Ethics Policy

1. General Principles

Progic is a company whose mission is to humanize the corporate environment, transforming internal and external communication into an innovative experience that unites people, companies, and communities. We work tirelessly to connect people, integrate and facilitate understanding, promoting effective communication, collaboration, and growth for all.

To that end, it has Values ​​that govern its relationship with its employees, customers, suppliers, and other business partners. This document formalizes the ethical principles and standards of conduct directed at these relationships (internal or external) that have helped strengthen Progic’s reputation as an ethical, innovative, and sustainable company.

The principles presented in this Code of Ethics must be practiced throughout the value chain, regardless of where Progic or any of its representatives are located, seeking high standards of personal and professional integrity, and compliance with applicable laws, regulations, and standards.

2. Values Progic

a) Customer, b) Self-responsibility, c) Quality, d) Unity, e) Innovation

3. Existential Foundations

a) High need: A need shared by a large number of potential customers who are able to pay for the appropriate solution; b) Not fully met: A need that is not yet being fully met for most of these potential customers; c) Long-term: A need that exists due to macro-trends enabled by major socio-cultural-technological transformations.

4. Relationships Between Partners

All partners will have their rights respected and access to company information in a transparent manner, regardless of their shareholding.

Business relationships between Progic and family members of partners and other employees are permitted, provided they are guided by the principles of impartiality and transparency.

Ethics and the absence of conflicts of interest, subject to market conditions and company needs.

5. Relationships with Employees

Progic treats its employees with dignity, respecting individual differences and values, and providing a work environment with opportunities for professional and personal growth for all.

Relationships with employees will always be based on professionalism, trust, honesty, integrity, and impartiality, without the use of any abusive practices, always prioritizing their health and physical integrity above any economic interest. Abusive practices against employees, such as sexual harassment, arrogance, intimidation, threats, or anything that goes against the company’s values, are not permitted.

Progic expects its employees, in the performance of their duties, to adhere to established corporate procedures, as well as to conduct themselves honestly and with dignity, in accordance with the laws and ethical standards of society. It also expects that all company matters, without exception, will be handled by all employees with due secrecy and confidentiality.

5.1 Recruitment and Selection (R&S)

In any recruitment and selection process, the candidate must be carefully evaluated regarding their skills and other requirements for the position, without any discrimination.

In the recruitment and selection process, the possibility of internal recruitment will always be considered, providing professional growth opportunities for those who are already part of the staff. The selection of employees will be carried out using the same criteria applied to external candidates participating in the process.

Employees will only participate in the internal recruitment process with the authorization of their immediate supervisor.

In the recruitment and selection process, the candidate’s alignment with the company’s values ​​is an evaluation criterion, and this aspect is considered crucial for whether or not the candidate continues in the process.

The admission of blood relatives and relatives by marriage in the 1st and 2nd degrees is not permitted, such as, for example, father/mother, son/daughter, brother/sister, uncle/aunt, nephew/niece, brother-in-law/sister-in-law and adopted child, in addition to spouses for work in direct subordination.

5.2 Hierarchical Relationships

An employee’s participation in an internal recruitment process should be understood as a natural career advancement opportunity and should not give rise to any type of retaliation.

Everyone should listen to and consider new ideas and differing opinions, questions, and positions that represent a form of learning and process improvement, regardless of the employee’s hierarchical level.

Cooperation between departments should always be encouraged by everyone with the goal of the company’s overall growth and the sharing and dissemination of knowledge.

knowledge, while respecting the criteria of confidentiality and secrecy of privileged information.

It is everyone’s responsibility to point out the need for process improvements to avoid errors or their recurrence.

Respect between leader and follower is essential for the proper functioning of the company, and the principle of leadership should not be confused with arbitrariness.

It is the role of leaders to guide their team members on how they will be evaluated, making clear all the aspects that will be observed.

It is the responsibility of both the leader and the person being led to give feedback at any time in order to guide and improve each other’s performance.

5.3 Prejudice

Prejudice and discrimination of any kind are not tolerated, whether based on religious belief, philosophical or political conviction, nationality, sex, color, age, marital status, sexual orientation, physical conditions, or any other factor.

Everyone should be treated with the same respect, courtesy, and fairness, regardless of their position or role.

5.4 Harassment, Aggression and Violence

Progic does not tolerate any form of aggression, violence, or harassment, whether verbal, sexual, economic, moral, or of any other nature, nor situations that constitute disrespect, intimidation, or threats in the relationship between employees, regardless of their hierarchical level.

5.5 Child or slave labor

Progic does not tolerate, in its operations or in its relationships with suppliers and partners, slave labor, analogous conditions, or child labor, except under the condition of Young Apprentice, in accordance with current legislation and without prejudice to studies.

The protection of children and adolescents is a top priority. Any content, behavior, or activity involving exploitation, sexual abuse, misuse of products by minors, or any form of child labor is prohibited.

Progic complies with applicable legislation regarding the protection of children and adolescents and cooperates with the competent authorities whenever necessary.

The following are expressly prohibited:
a) Use of company products by minors, b) Any form of abuse, sexual exploitation or enticement of children and adolescents, c) Child labor or use of child labor, except in legal cases, d) Sharing or distribution of material related to child sexual abuse, e) Falsification of age or identity to circumvent these rules.

Any indication of a violation of these principles must be reported immediately through the Whistleblowing Channel.

5.6 Use of weapons, drugs and sale of goods

The possession and consumption of illicit drugs, or the consumption of alcoholic beverages, as well as the performance of duties under their influence, are not permitted in the workplace, due to the impact on professional performance and the safety of everyone.

No weapons of any kind are permitted on company premises, with the exception of employees expressly authorized to carry them.

The sale and exchange of goods for personal use is prohibited during working hours on company premises.

5.7 Private employee information

Progic respects the privacy of its employees and therefore access to their personal information is limited only to those with a legal right to view it, and even then, only when necessary for the performance of their work.

Employees’ personal information will only be collected or processed for business reasons and always in accordance with current legislation.

It is the employee’s responsibility to provide information in order to keep their personal data up-to-date with the company.

5.8 Company assets

Progic’s assets, equipment, and facilities are intended exclusively for use in its operations and may not be used for private purposes, except in specific situations defined by the company.

It is the employee’s responsibility to ensure the proper use and preservation of company property placed under their care.

Purchases, sales, write-offs, or disposals must be carried out in accordance with the company’s internal rules and in its best interest.

Employees are prohibited from using company assets, services, and credits, including intellectual and industrial property rights, as well as strategic and confidential information belonging to the company, for their own benefit or that of third parties.

5.9 Activities and services external to the company

Engaging in activities, services, or even employment outside the company cannot interfere with the work to be performed at Progic.

The company encourages volunteer work activities.

No activity is permitted that represents an immediate or future conflict with the activities and interests declared and disclosed in Progic’s Strategic Plan. This applies to employees, partners, family members of any degree, and business associates.

It is recommended that any initiative in this regard, even if it does not currently conflict with the company’s interests, be duly communicated to the Ethics Committee, thus protecting against future conflicts.

Activities carried out outside of Progic should in no way harm the company’s image. Employees must act prudently and diligently, not exposing or jeopardizing the company or their own careers.

Employees are expected to behave in a way that is consistent with the company’s values ​​and the conduct described in this code.

5.10 Use of electronic information systems

Electronic systems and Information Technology resources are available to employees to support the proper performance of their duties. Their use for personal matters is permitted as long as it does not violate the rules and guidelines defined in the Technology Manual or hinder the performance of their responsibilities.

Progic may, at its discretion, use and monitor any information transmitted or residing in these media. Therefore, users in general should not expect privacy when using the systems and resources.

All files and information relating to professional activity created, received or stored in electronic systems are the property of Progic and constitute commercial and legal assets.

The password for accessing systems and information is personal and non-transferable, and is for the exclusive use of each employee. It is not permitted to share it with third parties or colleagues.

5.11 Intellectual Property and Confidentiality

Intellectual property is a strategic asset for Progic, representing a competitive advantage for the company. All patents, trademarks, know-how resulting from intellectual work carried out by the company, technical data, process information, market information, or strategic information are the exclusive property of Progic.

Every employee is responsible for treating information about intellectual property to which they have access in the course of their work in a confidential and secretive manner, using it carefully and not disclosing it without the express authorization of the company.

Progic also respects the intellectual property rights of third parties.

6. Customer Relations

Progic’s core values ​​include the constant pursuit of customer satisfaction and generating value for them by meeting their expectations and developing innovative, high-quality solutions and technologies.

Progic does not discriminate against clients based on origin, economic size, or location; however, it reserves the right to terminate any business relationship whenever its interests are not being met, or when the relationship poses a legal, social, or environmental risk.

Information about our products and services must be clear and truthful. Each product strictly adheres to the legal requirements of the market it is intended for.

All Progic employees are expressly prohibited from making or receiving any improper, dubious, or illegal payments, or from granting/receiving undue privileges or benefits outside of usual business practices, whether directly or through third parties, with the intention of facilitating the sale of our products and services, even if this results in lost business opportunities.

All Progic customers must be treated with courtesy and efficiency, being offered clear, accurate and transparent information within the agreed deadlines and in the agreed manner.

Relationships with Progic clients must be conducted with mutual respect and honesty in negotiations, in compliance with local and international laws, always observing strict respect for privacy and the protection of personal data that may be processed (such as access, use, and storage) for the exclusive purpose of fulfilling contractual obligations and activities essential to the operation of Progic’s business.

Any attempt at bribery, favoritism, or violation of this code must be reported to the Ethics Committee, ensuring privacy where applicable.

7. Supplier Relations

Relationships with Progic suppliers, including those companies that provide services within the company’s premises (contractors), must be based on mutual respect and honesty.

The hiring of any supplier should always be based on technical, professional, ethical, and economic criteria, aligned with Progic’s general guidelines and values.

Progic suppliers must conduct themselves in accordance with the principles defined in this Code. Therefore, clarity in the description of products and services is expected, as well as respect for the confidentiality of information in this relationship.

Progic may terminate its business relationship with a supplier whenever its interests are harmed or legal, tax, social, environmental, and occupational health and safety issues are disregarded.

All employees (or their legal representatives) are expressly prohibited from making or receiving payments as gratuities, or offering/receiving any gratuity or advantage to suppliers to influence any company decision. Therefore, the receipt/payment of bribes, kickbacks, illicit commissions, and similar payments is strictly prohibited, as it violates ethics and may subject Progic and the employees involved to criminal proceedings or legal penalties. Attempts at preferential treatment must be immediately reported to the area manager or the Ethics Committee.

8. Relationships with Competitors

Progic’s relationship with competitors is based on respect for free and fair competition. All legitimate market and competitor information necessary for the business must be obtained through transparent and ethical practices, and obtaining it through illicit means is not permitted. Here, illicit means are illegal and morally unacceptable ways of accessing confidential information.

No statements, verbal or written, should be made that could affect the image of competitors or contribute to the spread of rumors about them; competitors should be treated with the same respect that Progic expects to be treated.

It is prohibited to provide competitors with any information about Progic’s business and products.

It is forbidden for any employee to maintain agreements with Progic’s competitors aimed at fixing prices and/or sales conditions, adopting or influencing the adoption of uniform or pre-agreed commercial conduct, dividing the market, or subordinating the sale of one product to another.

9. Relations with the Federal, State, and Municipal Governments

Progic respects the law and expects the same conduct from all its employees wherever it operates. Relationships with the government, at any level, must be frank and constructive.

The provision of information to any level of government, including municipal bodies, must always be in writing, officially registered, and with the proper guidance of the Legal Department, regardless of its content or purpose. The information sent must be accurate and sufficient to clarify the issue addressed, in order to strictly comply with current and applicable laws and regulations.

All employees (or their legal representatives) are expressly prohibited from making payments as gratuities, or offering any gratuity or advantage to public officials and government authorities to influence any decision for the benefit of the company. Therefore, payments of bribes, kickbacks, illicit commissions, and similar payments are strictly prohibited, as they are unethical and may subject Progic and any employees involved to criminal proceedings or legal penalties.

Offering any type of benefit as a gesture of gratitude or reward, even on a personal basis, is prohibited.

All supply, employment, financing, service, and consulting/advisory contracts must be submitted beforehand to Progic’s legal department for evaluation, guidance, and approval.

Attempts to obtain preferential treatment should be immediately reported to the area manager or the Ethics Committee.

10. Relationship with the Environment

Progic constantly seeks to reconcile its activities and business operations with sustainable development, environmental preservation, and the health and physical integrity of its employees.

Everyone is expected to carefully observe the work environment and potential environmental risks – both inside and outside the company – acting proactively in relation to them, and informing their direct leadership when situations outside the company or competent authorities are directly involved so that corrective actions can be taken.

Progic will always obtain environmental permits when necessary, aiming to understand the risks to the environment before taking any action that could impact it. It will always follow the rules established for this purpose.

11. Relationship with the Community

Respect for individuals and citizen institutions – governmental or otherwise – guides Progic’s relationships with the communities where it operates.

The company encourages all employees to participate in volunteer programs.

Investment in social, cultural, and environmental projects should be guided by the real needs of the communities involved in order to promote social transformation. Therefore, any donations, sponsorships, or other forms of support for social development and the improvement of living conditions for people and communities should be carried out in accordance with guidelines of sustainability, engagement, and volunteerism.

12. On Confidentiality and Protection of Personal Data

In the performance of their professional duties, partners, employees, and service providers may carry out actions classified as the processing of personal data under Law No. 13709/2018 (General Data Protection Law) or Regulation 2016/679. In accordance with the requirements of current legislation and in order to ensure the security and protection of personal data, all professionals involved in Progic’s activities must:

a) Follow corporate guidelines and rules (information security policy) related to the use of devices (hardware) and applications (software), prohibiting the use of unauthorized equipment or systems, except with the express prior authorization of the department responsible for information security at the employer; b) Follow corporate guidelines and rules related to the proper use of personal data, strictly observing its contractual purposes; c) Report, as soon as detected, any type of failure, defect, or error in the operation of systems or procedures that may represent any type of risk to information security, whether or not involving personal data; d) Guarantee and safeguard the confidentiality of information handled in their activity, especially personal information, under penalty of termination of the contract for just cause.

13. From the Ethics Committee

The Ethics Committee must ensure that the institution’s decisions, conduct, and practices are aligned with ethical and legal values.

13.1 The responsibilities of the Ethics Committee will be:

a) To ensure compliance with the organization’s Code of Ethics and Conduct, guaranteeing that its principles are understood and applied by all employees; b) To analyze and issue opinions on cases of questionable ethical conduct, conflicts of interest, complaints, or breaches of the code; c) To receive, investigate, and deliberate on complaints of ethical infractions, ensuring confidentiality, impartiality, and the right to defense of the parties involved; d) To guide managers and employees regarding the expected ethical conduct in professional and institutional relationships; e) To promote educational and preventive actions, such as lectures, training, and campaigns on ethics and integrity; f) To recommend improvements or updates to the Code of Ethics; g) To monitor the implementation of corrective measures resulting from ethical investigations and recommendations; h) To maintain records and reports of the Committee’s activities, preserving the confidentiality and transparency of the processes; i) To act as an advisory body, providing support to senior management and company areas in decisions involving ethical dilemmas; j) To foster an ethical organizational culture, based on… with respect, fairness, social responsibility, and compliance with laws and regulations.

13.2 Constitution of the members of the Ethics Committee

The Ethics Committee will be composed of members appointed by senior management.

Taking into account the diversity across areas, Senior Management will appoint four members to the Committee and one member from Senior Management, which will be structured as follows:

a) A representative from the Human Resources area, b) A representative from the Legal area, c) A representative from the Finance area, d) A representative from the Operations area, e) A representative from Senior Management.

13.3 Of the Mandate

The members of the Ethics Committee will have two-year terms, after which the senior management will appoint new members to the Committee or may continue to renew those previously appointed.

13.4 Meeting Frequency

Regular meetings will be held every three months, and extraordinary meetings whenever necessary.

14. Communication and Policy Updates

This policy will be widely disseminated and reviewed periodically, according to company needs, legal or strategic changes.

Any updates will be communicated to all employees through official channels.

Note: This Policy has been automatically translated from its original version in Portuguese.