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CASACOR

Code of Ethics and Conduct

CASA COR PROMOÇÕES E COMERCIAL LTDA.

Legal & Compliance Directorate

1. Objective

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.

2. Who this Code applies to

This Code applies to:

  1. All Company Employees, including employees of any hierarchical levels, even if temporary, as well as interns, among others;
  2. All managers and executives, including directors and members of the Presidency and Vice-Presidency, among others;
  3. Business Partners.

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.

3. Glossary

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:

  1. Government inspectors and agents;
  2. Municipal, state, federal or military guards and police officers;
  3. Firefighters and Armed Forces personnel;
  4. Ministers, appellate judges, judges, attorneys, prosecutors and public defenders;
  5. Presidents, governors and mayors;
  6. Senators, federal and state representatives and city council members;
  7. Public servants in general, whether or not civil service appointed;
  8. Notaries or notary publics and registry officers;
  9. Employees, members or representatives in general of state-owned companies and mixed-economy companies, such as: Petrobras, Caixa Econômica Federal, Banco do Brasil, Correios, Furnas, Eletrobrás, etc.;
  10. Employees, members and representatives in general of autarchies and foundations, such as Administrative Council for Economic Defense - CADE, Securities and Exchange Commission - CVM, Central Bank of Brazil - BACEN, National Bank for Economic and Social Development - BNDES, Brazilian Institute of Environment and Renewable Natural Resources - IBAMA, National Foundation for Indigenous Peoples - FUNAI, among others;
  11. Employees, members and representatives in general of regulatory agencies, such as National Telecommunications Agency - Anatel, National Film Agency - Ancine, National Electric Energy Agency - Aneel, National Health Surveillance Agency - Anvisa, among others.

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.

4. Our purpose

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.

5. General Principles of Conduct

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:

  • Act with integrity
  • Respect for people
  • Lead by example
  • Fight against corruption

5.1. Act with Integrity

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:

  1. Know and act in accordance with the policies and procedures applicable to Casa Cor and the respective area of activity, such as this Code, other policies available on the Intranet and laws applicable to the activity performed;
  2. Safeguard the image and values of Casa Cor, inside and outside the workplace, maintaining a compatible posture in personal life as well;
  3. Refuse any benefit or personal advantage in exchange for providing confidential or privileged information;
  4. Maintain due confidentiality regarding work performed;
  5. Report to Casa Cor whenever having knowledge of or witnessing any action in breach of this Code, other policies available on the Intranet or applicable legislation;
  6. Recognize mistakes made, correct them and use them to identify ways to avoid them;
  7. Inform of the existence of any company owned by you or by relatives that have a business relationship with Casa Cor, with relatives for this purpose understood as spouse, parents, children, siblings and in-laws;
  8. Act with respect for human rights;
  9. Repudiate any fraudulent or corrupt practice (bribery, influence peddling, money laundering, concealment of assets, undue advantages and others) or illegal or criminal acts of any kind;
  10. Repudiate and report, through the Reporting Channel, any form of harassment, prejudice or discrimination;
  11. Disapprove, condemn and report illegal conduct, such as document tampering and forgery, tax evasion, among others.

The following is not permitted:

  • Practice gambling in the workplace or outside it when on Casa Cor business;
  • Be under the influence of narcotic substances during working hours or when on Casa Cor business;
  • Give, promise, offer or authorize favors and/or anything of value, even indirectly, to any individual or private legal entity with the aim of obtaining or maintaining any undue advantage and maintaining business;
  • Have another occupation outside Casa Cor that negatively affects your performance or interferes with the performance of your duties at Casa Cor;
  • Provide services to other communication companies and/or competing companies/same segment;
  • Use confidential or privileged information for personal benefit or that of a third party;
  • Make statements and declarations to the press related to Casa Cor, including through interviews, without proper authorization and qualification by the Company;
  • Accept, for yourself or a relative, any advantage or personal benefit from a supplier, client, competitor or any other organization that seeks to do business with Casa Cor or any of its direct or indirect subsidiaries, except as permitted in item 6 of this Code;
  • Engage in or carry out activities that conflict, or may conflict, with Casa Cor's interests;
  • Use your position to obtain undue advantages or benefits, directly or indirectly, for yourself or a third party;
  • Conduct any form of political disclosure and propaganda on Casa Cor premises or using Casa Cor materials and equipment.

5.2. Respect for people

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:

  • Zero tolerance for child labor, forced labor and slave-like labor;
  • Zero tolerance for sexual exploitation of children and adolescents;
  • Make fair, equitable job offers in accordance with local laws;
  • Guarantee the rights of migrant and/or refugee workers;
  • Promote diversity and offer equal and fair opportunities to all;
  • Promote a dignified, safe work environment free of harassment, bullying, prejudice and discrimination;
  • Allow freedom of association and the right to collective bargaining for Employees;
  • Ensure an inclusive environment where all people feel respected and safe to be who they are;
  • Provide healthy and safe working conditions;
  • Exercise its social and environmental responsibility and contribute to the development of a more sustainable society, preventing and mitigating negative impacts on the environment, people and communities.

It is everyone's commitment, when interacting with colleagues, Clients, suppliers and Business Partners:

  1. Maintain an attitude of respect and cooperation with all;
  2. Respect diversity, differences and individual values without discriminating against any person on the basis of color, race, ethnicity, gender identity or expression, nationality, origin and social class, age, marital status, sexual orientation, family matters, physical appearance, physical or mental disability, political stance, religion, lifestyle, or any other aspect;
  3. Combat and report any type of abusive behavior that characterizes sexual or moral harassment, bullying or other forms of abuse as well as physical and/or verbal aggression;
  4. Condemn aggressive or embarrassing attitudes;
  5. Respect intellectual property, recognizing the value and authorship of projects, ideas, proposals and initiatives, both from colleagues and third parties.

Therefore, the following is not permitted:

  • Verbally, morally and/or physically assault;
  • Make jokes that offend or have the potential to offend, intentionally or not, groups or individuals;
  • Make aggressive and/or prejudiced statements;
  • Tolerate any moral harassment behavior, such as: systematically devaluing the work of colleagues or Employees; or constantly ridiculing, directly or indirectly, a physical or psychological characteristic of colleagues or Employees;
  • Tolerate any sexual harassment behavior, such as: making suggestive remarks or comments about the appearance or sexual orientation of colleagues; sending unwanted messages of a sexual nature; intentionally promoting unnecessary and unsolicited physical contact or approach.

5.2.1. Occupational Health and Safety

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:

  1. Declare awareness and commitment to the rules contained in the health and safety manuals provided by Casa Cor and available on the intranet and the Company website;
  2. Adapt the workstation according to the guidelines described in the ergonomics manual - NR 17 and inform Casa Cor if there is any need;
  3. Know and comply with the health and safety procedures applied to your activity, according to instructions from the Specialized Services in Occupational Safety and Medicine – SESMT, disseminated through internal communications and policies available on the intranet;
  4. Report any and all risk situations identified in the workplace;
  5. Respond to occupational examination summons made by the Health Center;
  6. Strictly follow Casa Cor's guidelines for prevention of contagious, pandemic diseases, among others that require specific measures, such as, for example, COVID-19 (vaccine, social distancing, isolation, use of masks, among other measures eventually necessary);
  7. Participate in training, pay attention to internal communications and apply all guidelines received through them to avoid accidents and occupational diseases;
  8. Perform only the activity for which you have been properly guided, trained, qualified and authorized by Casa Cor;
  9. Report to Casa Cor whenever there is any condition that puts your health and integrity or that of your colleagues at risk.

The following is not permitted:

  • Store or carry any type of weapon, except when the function requires it and you have express permission to do so;
  • Work under the influence of substances that may compromise professional performance (e.g., alcohol or drugs, among others), as well as carry, buy or sell illicit substances on Casa Cor premises;
  • Refuse to comply with health and safety measures as well as applicable regulatory standards.

5.3. Lead by example

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:

  1. Contribute so that workplace relationships are always based on respect, courtesy, transparency and team spirit;
  2. Know, disseminate and comply with the company's internal norms and policies;
  3. Give clear feedback, based on facts and concrete data, aimed at the professional development of each team member;
  4. Share Casa Cor information that is of interest to team members, in order to ensure transparency;
  5. Not make decisions based on personal relationships;
  6. Not use the position to request personal favors or services from Employees;
  7. Disseminate and promote this Code, ensuring it is understood and adopted by team members;
  8. Provide equal access to professional growth opportunities according to the characteristics, competencies and contributions of each person;
  9. Not use a disproportionate and inadequate reprimanding tone of voice for the work environment, avoid reprimanding in public, not employ excessive rigor and not disqualify professionals.

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.

5.4. Fight against Corruption

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:

  1. Receive representatives of public bodies with courtesy and in a professional manner, providing requested information and documents and respecting legal requirements;
  2. Not promise, offer or give, directly or indirectly, any type of undue advantage to a Public Agent (or to any person related to the Public Agent who may influence their decisions as a public manager) that could bring any type of benefit – personal or institutional –, even if no consideration is required and/or no consideration is given by the Public Agent;
  3. Not promise, offer or pay bribes for obtaining information or advantages, even if the intended consideration is legitimate and the payment is intended to facilitate a public service;
  4. Not promise, offer or give any type of advantage or facilitation to Public Agents, such as "tips" or "gratuities", even if the practice is customary and seems common;
  5. Observe the rules of this Code regarding the offering of Courtesies to Public Agents and Politically Exposed Persons (PEPs);
  6. Not grant loans of movable or immovable property or funds or provide any type of favor or financial concession to a Public Agent, whether in the context of Casa Cor's institutional activities or in their private life, respecting private family and friendship circles.

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.

6. Conduct related to promotional items, gifts and other offers

6.1. General Rules

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.

6.2. Promotional items and Gifts

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.

6.3. Meals

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.

6.4. Entertainment

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.

6.5. Hospitality

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.

7. Conduct criteria in relationships

7.1. With Business Partners

The following are common conduct criteria for all Employees and service providers in relation to Business Partners:

  1. Comply with and honor agreements and contracts entered into;
  2. Select Partners based on technical, legal and professional criteria, through objective and transparent processes that ensure impartiality and serving Casa Cor's best interest;
  3. Maintain clear and transparent communication throughout the relationship with the Partner, without creating expectations that cannot be met;
  4. Require from Partners confidentiality and secrecy in the handling of data and information to which they may have access at any time, including phases before and after service contracting;
  5. Disclose and require from Partners compliance with the LGPD, Casa Cor Corporate Personal Data Protection Policy and all Casa Cor internal policies related to information security and Personal Data protection, which are applicable to all business partners;
  6. Not do business with unlicensed companies that engage in illegitimate activities and/or whose resources come from illegitimate sources;
  7. Actively encourage our Partners to share the same values we adopt in this Code;
  8. Legitimately defend Casa Cor's interests and those of the media and communication companies category;
  9. Reject commercial partners and suppliers that show any signs of use of slave, child or forced labor and illicit practices such as fraud, bribery and corruption and, if any irregularity is detected, refer your suspicion to the Legal and Compliance Directorate or directly to the Compliance Committee.

All Casa Cor Business Partners must observe the following conduct rules:

  1. Know and apply the principles, values and conduct rules established in this Code;
  2. Comply with Casa Cor's internal norms;
  3. Reject and not offer any undue payment or advantage (bribe or kickback), for any reason, aimed at celebrating, maintaining or guaranteeing a commercial relationship with or for Casa Cor;
  4. Act according to Casa Cor's ethical parameters, through dignified and ethical attitudes represented by compliance with legal, labor, environmental, health and occupational safety requirements;
  5. Avoid any interaction with Casa Cor, or on its behalf, that is characterized by conflict of interest;
  6. Promptly provide accountability when requested by Casa Cor;
  7. Not tolerate the use of child labor, slave labor and the like that may be considered a violation of human rights;
  8. Respect the confidentiality and secrecy of information shared resulting from the activities they develop with Casa Cor;
  9. Enter into a confidentiality agreement if requested by Casa Cor in case of exchange of confidential information;
  10. Safeguard the security of data and confidential information about Casa Cor, in physical or digital form, adopting due precautions to keep them confidential.

7.2. With Clients

The following must be a common standard of conduct for all Employees, service providers and business partners towards Casa Cor clients:

  1. Act in a transparent and ethical manner in commercial practices;
  2. Comply with agreements and contracts entered into;
  3. Evaluate and adequately address all criticism, suggestions and requests received;
  4. Ensure that the client receives a clear, objective and satisfactory response to their questions and requests;
  5. Respect client privacy, ensuring that information about the client is treated with confidentiality and used only with their knowledge;
  6. In the Processing of Client Personal Data, strictly observe the provisions of the LGPD, Casa Cor Corporate Personal Data Protection Policy and all Casa Cor internal policies related to information security and Personal Data protection;
  7. Base marketing and communication strategies on clarity of objectives so that the client has no doubts about the product and/or service purchased.

7.3. With competitors

The relationship with competitors must be based on respect, in accordance with current legislation, not spreading misleading statements about their products and services.

7.4. Conflicts of Interest

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:

  1. family relationships or affective relationship between Employees/third parties with hierarchical subordination and/or direct influence on the performance of tasks performed for Casa Cor;
  2. recruitment, promotion or annual performance evaluation of relatives or persons with whom one has an affective relationship;
  3. being part of the board of partners or senior management of a company with which Casa Cor maintains commercial relations;
  4. engaging in parallel competing and/or conflicting activities with those performed by Casa Cor;
  5. using Casa Cor resources for personal benefit or that of third parties; using the position or position held at Casa Cor for personal benefit or that of third parties;
  6. using privileged information for personal benefit or that of third parties; or
  7. hiring suppliers for reasons unrelated to their technical and commercial capacity.

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.

8. Conduct standard in the use of information, assets and Casa Cor brands

8.1. Conservation and proper use of equipment

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:

  1. Lock the equipment screen every time you leave it unused (even momentarily);
  2. Store the equipment in safe places, without access by third parties;
  3. Carry the equipment in bags, backpacks, carry-on luggage, etc., keeping it in the trunk only when in transit by car, not leaving it inside the vehicle when you are not in it and, if used on trips that depend on a plane, do not check it or place it in luggage carts;
  4. Do not insert into the equipment received USB drives, hard drives or other removable media of whose origin you have no knowledge;
  5. Do not use Casa Cor resources to download or distribute unlicensed software or data;
  6. Do not open Casa Cor equipment to perform any type of maintenance on your own; if repair is needed, request it from Casa Cor's Information Security team;
  7. Do not share access passwords, as they are non-transferable and confidential;
  8. Access Casa Cor systems via VPN containing access logs;
  9. Do not access pages with content considered offensive, illegal or improper through Casa Cor equipment;
  10. Do not use Casa Cor equipment for games or any purpose not linked to the functions and services provided to Casa Cor;
  11. Do not send electronic correspondence containing messages: ● defamatory, of indecent and obscene content, or in any way offensive to third parties; ● that intend to deceive anyone about the true authorship of the message or intend the anonymity of the same; ● that distribute software or information of third parties protected by legislation; ● that distribute programs containing viruses, intentionally; ● that initiate or continue chain letters, in any form or purpose.

8.2. Intellectual Property

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:

  1. Not publish, transmit, reproduce, manipulate, distribute, make available or use any intellectual property of Casa Cor or others without proper prior authorization;
  2. Not use or disseminate unauthorized or illegally obtained copies of any materials, content, illustrations or concepts.
  3. Be aware that all inventions made during the employment contract in which the inventive activity has been foreseen or results from the very nature of your functions are the property of Casa Cor, as well as the copyrights of the materials (photographic, journalistic, artistic, literary, scientific or educational);
  4. Report to Casa Cor in case of infringement or suspicion of infringement of the Company's intellectual property and its direct or indirect subsidiaries; and
  5. Respect the valid intellectual property rights of third parties.

8.3. Privacy and Personal Data Protection

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:

  1. Protect and safeguard all internal information of Casa Cor and its business, even after the end of the contractual relationship or commercial relationship;
  2. Formalize by e-mail the discussions and decisions made through telephone contact;
  3. Not handle confidential files within connections on open networks, public environments or similar;
  4. Communicate through internal and corporate mechanisms, such as Google Chat and corporate e-mail under the @abril.com.br domain;
  5. Store electronic and/or printed information in a safe place and only share it among those who have authorization to access it;
  6. Report to the Information Security Team any security incident of which they are aware, as well as all violations or suspicions of violations of the Information Security Policy or access or anomalies that indicate the possibility of an incident occurring;
  7. Not use any external network access devices that exceed or intentionally override Casa Cor's security controls;
  8. Not disclose Casa Cor information to people outside the organization, except when necessary for the Company's interests;
  9. Know the resources described in the Corporate Personal Data Protection Policy, the Information Security Policy and other applicable policies, being responsible for any loss or damage they may cause to Casa Cor or third parties as a result of non-compliance with the guidelines established therein.

For cases where personal equipment is used for work, the Personal Equipment Use Policy must be strictly followed.

8.4. Social Media

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:

  1. Not defend personal political opinions;
  2. Not create profiles on social media, blogs or microsites using Casa Cor's e-mail, name or brand;
  3. Not make posts on behalf of Casa Cor without prior express authorization from the Company;
  4. Not make derogatory comments about Casa Cor or third parties or threatening posts or content that is offensive, defamatory, intimidating, discriminatory or pornographic;
  5. Report to Casa Cor whenever viewing any information on social networks that is in breach of this Code;
  6. In case of doubt about the adequacy of any content to the rules of this Code or any other Casa Cor internal policy, consult the Compliance Committee before publishing or sharing it.

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.

9. Management of the Code of Ethics and Conduct

9.1. Questions, suggestions and reports of violations to this Code

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.

9.2. Compliance Committee

The Compliance Committee will be composed of:

  • Legal and Compliance Representative
  • Financial Representative
  • Human Resources Representative
  • Operations Area Representative

Among other attributions provided for in this Code, the Compliance Committee is responsible for:

  1. Keeping this Code updated;
  2. Permanently monitoring compliance with this Code and determining actions for the dissemination of its guidelines;
  3. Ensuring that our various areas of activity develop and implement the routines and procedures necessary for compliance with this Code
  4. Judging cases of alleged violation of this Code, based on reports eventually received, facts investigated and evidence collected;
  5. Evaluating and deliberating on questions of interpretation of the rules of this Code and eventual omitted cases.

10. Final Provisions

The provisions of this Code enter into force on the date of its publication and will remain valid indefinitely.

ANNEX 6.1

PROMOTIONAL ITEMS, GIFTS AND OTHER COURTESIES FORM

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

ANNEX 6.2

STANDARD THANK YOU AND RETURN LETTER

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 [=]