation to Business Partners:
All Casa Cor Business Partners must observe the following conduct rules:
The following must be a common standard of conduct for all Employees, service providers and business partners towards Casa Cor clients:
The relationship with competitors must be based on respect, in accordance with current legislation, not spreading misleading statements about their products and services.
Situations of conflict or potential conflict of interest occur when an individual's personal interest interferes or may interfere with their ability to make impartial judgment, to the detriment of Casa Cor's interests.
Although it is not possible to list all situations of conflict or potential conflict of interest, the situations listed below are some examples of situations that may give rise to conflicts of interest:
As this is not an exhaustive list, any doubt about the specific case must be referred to the Compliance Committee.
Every conflict of interest situation identified as real, potential or apparent must be analyzed, addressed or avoided according to each context and declared, for transparency purposes, to the Compliance Committee.
It is the responsibility of each Employee and service provider to use Casa Cor resources to which they have access with care and consciously, with the same degree of care they would have with their own resources, within current legislation and respecting internal IT and Information Security policies, without any intention of damaging them.
Therefore, everyone must respect and strictly follow the guidelines of the Information Security Policy, available on the intranet, as well as the following rules:
Casa Cor is committed to complying with all applicable laws, regulations and standards related to intellectual property rights, including copyrights, patents, registered trademarks, trade secrets, software and algorithms, among others.
Protecting our intellectual property and that of our Business Partners is everyone's duty and obligation. Thus, it is necessary to:
Casa Cor adopts the necessary measures to ensure the privacy and protection of Personal Data of all its Employees, service providers, Partners and consumers, in compliance with the LGPD.
All Employees, service providers, suppliers and Partners in general are guided on the rules of privacy and Personal Data protection and must follow the internal policies and regulations widely disseminated and available on the Intranet.
In the case of storage of Personal Data by service providers and Partners, it is necessary to ensure that these providers and Partners are in compliance with the Casa Cor Corporate Personal Data Protection Policy in force and other legislation on Personal Data protection and adopt measures aimed at conferring on such data the same level of security as Casa Cor. Otherwise, storage of Personal Data by these providers or Partners will not be permitted.
In this regard, it is everyone's duty:
For cases where personal equipment is used for work, the Personal Equipment Use Policy must be strictly followed.
It is everyone's duty to act and express their opinions on their social networks with responsibility and respect for the provisions of this Code. Therefore, whenever expressing opinions on their social platforms where they make reference or have a potential impact on Casa Cor, consider:
When permitted by applicable law, Casa Cor reserves the right to monitor the use of social platforms and take appropriate measures to protect against misuse that may harm the reputation of the Company and its direct or indirect subsidiaries.
In the cases provided for throughout this Code or whenever any recipient of this Code (i) has any doubt about its application, (ii) has any suggestion or comment about ethical issues in general or (iii) identifies any possible violation of these rules, regardless of their hierarchical level and those involved in the occurrence, they must report the situation to the Compliance Committee, through the Reporting Channel (e-mail: https://www.contatoseguro.com.br/pt/casacor / phone: 0800 810 8439 / application: Contato Seguro) or the Women's Channel (e-mail: https://www.contatoseguro.com.br/pt/canaldamulhercasacor / phone: 0800 810 8439 / application: Contato Seguro). The report may be made anonymously or identified and it is essential that it be transparent and based on facts, without conspiratorial or revenge purposes and, if possible, accompanied by evidence.
In case of reports of possible violations of this Code, the facts will be investigated by impartial specialists appointed by the Compliance Committee, through analysis of evidence eventually presented to the Reporting Channel or Women's Channel, as the case may be, conducting interviews, document review and any other measure necessary to verify what occurred. The Compliance Committee must assess the data collected and, if there are sufficient indications of authorship and materiality, will decide on the application of corrective measures, based on the circumstances and severity level of the facts, as well as conduct history and level of responsibility of those involved (for example, if there is recurrence). Such measures may include mere feedback, verbal warning, written warning, suspension or even termination of the contract of those involved.
There will be no penalty or retaliation for the good-faith referral of questions or issues related to violations of this Code.
The Compliance Committee will be composed of:
Among other attributions provided for in this Code, the Compliance Committee is responsible for:
The provisions of this Code enter into force on the date of its publication and will remain valid indefinitely.
This form must be completed and sent to Casa Cor's Compliance Committee via e-mail compliance@casacor.com.br, in case of promise, delivery and/or receipt of any Courtesy, regardless of its nature, including Promotional items, Gifts, Meals, Entertainment and Hospitality. The Committee will assess the compliance of the Courtesy with the terms of the Company's Code of Ethics and Conduct and will deliberate on the possibility of carrying out the said promise, delivery or receipt.
Name of Employee, partner or service provider acting on behalf of Casa Cor:
Position:
Department:
Detailed description of the Courtesy. Present here any justifications and any necessary explanations. In case of Courtesy already granted, attach proof and receipt of expenses involved. If there is no supporting document, present justification.
Name of the third party who granted/received the Courtesy:
Company:
Position:
Is the third party a Public Agent or Politically Exposed Person? If so, please detail.
Value of the Courtesy (if it is not possible to determine, present reasonable estimate):
Directorate approval:
Compliance Committee approval and comments (for completion by the Committee, after case analysis):
Date: _______/_______/_______
[Employee / Service Provider / Partner Name]
[Position]
[Area Director Name]
[Position]
[Compliance Committee President Name]
Compliance Committee President
Dear [recipient name],
We would like to thank you for the promotional item / invitation / gift / hospitality [declare the item received] sent.
We know that your intention was to strengthen our good relationship, which gives us great satisfaction.
However, the promotional item / invitation / gift / hospitality [declare the item received] is not in compliance with the rules established in Casa Cor's Code of Ethics and Conduct. Thus, in order to preserve our good relationship and transparency in our business, we cannot accept the promotional item / invitation / gift / hospitality [declare the item received] offered.
Our Code of Ethics and Conduct is available for consultation on the Casa Cor website, at https://casacor.abril.com.br/pt-BR/codigo-de-etica-e-conduta. Access the website and learn about the organizational values and guidelines that guide the attitudes of all our Employees, as well as service providers and Partners acting on our behalf.
Once again, we thank you for your kindness and understanding. We are at your disposal to provide any additional clarifications that may be necessary.
Sincerely,
[Sender name]
Management [=]
Directorate [=]