Code of ethics and conduct

1.1. Understanding Our Beliefs

Founded on October 26, 1984, CBAA – Asfaltos Ltda. focuses on the development of Cationic Asphalt Emulsions, having Quality Certification NBR ISO 9001/2015.

The mission
Production, commercialization and distribution of asphalt products in Brazil, prioritizing safety, quality and the environment.

The vision
Have more than 10% representation in all regions of BRAZIL where we operate, with total focus on our CUSTOMERS to improve the country’s infrastructure.

The values

• Security
• Partnership
• Excellence
• ethic
• Efficiency
• Quality
• employability
• Sustainability

1.2. To Whom and How Our Code of Ethics Applies

The general guidelines provided for in this code must be complied with by the Board of Directors, employees, young apprentices, interns, and third parties involved in the provision of services.

All those involved have access to this Code, through the company’s website, for reading, understanding and applying the rules on a day-to-day basis. Its importance is directly linked to the promotion of ethical conduct in the work environment, with the primacy of broad respect and the development of a satisfactory organizational climate.

2.1. Respect for Workplace Safety and the Environment

Within the work environment, CBAA seeks to ensure a safe place that respects the environment. For this reason, we aim to maintain a zero-risk working day, with adequate facilities and equipment, in addition to ethical and conscientious conduct.

2.1.1. Regarding Occupational Safety, what do we expect from our employees in general:

• Try to take care of yourself and your co-workers, first of all;
• Put your health/safety and that of other people first, not accepting situations where any production process could expose you to risks;
• Do not agree to work in an environment that puts your life and that of other people at risk;
• Warn those responsible if there are situations that pose risks to the integrity of employees and other people, as well as in the event of accidents and work-related illnesses;
• Know and comply with strict compliance with legal rules and internal guidelines regarding health and safety within the company;
• Seek training and only perform activities in which you are technically qualified, with due authorization and in suitable conditions so as not to endanger your physical and mental health;
• Do not drink alcohol or use illicit drugs or other substances that compromise your ability to perform tasks and put yourself and/or co-workers at risk;
• Meet the company’s standards regarding admission, periodical and dismissal medical examinations;
• Act prudently and know how to proceed in emergency situations.

2.1.2. As for the Environment, what do we expect from our employees in general:

• Respect the environmental legislation, meeting its requirements;
• Immediately inform those responsible for the unit where you work, if you become aware of any environmental accident on or near the company’s premises;
• Prioritize actions within the company, such as facilities, infrastructure and other projects that respect and minimize environmental impacts;
• Be aware of the conscious and sustainable consumption of resources, such as water, fuel and electricity, avoiding the generation of waste and toxic products that could contaminate the environment;
• Carry out actions to map environmental risks, in order to guarantee environmental preservation and compliance with current legislation.

2.2. Respect for Diversity and Human Rights

Respect is a fundamental premise for our company, especially with regard to ethnic, racial, cultural, gender, religious, special needs and whatever else may guarantee the preservation of the fundamental rights of the human person, in their broad understanding.

Thus, we expect ethical and moral behavior from employees, in view of everyone’s rights and duties, where differences are respected and no one feels their unique freedom has been infringed.

Therefore, attitudes and/or postures that confront or disrespect this very important premise are not accepted, where the appreciation of differences and the recognition of diversity constitutes a driving agent for valuable exchanges of experiences and the development of knowledge and the organization.

2.3. Conflict Management and Interpersonal Relations

The company seeks to act ethically, carrying out and encouraging, through training and management guidelines, people management aimed at a satisfactory organizational climate, where there is respect and the development of teamwork.

In this sense, we expect from everyone the non-occurrence of conflicts and positive management in the face of possible situations that impose this premise. Thus, we encourage and seek to motivate our employees, so that healthy interpersonal relationships prevail in the work environment. For this, we advise that there is assertive, clear communication, which can inhibit unnecessary conflicts.

It is up to employees, especially those in leadership positions, to manage disputes, if they occur, minimizing and eliminating adverse consequences and looking for ways to intervene and/or resolve the conflict.

2.4. Combating Moral and/or Sexual Harassment

The company does not condone attitudes or practices that may characterize moral and/or sexual harassment, characterized by the abuse of power, by behaviors that may humiliate, embarrass or coerce employees, creating vexatious situations that may ridicule the person or harass the person morally and/or sexually, violating the principle of respect and ethics of good coexistence and satisfactory organizational climate.

In this way, in the face of complaints for these types of situations, the Human Resources Sector will investigate the information confidentially, listen to the report of the employees involved and, through analysis of what happened, guide the Board to proceed with the appropriate disciplinary sanctions, based on the company’s Internal Regulations and current legislation.

It should be noted that the company acts actively and periodically to raise awareness, prevent and investigate any situations of moral and sexual harassment, including under the terms set forth in Ordinance no. 4,219 of the Ministry of Labor and Social Security, regardless of whether or not the company has a CIPA, under the terms of the law. In investigations related to moral and sexual harassment, the results of investigations will be shared with CIPA.

3.1. Respecting the Anti-Corruption Law

The Anti-Corruption Law provides for the administrative and civil liability of legal entities for the practice of acts against the public administration, nationally or abroad (Article 1 of Law 12,846/2013). It was created to combat harmful acts committed by companies to public entities, especially in bids and contracts.

Corruption is the act or effect of corrupting. It is a worldwide social, political and economic phenomenon that culminates in damage to democratic institutions, preventing economic development and contributing to political instability and social inequality.

In view of this, the company does not tolerate corrupt attitudes, in which there is an interest in obtaining or generating advantages or gains for itself or third parties.

Because of this, CBAA presents an Integrity Program, which establishes the rules that must be followed within the company. This program is available for all employees to read on the company’s website, along with this Code of Ethics.

The Anti-Corruption Law provides, at the administrative level, for the imposition of a fine that may vary from 0.1% to 20% of the last gross billing. The punishment is provided for in Article 6 of Law 12,846/2013.

Art. 6 provides that “The following sanctions will be applied to legal entities considered responsible for the harmful acts provided for in this Law:”

• In the Administrative Sphere:

I – Fine, in the amount of 0.1% (one tenth percent) to 20% (twenty percent) of gross revenue for the last fiscal year prior to the filing of the administrative proceeding, excluding taxes, which will never be less than the benefit earned, when possible its estimation; It is

II – Extraordinary publication of the conviction.

• In the Judicial Sphere:
  • Loss of assets, rights or values ​​that represent an advantage or benefit directly or indirectly obtained from the violation;
  • Suspension or partial interdiction of its activities;
  • Compulsory dissolution of the legal entity;
  • Prohibition of receiving incentives, subsidies, grants, donations or loans from public bodies or entities and public financial institutions or those controlled by the public authorities.

In view of current legislation and the ethical and integrity view of the company, its employees and partners, we do not allow actions, attitudes or postures that may infringe or disrespect the principles, values and the law mentioned here.

3.2. Combating the Practice of Bribery

It is necessary to understand that bribery is linked to corruption. Thus, combating these issues is so important that ISO 37001, also called the Anti-Bribery Management System, was created.
Under this rule, bribery is characterized as: “the offer, promise, donation, acceptance or solicitation of an undue advantage of any value (which may be financial or non-financial), directly or indirectly, and regardless of location, in violation of applicable laws , as an incentive or reward for a person who is acting or failing to act in relation to the performance of his obligations”.

Our company does not, in any way, accept bribes of any kind. Therefore, to inhibit this practice, we will apply severe punishments to offenders.

We understand the benefits of anti-bribery actions:

• Credibility before the market and society as a whole;
• Greater competitive advantage over the competition;
• Attractiveness for investments;
• ethical organizational culture;
• Prevention of ethical deviations, such as misappropriation, corrupt practices and manipulation of financial statements;
• Management with sustainability and greater profit margin;
• Pointing and continuous assessment of risks, with prevention and significant reduction;
• Improved efficiency and quality of services/products;
• Expansion in the improvement of management levels;
• Promoting the company’s transparency in all its processes;
• Reduction of expenses with payment of fines and penalties.

The ethical attitude in the development of the company’s activities needs to go beyond the legal obligation. It needs to be embedded in the organizational culture, where everyone is engaged and aware of responsibility within the company and towards society.

4.1. Ensuring Confidentiality and Information Security

In view of the advancement of technologies and the ease of access to the most diverse means of communication, we understand that it is necessary to preserve secrecy and guarantee security in the use of company information.

It is advised that:

• Be careful when passing on company information, whether in private and/or public places, even in informal conversation;
• Only use company information for purposes of exclusive interest to our organization, unless there is formal authorization from management, for some different purpose;
• Copies, backups and reproduction of company content are expressly prohibited for purposes of personal interest or of third parties;
• Do not share or disclose confidential images and information to external entities or public media, for use in the company’s internal processes, without prior authorization from management;
• Communicate and denounce practices that violate our guidelines for the preservation of information security and the misuse of documents, content and even the use of access passwords by third parties, without the knowledge and authorization of the company.
• Failure to comply with ethical practices and information security guidelines will incur strict disciplinary sanctions, supported by current legislation.

It is important to highlight that the CBAA presents a Privacy and Data Protection Policy – PPPD, as it is in line with what the LGPD requires.

This document sets out the rules, rights and duties that must be met by all employees, with regard to the protection of personal data. It should be noted that said policy is available on the company’s website for reading.

4.2. Using Social Networks

With the development of computer technology and the emergence/expansion of the use of social networks via the internet, where people relate through websites and virtual platforms, it is necessary to be aware of the direct and indirect impacts through the publications and shares generated. For example, we have the use of profiles on social networks such as Facebook, Instagram, Twitter, Linkedin, among others.

In this regard, we recommend that:

• Use common sense and care when disclosing images, information and news that may have some interference or association with the company’s copyright and personality;
• Do not disclose images with a uniform, badge or inside the company’s premises;
• Only disclose or share information and content of interest to the company, with due prior authorization from the respective board;
• It is always advisable to choose to preserve our professional self-image and ensure respect for the image of co-workers and our company.

5.1. How to Take Care to Preserve It

Acting ethically and with respect for others and the place where we work is something that is expected of any and all professionals who seek credibility in the job market. Therefore, our company could not expect anything different from its professionals, collaborators and partners.

In this way, it is everyone’s duty to preserve and guarantee respect for its guidelines, maintaining a good relationship, taking care of the reputation and integrity of employees and the company, respecting the norms, procedures, established values and the existing organizational culture.

Thus, we aim to always cultivate a good work environment, through attitudes and decisions aligned with the common objectives and interests of the company, which constitute the guiding principle of the business vision and mission.

Take care of the Code of Ethics and Conduct of the company CBAA – ASFALTOS Ltda. it’s everyone’s responsibility.

We believe that we can rely on each one, in the guarantee of this care and in the expected preservation.

5.2. Failure to comply with the Code

Failure to comply with the procedures, rules and recommendations described in this Code of Ethics and Conduct will subject the violator to disciplinary sanctions. Are they:

• Verbal Warning;
• Written Notice;
• Suspension or;
• Resignation.

Matters related to non-compliance with this Code will be dealt with by the Human Resources Sector together with the company’s management, with penalties applied according to the seriousness of the act practiced.

Click here to access the Term of Commitment.

5.3 Reporting Channel

In order to guarantee the preservation of this code, the company has a Reporting Channel that can be accessed by all employees and third parties, so that, even anonymously, they can formalize situations of non-compliance with the rules of this code.