Ethics and Conduct

Code of Ethics and Conduct of DM11® [IT Risk Protection]

Last Update: October 2023

1. Introduction

This code of conduct and ethics brings together the precepts and guidelines considered essential as part of the Improvement of behavioral processes of DM11® [IT Risk Protection], focusing on its growth with maintenance of the quality of its services.

Therefore:

2. Enchanted customer

Customers enable the mission and business of DM11® and the company aims to contribute decisively to the success of their enterprises. For DM11®, keeping the customer enchanted means thinking permanently on solutions capable of improving their results and, at the same time, strengthening their management practices, sustainability and business responsibility.

3. Owner attitude

This value means facing all activities with attitude of those responsible for their success. It is performing them with a sense of urgency, fulfilling the deadlines and budgets agreed, with transparency and meeting the requirements of quality and sustainability.

4. Ethics in all relationships

For DM11®, ethics is essential. Present in each decision that is made, it helps to seek business objectives having as reference corporate values. Ethics also helps not lose sight of the interests of different DM11® relationship audiences.

5. Excellence in execution

It is understood as excellence in execution, constantly seeking the highest degree of performance, improving everyday practices and valuing the full quality of the result of each work.

6. Innovation with results

The DM11® is recognized for its ability to innovate and propose differentiated solutions that add value. The company values the innovation that brings results, which helps overcome the goals and reveal new paths that can contribute to the success of the business, customers and other partners of the organization.

7. Sustainability and corporate responsibility

DM11®, through the inclusion of topics associated with sustainability in management practices and processes, aims to pursue the success of the long -term business, contributing to a healthy environment, in order to collaborate with a fairer society and for the economic and social development of Brazil.

8. Internal relationship

For mutual respect, we promote that the consequences of our actions are measures, that the dignity of others be preserved and social differences valued, that is, to ward off the various forms of discrimination, declared or concealed, to secrete or humiliate.

In this sense, our managers should perform much more than a coordinating function: they must promote pedagogical actions, spread moral guidelines with their acts or words and influence their conduct.

9. Forced labor and analogous to slavery

DM11® is against forced labor and situations that potentially involve coercion, punishment under any pretext, degrading disciplinary measures and punishment for the exercise of any fundamental right.

DM11® monitors and encourages its suppliers to monitor its value chain to prevent and combat such situations, not compacting such practices; And if identified, they will be properly reported to the competent authorities.

10. Child labor

DM11® is against child labor and does not compact with any situations that potentially involve:

Irregular work of adolescents under 16 years (except when apprentices, from 14 years old);
Inadequate conditions for work and the development of adolescents from 16 to 18 years old;
Characterization of any form of discrimination, violence or attack on the fundamental rights of children and adolescents.

11. Sexual exploitation of minors and child pornography

DM11® is against any form of discrimination, violence or attack on the fundamental rights of children and adolescents and to whom it produces, reproduces, records, by any means, scenes of explicit or pornographic sex involving children or adolescents, and/or who agrees, facilitates, recruit, coer or intermediate the participation of children or adolescents in these scenes.

DM11® does not condone the sexual exploitation of minors in its value chain, thus, as it does not accept the use of its products / services by customers who can explore this activity. Any supplier or client who has any direct or indirect involvement with this type of situation will be described and denounced to the competent authorities.

12. Harassment

DM11® is against any form of intimidation or sexual, moral, religious, political or organizational harassment and provides work environments that promote personal fulfillment and offer prospects for human and professional development. Thus it is unacceptable for employees to compact with harassment situations in their business environments.

13. Discrimination and diversity

Our employees should not allow any kind of discrimination by gender, color, race, ethnicity, disability, sexual orientation, religion, origin, marital status, age, gestational situation, social class or any other personal characteristics in their hiring, promotion and promotion processes and resignation of employees.

DM11® wants its employees to encourage the valorization of diversity in order to promote the inclusion of all segments of society.

14. Compliance with legislation

Our employees must comply with the applicable legislation and rules in force. This includes respect for health, safety, human rights, labor, the environment, local legislation, including tax and tax, but not limited to these items.

15. Anti-Corruption law

Our employees should act in accordance with all applicable laws, including the terms of the anti -corruption law, committing not to promote, offer or directly or indirectly, undue advantage to the public agent, or the third person related to him, for the purpose To influence any act or decision of the agent, government or public entities, or to ensure any improper advantage, or to run business to anyone, and that violate the anti -corruption law.

DM11® is against and does not compact with any fraudulent practices and corruption in its business environment. We do not adopt, do not encourage and do not allow any conduct that constitutes or results in acts harmful to the public, national or foreign administration, as provided by law.

DM11® encourages and supports, unlimitedly, the provision of denunciation of any act or omission that may configure transgression to the code of ethics and conduct of suppliers or the legislation in force, including the anti-corruption law, committing to investigate , punish and/or inform the competent authorities, as much as possible, any deviations that may be informed.

For more information see DM11® anti -corruption policy [IT Risk Protection]

16. Money laundering

DM11® does not compact with money laundering practices economic and financial practices that aim to conceal the illicit origin of certain assets so that such assets appear to have lawful origin. If identified, those responsible will be properly reported to the competent authorities.

17. Social responsibility

Employees commit to:

Respect and enforce all provisions of current environmental legislation, being responsible before the environmental agencies and society, for any damage or damage that causes the environment, as well as to perform their services and/or activities Respecting the legal, normative, administrative and related acts, emanating from the federal, state and municipal brazilian´ spheres, including, but not limited to compliance with Federal Law No. 6,938/81 (National Environmental Policy), Law No. 9.605/98 (Law of Environmental Crimes) and Law No. 12.305/10 (National Solid Waste Policy) also implementing efforts in this regard with their respective representatives and suppliers of products and services, so that they also commit to combining conjugation Efforts to protect and preserve the environment as well as to prevent harmful practices to this;
Do not employ workers under sixteen years old, except as an apprentice from fourteen years, pursuant to Brazilian Law No. 10,097 of 12/19/2000 and the consolidation of labor laws and other laws governing the matter;
Do not use adolescents up to 18 (eighteen) years old, in places harmful to their formation, their physical, psychic, moral and social developments, as well as in hazardous or unhealthy places and services, at times that do not allow the frequency to school and also, at night, according to specific legislation;
Do not adopt work practices analogous to the slave, nor illegal work of children and adolescents in compliance with this contract; combat the practice of discrimination in all its forms;
To value diversity in your workplaces, promoting equity; prevent moral and sexual harassment;
Respect free trade union association and the right to collective bargaining;
Combat the sexual exploitation of children and adolescents in their operations and in their supply chain;
Seek hiring local suppliers;
Seek hiring small and medium suppliers;
make the punctual and correct payment of your obligations with your employees, the IRS, Social Security and other tax obligations;
Seek appreciation, training and employment of people with disabilities; and
Comply with the health and safety conditions provided by law to employees.

18. Conflict of interest

In order not to compromise the personal and professional integrity of employees, it is essential that they have no doubt about our decisions and actions. Delicate questions can be raised when personal interests are involved, which may compromise impartiality. Thus, any conflict of interest with those of DM11® deserves to be avoided or declared.

The exemption of responsibility is ensured when the employee:

communicates to your immediate superior any activity or situation that may affect your professional responsibilities or that may lead to real or potential conflicts of interest to DM11®;
Formally communicates to the hierarchical superior and the eventual ethics committee to run for political representation for proper appreciation and consent;
has no financial interests or bonds of any other species with a company that keeps business with DM11® or, if you have them, reflects on the contracting of the third party or the management of the contract so as not to give suspicion of favoritism; Li>
Declines of particular, habitual trade relations, with customers or suppliers, except for eventual transactions that are performed on the usual conditions of the market or are devoid of any kind of favoritism;
Declares morally prevented from representing DM11® in any transaction involving relative or friend;
No more activities that can interfere with their work or attributions, in view of the best interests of DM11®;
Does not seek to influence decisions from other areas that may benefit third parties with which they maintain some kind of bond;
Not to be negotiated on your own or someone else, on behalf of DM11®, without prior authorization of who is right;
Do not abuse the prerogatives of the position you occupy, avoiding actions that can generate personal benefits or advantages for third parties over DM11®;
A refuses to hire relatives to work under their direct subordination and do not indicate family members or lead others to indicate them without revealing the fact to the person responsible for hiring;
formally communicates to HR affective-love relationships with another employee;
Informs DM11® its kinship degree with possible job candidates;
It does not provide services to third parties that have relations with DM11®;
Does not monopolize attributions that good management usually divides;
It is not in default in your personal business to the point of becoming vulnerable and endangering your professional integrity;
Demonstrates extreme rigor in the rendering of accounts regarding administrative expenses, both their own and colleagues or subordinates;
does not make interest loans to colleagues or requests loans and avoids offering or receiving approval for personal operations, always aiming to prevent embarrassing situations;
It is striving to submit issues not regulated by this Code to the appreciation of the Ethics Committee;
Contributes to the success and improvement of the moral guidelines contained in the Code through various initiatives and in accordance with the competent communication channels and reports any violations of legal rules or infractions to this Code, being guaranteed to the employee that he does not not will suffer embarrassment or reprisal.

19. Relationship with suppliers

Our employees have a direct influence on the quality of our products and services. Therefore, we value the partnership relationship, considering what is good for us, they and other audiences involved.

The relationship with our suppliers will be characterized by observing the precepts of the Code of Ethics and Conduct. DM11® practices free competition, transparency and impartiality in the process of hiring suppliers, direct and indirect third parties, as well as the strict compliance with contracts.

DM11® encourages its suppliers:

Fulfill and monitor their value chains to prevent and combat forced or compulsory and/or child labor, pedophilia, discrimination, bullying and/or sexual, tax evasion, corruption and money laundering;
Have internal policies and/or social inclusion programs, code of conduct, business responsibility, environmental management policy or minimization of environmental impacts related to your business, and actions that promote the valorization of diversity, equity and training for employment of people with disabilities and apprentices, and free association;
Manage your supply chain, identify critical suppliers from the sustainability point of view and set goals for improvements in economic, social and environmental indicators with this group of suppliers;
Manage economic, social, labor, tax and environmental risks in your supply chain, aiming at business continuity;
Encourage internally and its supply chain to hire small and medium local suppliers for economic development;
Have and recommend to your suppliers to have a code of conduct with regard to personal and commercial relationships;
Fulfill and recommend to their suppliers: the punctual and correct payment of their obligations with their employees, practices aimed at guaranteeing salaries that meet the minimum standards of the region’s category and are sufficient to meet basic needs, and guarantee them conditions health and safety provided for by law to their outsourced employees and workers. As well as the punctual and correct payment of their tax, labor and social security obligations.

DM11® hires suppliers whose management practices are adherent to the precepts of this Code of Ethics and Conduct, and has as its permanent objective the expansion of the supply base, without restrictions on suppliers for size, size or location, provided they are able to offer Your product or service in accordance with the needs and specifications disclosed and are able to supply from the administrative point of view.

Supplier base is monitored by approving suppliers that encompasses administrative, tax, labor and social and environmental issues, as well as performance and punctuality in supply and revenue.

20. Development of suppliers’ employees

It is important for suppliers to seek the development of their employees through work training and encouragement to improve the level of education, as we believe that education accelerates and leverages the social ascension of individuals, as well as the quality of the product and service provided is intrinsically linked to the training of labor.

DM11® encourages its suppliers and value chain to have a formal policy and/or business responsibility program that includes environmental, social, and health and safety aspects of the employee.

21. Employee’s responsibility

Some activities and actions may interfere with the work environment, internal relationships or employee performance. To ensure that everyone can perform their tasks and functions in the most appropriate way we establish rules that must be followed.

Thus, it is the obligation of all employees to observe what is contained in this code, practicing and promoting their application in any action or business involving interests of DM11®.

22. Company’s heritage

DM11® goods and resources are not just about their equipment and facilities, tools and supplies, technologies and finances, information and other actives. In addition to these, there are also other no less important: the so -called intangible goods and resources, that is, whose value cannot even be sized, such as suitability, tradition, reliability and transparency. Together and allied to the inexhaustible willingness to work and the intellectual, professional and human capacity of their employees, they constitute the necessary assets to produce wealth, ensure jobs and add value to shareholders and clients capital. Therefore, their protection and preservation over time become essential.

23. Heritage protection

Every contributor is expected:

safeguard DM11® against waste, damage, inappropriate use, loss, theft or withdrawal of any goods from DM11® without prior authorization;
Communicate to the immediate superior any news related to misuse, deviation or fraud, so that appropriate measures are taken;
Does not allocate your work to political, trade union or religious uses insofar as such a procedure can compromise DM11;
Do not destroy or discard records and documents, except on legal, systematic and regular bases;
Do not use vehicles or any DM11® equipment for private purposes – except if authorized – because this abusive fact shakes the reputation of DM11;
Use the DM11® resources with administrative expenses with caution, always in order to safeguard the interests of shareholders;
Drive care and use of users’ secrecy and password protection so as not to compromise information security services and systems;
Observe rites of confidentiality and caution in the elaboration of messages in the face of possible disputes.

24. Professional confidentiality

It is essential to note that:

All information other than public domain is confidential;
It is essential not to mention confidential information in public places, relationship sites or internet discussion forums in view of the possibility of inadvertent diffusion;
It is vital to refrain from commenting on business with third parties, friends or relatives, thus preventing the generation of rumors, in view of the inconvenience of an innocent leak;
It is essential that business secrets, confidential or privileged information and any third party data that has been entrusted to employees are used exclusively to meet the objectives of DM11®. Any communication in this regard depends on prior authorization from the Director of the area or legal determination, after consultation with the legal area;
The financial situation of customers is confidential, otherwise DM11® image and, consequently, to subject it to complaints and lawsuits;
Reserved information holders are responsible for ensuring their confidentiality in order not to compromise the activities and interests of DM11®;
It is unacceptable, obtaining confidential information from third parties by illicit means or economic espionage;
The confidentiality of the personal records of colleagues must be protected, and their access is restricted to the employee who has a functional need to meet them. The disclosure of these records will only be justified if authorized by the interested party or in case of legal, regulatory or court decision;
It is the moral commitment of each employee to avoid using confidential information for personal or third party benefits, even after its departure from DM11®.

25. Intellectual property

Confidential information is part of the intangible assets of DM11®, as well as the innovations of product or processes and the improvements made by employees in the exercise of their activities or outside working hours and the DM11® facilities, provided they are related to the business.

Therefore, and not to cause irreparable damage, it is the object of attention and application:

Enter applications exclusively approved by manufacturers so as not to compromise the security of DM11® and to respect copyright;
Do not use, for private purposes or transfer to others, technologies, methodologies or any information that belongs to DM11® or that have been developed directly or indirectly by the employee himself as a result of his activities and functions;
To mention the authorship of any individual or collective work when your presentation.

26. Ethics in trade relations

26.1. Freedom of Association

DM11® respects the right of its employees to associate with the discussion and collective claim of claims and their rights and expects their suppliers to adopt the same practices with their employees.

26.2. Unfair competition

DM11® values free and loyal competition. Thus, we do not condone the following practices, but not limited to:

Offer better prices, the result of non -compliance with legislation (labor, tax, etc.);
Make insinuations or comments that may affect the image of competitors;
Compact with the formation of trustes and cartels;
Perform or benefit from any type of fraud and/or business espionage;
Perform or contribute to coercive business practices and abuse of economic power;
Offer or make bribe, extortion or facilitation payments to accelerate an action that concerns it.

DM11® respects its competitors and believes that loyal competition contributes to the improvement of the market.

26.3. Power abuse | Harassment

We have not made comments that can contribute to the dissemination of rumors about our competitors.

We do not compact coercive business practices to get advantage or any kind of harassment (moral, sexual, racial, political and religious).

26.4. Conflict of interest

It is essential that personal interests are not in conflict with the interests of DM11®, such as, but not limited to:

Activities, professional or not, performed by DM11® employees for suppliers and/or customers;
Private DM11® employee relationships with suppliers and/or customers who compromise business impartiality;
The existence of kinship of up to 2nd degree, with employees of DM11® and/or with respective spouses.

The existence of these and other situations of doubt should be reported immediately through the ethics channel to be properly evaluated, and found or not, the characterization of a conflict of interest. Until the evaluation is completed, the people involved in the potential conflict should be fully withdrawn from the situation.

26.5. Gifts, favors and services

The provision or acceptance of gifts, favors and services will follow the usual market practices, and it should be avoided everything that may or seems to compromise the company or any people involved who may affect decisions, facilitate business or benefit third parties.

Performing actions aimed at strengthening the relationship with DM11® is acceptable, respecting reasonable limits, with no value considered significant, that do not imply embarrassment for those involved or eventual retribution by them.

It is unacceptable to offer or receive commissions, bonuses or money.

Before offering a gift or toast, make sure it is in accordance with the usual market practice and eventual code of ethics of the customer or supplier, and the legal requirements, in order to avoid situations that configure inappropriate behavior.

26.6. Social networks

Employees should act on social networks respecting the values of DM11® and this code when mentioning or referring to DM11® and its customers.

27. Confidentiality and confidentiality

27.1. Confidentiality and confidentiality of information

Confidential and strategic information should not be disclosed.

Employees must treat as confidential the non -public information received, by any means or form, during the preparation of their proposals, and during the term of their contracts and/or proposals.

Confidentiality extends indefinitely after the end of its contracts or until this information may become public.

27.2. Information transparency

Transparency is a fundamental component in all relations of DM11®. It is understood as transparent behavior:

To have clarity and transparency in the information necessary for the quotation, hiring, purchase and administration of products and services;
The veracity of legal, tax, economic and financial information, health and safety, environment, quality, professional training and other information existing in the relationship with our company;
The clear manifestation of opinion regarding the practices that result in the best possible service, avoiding error induction;
The ability to perform the services contracted due to information, knowledge, and skills that have;
The adoption of good corporate governance practices, ensuring equity, accountability, transparency and responsibility for the results.

27.3. Information security

At DM11®, internal and external information is treated with extreme care. Therefore it is necessary that all information be stored, conducted and processed in a safe environment and that all involved share responsibility for security processes and ensure the integrity, availability and confidentiality of information assets.

Business, service and business strategies that are eventually available to our employees, must be treated confidentially and should not be available, shown or passed on to third parties without prior writing consent of DM11®.

28. Code management

28.1. Ethics Committee

For management of the Code of Conduct and Ethics, the Ethics Committee was created, formed by members of the Board and Administration that sign and validate the publication of this document.

28.2. Ethics Committee responsibilities

Ensure the dissemination and dissemination of the guidelines contained in this Code;
Update this code, including or adapting guidelines and concepts according to specific business needs and market requirements;
Receive and analyze cases of deviations and infractions to the Code of Conduct and Ethics of DM11®;
clarify doubts of interpretation of the code;
Ensure confidentiality about the information received.

28.3. Violations of the code of Conduct and Ethics

Any deviations of conduct and reports of infractions will be analyzed by the Ethics Committee and will be subject to disciplinary measures or penalties based on the legislation, as the case may be.

Failure to comply with the precepts set forth in this Code may imply the closure of the contracts established with DM11® without burden or any penalties for DM11®.

DM11® may, at its discretion, directly or through third parties, verify the fulfillment of these precepts.

28.4. Communication channels

For the referral of infractions, we encourage you to look for the area manager or the Ethics Committee through the following communication channels:

Personally, talking to your manager, who will lead to the knowledge of the Ethics Committee, or
by email: etica@dm11.com.br

The protester may identify or make anonymous report.

Full service to this code is a fundamental condition for employees, suppliers and third parties of DM11®

28.5. Protection to the protester

DM11® will not consent to any retaliation or punishment to the complainant, or participant in the investigation of a suspected violation of the code of Ethics and Conduct, misconduct, illicit acts, fraud or corruption.

DM11® will always investigate retaliation allegations.

Employees guilty for adopting a retaliation conduct will also be subject to disciplinary actions described below. This declaration against retaliation does not exempt any employee of the responsibility of personal involvement in any irregularity.

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