1. INTRODUCTION
LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. is a company that operates in the Information Technology segment, aiming for growth, within ethical principles and the satisfaction of its clients and similar institutions, always seeking to maintain a solid reputation, with awareness of its social and environmental responsibility. Its activities must always be guided by integrity, trust and loyalty, as well as respect and appreciation for human beings and their privacy, individuality and dignity, without any prejudice or form of discrimination.
2. OBJECTIVE
The purpose of this CODE OF CONDUCT & ETHICS is to resolve issues related to: (i) compliance with the rules of coexistence in the workplace, without distinction of hierarchy, gender, race, creed, sexual orientation, or any other form of discrimination in the areas or functions performed; (ii) the transparency of operations in general; (iii) the safety of the activities of the professionals involved; and (iv) the security and secrecy of information that must be protected by confidentiality.
3. SCOPE AND PERIODICITY
The CODE OF CONDUCT & ETHICS includes conduct guidelines based on ethical and moral standards that will serve as a benchmark for the behavior of all employees, both internal and external, and its application is incumbent on all members of the LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. staff, in the performance of their duties, including service providers, suppliers and business partners who are linked to the institution.
Compliance training, refresher courses and certifications are carried out annually throughout the company, keeping all the concepts and regulations on the subject up to date.
4. DISCLOSURE AND PROCEDURES
This CODE OF CONDUCT & ETHICS will be publicly available on the Company's WEBSITE at http://www.lgkservicos.com.br/ouvidoria, as well as physically distributed in the common areas, for consultation by employees at any time, under the responsibility of the Company's Legal Representative:
ensure compliance with this CODE OF CONDUCT & ETHICS, as well as with the legislation that provides for the administrative and civil liability of legal entities for the practice of acts against the national or foreign Public Administration (Law 12.846 of August 1, 2013);
inform new employees of the CODE OF CONDUCT & ETHICS, keeping a record of their knowledge and agreement;
promoting the wide dissemination of the Code and its updates to the Company's staff, clients, service providers and suppliers;
clarify doubts and check understanding of the content and application;
recycle its content periodically in order to keep it up to date;
in the event of an accusation or suspicion, the collaborator or manager involved will be immediately removed until the investigations are complete;
if the direct or indirect participation of the collaborator or manager is proven, the measures provided for by law will be applied.
5. VALUES
- Respect for people.
- Social responsibility and citizenship.
- Professional and personal integrity.
- Transparency in processes.
- Proud to work at LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA.
- I like challenges.
- Equity of Gender, Race, Creed, Sexual Orientation, etc.
- Commitment to results.
- Technical competence.
- Trust and credibility.
- Confidentiality and security of information.
6. ETHICAL PRINCIPLES
The managers and employees of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. base their actions on the following principles in their dealings with the various sectors of society, ensuring:
6.1. TO CUSTOMERS
6.1.1 Professionalism, trust, confidentiality and transparency;
6.1.2 The availability of solutions that add value to its clients' businesses, by permanently investing in the search for appropriate technologies and the improvement of business strategies;
6.1.3. valuing and respecting compliance with agreements and contracts, as well as the rights of its clients;
6.1.4. valuing the business opportunities and partnerships built with its clients, seeking results for the benefit of society; and
6.1.5 Identifying, proposing and implementing innovative and integrated solutions that contribute to strengthening the legitimacy and sustainability of its clients.
6.2. TO GOVERNMENT AGENCIES
6.2.1 Recognizing the role and supporting the work of the supervisory bodies, providing them with relevant and reliable information at the appropriate time;
6.3. TO PEOPLE
6.3.1 Maintaining a working environment where relationships are based on professionalism, trust, cooperation, integration, respect for individual differences and urbanity;
6.3.2 Sharing their knowledge and experience, seeking to improve technical training, methods and processes in order to achieve better overall results for the company;
6.3.3 Valuing people, contributing to their personal, technical and professional development;
6.3.4 The permanent zeal for the appropriate and economical use of the Company's material, technical and financial resources;
6.3.5. Preserving and respecting the Company's image, assets and interests;
6.3.6. Recognizing and valuing the company's intellectual capital and encouraging the emergence of new leaders; and
6.3.7. Valuing and encouraging individual and collective ethical conduct.
6.4. SUPPLIERS AND SERVICE OUTSOURCING COMPANIES
6.4.1. legality, impersonality, morality, publicity and efficiency in all acts carried out;
6.4.2 Maintaining a relationship based on mutual respect, preservation and confidentiality of information pertaining to the Company and its clients;
6.4.3 Relationships with suppliers and partners whose practices are in line with the ethical standards adopted by LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. and social morality;
6.4.4. The establishment of partnerships, provided that the image and interests of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. are preserved; and
6.4.5. Rejection of contractual provisions that undermine or minimize the dignity, quality of life and social well-being of outsourced employees.
6.5. REPRESENTATION OF EMPLOYEES, ASSOCIATIONS AND INSTITUTIONS
6.5.1 Recognizing the legitimacy of and maintaining a permanent dialogue with legally constituted institutions representing workers, maintaining channels of dialogue based on mutual respect, seriousness, responsibility and transparency in relations;
6.5.2 Negotiation as a suitable instrument for seeking integration and convergence;
6.5.3. compliance with the provisions set out in the instruments that regulate the company's relationship with its employees;
6.5.4 Ensuring clear and objective communication, which must include the company's disclaimer, guaranteeing the correct addressing of e-mails and documents, as well as relevant information.
6.6. TO THE COMMUNITY
6.6.1 Establishing fair and balanced relations with the community by encouraging, promoting, supporting and participating in social responsibility and citizenship actions;
6.6.2 Encouragement, support and participation in government actions aimed at social development, combating poverty and sustainability; and
6.6.3 Encouraging the social, cultural and sporting initiatives of its employees.
7. CODE OF BUSINESS CONDUCT
The managers and employees of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. must conduct themselves in accordance with this Code of Business Conduct, under the terms listed below.
7.1 Acceptable conduct for managers and employees of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA:
7.1.1 Preserving and cultivating the company's positive image;
7.1.2. only sell products and services owned by and of interest to LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA on the Company's premises;
7.1.3 Developing conditions conducive to establishing a productive, respectful and pleasant climate in the workplace;
7.1.4 Treating people and their ideas with dignity and respect;
7.1.5 Proceeding with loyalty, fairness and frankness in work relations;
7.1.6. Preserving the well-being of the community, respecting personal characteristics, freedom of opinion and the privacy of each individual;
7.1.7. acting clearly and loyally in defense of the interests of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA;
7.1.8. Present themselves in an appropriate manner for the performance of their duties and activities at the Company;
7.1.9 Refraining from using internal or external influence to obtain personal or functional advantages;
7.1.10. refraining from using their position, the position of trust they hold or their status as an employee of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. to obtain advantages for themselves or for third parties;
7.1.11. use LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. resources only for purposes of interest to the Company;
7.1.12. Contribute to the smooth running of the entire Company, refraining from acts and attitudes that prevent, hinder or disrupt the provision of services;
7.1.13. refuse, and refrain from offering, gifts and/or presents worth more than R$ 100.00 (One Hundred Reais) to individuals and/or legal entities that maintain commercial relations with LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA.
7.1.14. Failure to prepare and/or present information that reflects actual economic, financial, operational, logistical and any other positions and results that affect the Company's performance;
7.1.15. prioritizing and preserving the interests of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. with clients, government bodies, financial institutions, suppliers, entities and other companies with which LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. maintains a commercial relationship;
7.1.16. always be accompanied by another employee, the manager or a peer when holding any relationship (meetings) with a supplier or partner that results or may result in a contract that meets the interests or needs of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA;
7.1.17. Strictly agreeing to the company's guidelines and strategic conduct when taking on a position of trust with the company; and,
7.1.18. Resign from the position of trust to which he/she has been appointed, when there is dissonance with the company's strategic guidelines and orientations.
7.2 Unacceptable conduct towards the managers and employees of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA:
7.2.1 Claiming personal benefits or advantages for themselves or third parties as a result of commercial or financial relationships entered into on behalf of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. with clients, government bodies, financial institutions, suppliers, entities and other companies with which LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. maintains this relationship;
7.2.2. conniving at or failing to act in relation to errors and infringements of this CODE OF CONDUCT & ETHICS and the legal and regulatory provisions in force;
7.2.3. carrying out other professional activities during working hours, whether for profit or not, or, regardless of the compatibility of working hours, carrying out activities that constitute a detriment to, or direct or indirect competition with, the activities of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA;
7.2.4. discriminating against people in any way on the grounds of economic, social, political, religious, color, race or sex;
7.2.5 Allowing persecution, sympathy, antipathy, whims, passions or personal interests to interfere with their professional relationships;
7.2.6. deliberately damaging the reputation of a Company employee or any other professional with whom LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. has a business relationship;
7.2.7 Deliberately damaging the reputation of customers, government bodies, suppliers, entities and other companies with which LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. maintains a business relationship;
7.2.8. Requesting, soliciting or receiving gifts or advantages of any kind, for themselves or for third parties, beyond the mere insinuation or provocation for the benefit to be given, in exchange for concessions or privileges of any kind with LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA;
7.2.9. prioritizing and preserving personal interests, those of clients, government bodies, financial institutions, suppliers, entities and other companies, to the detriment of the interests of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA;
7.2.10. Obtaining advantages, for themselves or for third parties, as a result of privileged access to LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. information, even if they do not cause damage to the Company;
7.2.11. use documents, work, methodologies, products, tools, services and information belonging to LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. or its clients and suppliers for their own benefit or pass them on to third parties, except by legal or judicial order;
7.2.12. Speaking on behalf of the Company, by any means of public disclosure, when not authorized or qualified to do so;
7.2.13. Making inappropriate and uneconomical use of the Company's material, technical and financial resources;
7.2.14. Preventing or hindering the investigation of irregularities committed within the Company;
7.2.15. Altering or misrepresenting the content of any document, information or data for which the Company or third parties are responsible;
7.2.16. Facilitating actions by third parties that result in loss or damage to the Company;
7.2.17. generating any kind of confusion of assets between the Company's assets and its own assets, regardless of whether any pecuniary advantages arise from this confusion;
7.2.18. remaining in the position of trust to which he/she has been appointed, when there is dissonance with the company's strategic guidelines and orientations; and
7.2.19. Making donations to political parties.
8. COMPLIANCE WITH THE CODE OF CONDUCT & ETHICS
If in doubt about the correct course of action, the employee should seek help from the Human Resources Department in a sincere and transparent manner.
Any situation that could characterize a conflict of interest, or facts that could harm the company or go against the principles of this Code, must be immediately and formally communicated to the company's legal representative.
The company guarantees confidentiality in the handling of these matters and is committed to investigating the cases reported.
Situations that are not explained here will be treated as exceptions and referred to the company's legal representative, who will analyze and decide within the principles of this Code.
This CODE OF CONDUCT & ETHICS reflects the values and culture of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. and compliance with it reveals a commitment to professionalism and transparency in all its actions at work.
Failure to comply with the CODE OF CONDUCT & ETHICS will subject employees to disciplinary action, including dismissal for just cause and legal proceedings.
All those who have a direct or indirect relationship with LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA. must be aware of and ensure compliance with this Code, and have the same ethical commitments, regardless of the position they hold.
Failure to comply with any of the practices and/or procedures described herein may influence the credibility of LGK SERVIÇOS EM TECNOLOGIA DA INFORMAÇÃO LTDA.'s institutional image in the eyes of clients, the market, supervisory and regulatory bodies, the government and society in general.
This Code takes effect from the date of its publication.
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