Code of ethics
The code of ethics and business conduct of Movile Internet Móvel SA (“Movile”) establishes the rules for the conduct of all its employees and collaborators, shareholders, administrators, including service providers, consultants and suppliers. Commitment to these guidelines is an essential condition for everyone to be aligned with the Movile objectives, in order to avoid any conduct that may be considered illegal under the laws and regulations applicable against bribery and corruption, including, without limitation, the Brazilian Law 12.846 / 2013, the United States Foreign Corrupt Practices Act - FCPA, the United Kingdom Bribery Act - UKBA, and other applicable laws, rules and related regulations that are being implemented. In complying with these guidelines, we act within the highest standards of integrity, in the best interest of Movile and our reputation.
Any conduct that is considered unethical, illegal or dishonest is not tolerated.
All Movile employees and collaborators must act in line with their values, described below.
People: we attract, develop and retain the best people, who are proactive, committed and passionate about what they do, always with a sparkle in their eyes and who treat our business as if they were theirs. We value teamwork, transparency and diversity, maintaining an open and transparent relationship with each other.
Customer Focus: We want our customers to recommend our services to their friends.
Innovation: we have the creativity and agility necessary to innovate, making new products, services and processes so that we can positively surprise our customers. We encourage responsible risk taking and accept mistakes that lead to rapid learning.
Results: we are obsessed with aggressive results since they guarantee our broad investment, compensate our shareholders, generate our own remuneration and enable our long-term growth and continuity.
Meritocracy: we reward and offer opportunities for people to grow as fast as their results, with clear and complete performance.
Ethics: we guide our actions by the highest standards of ethics and professionalism. We conduct our business with integrity. We guide our actions so that we are not ashamed if they become public knowledge.
Movile believes that the diversity of talents contributes to the success of its businesses and stimulates innovation and the creation of new opportunities. In this way, it offers an informal environment, where teamwork and mutual trust are encouraged and where people are treated with dignity and respect. To that end, Movile expects its employees to be fair and honest in conducting business with their work partners and to follow the following principles:
Be genuine and conscientious in conducting your work;
Avoid relationships or interests, whether direct or indirect, that may influence or impair your ability to act with integrity and objectivity;
Treat customers, colleagues, the competition and outsourced partners with dignity, integrity and respect, always being cordial in the communication used;
Acting ethically in all business transactions;
Make clear decisions and in accordance with business strategies;
Comply with local laws, regulations and rules related to dishonesty, corruption and / or bad faith behavior;
Respect the diversity of people, being considered unacceptable behaviors such as victimization, harassment, prejudice or discrimination in relation to race, color, origin, gender, personal aesthetics, physical conditions, nationality, sex, age, marital status, sexual orientation, social position, religion, disability and other acts that damage the honor, respect or dignity of other employees, as well as partners, customers or other third parties within the work environment, whether physical or virtual (Facebook @ Work, Email and Sli.do, for example).
Participate in training and other activities on this Code and other policies.
Contact the Compliance team whenever there are doubts about decision making or about the application of the provisions of this Code.
Communicate ethical dilemmas or complex situations that raise suspicion of violation of this Code or legislation.
Maintain confidentiality and collaborate with investigations involving issues in this Code.
We do not tolerate any type of sexual harassment between employees, third parties or partners at our offices or at corporate events. These problems must be reported and formalized with the People and / or Compliance area.
Consumption of illicit drugs and alcoholic beverages
Our position on substance abuse is simple: it is incompatible with the health and safety of our employees, and we do not allow it. Alcohol consumption is not prohibited in our offices, but use common sense and never drink in a way that impairs your performance or leads to inappropriate behavior, endangers the safety of others or violates the law. Illicit drugs at our offices or at corporate events are strictly prohibited.
Employee and Customer Information
The Group respects the confidentiality and privacy of personal information, acquired and maintained within the employee's personal record. Only those who have a legitimate and work-related need can access them. The trust imposed by our clients' knowledge and access to confidential data must be honored carefully, in accordance with Brazilian data protection legislation.
FINANCIAL INTEGRITY AND MOVILE ASSETS
Accounting and records
All Movile assets must be used only for business purposes, and all employees and collaborators have a duty to inform financial transactions in an appropriate, accurate and within the time pre-established by the area responsible for the Group's accounting and administrative records.
All employees are responsible for the proper, safe, appropriate and ethical use of Movile's resources and assets, including e-mail, internet, access to the work network, equipment, computers, cell phones, systems, facilities or any other resource provided by the company . For this reason, we highlight some necessary precautions that we need to be aware of:
Password sharing is prohibited. Passwords are personal and non-transferable. Also, do not write down passwords on post-its or notebooks. Be responsible.
Keep your computer or notebook locked when moving away or leaving the workstation. Think about how many important tools you have access to and what the risks would be if they fell into the wrong hands.
Always ensure the maintenance and good physical condition of the equipment and / or assets made available to carry out your work. That is, act with a sense of ownership.
In exposed locations do not leave your devices unattended and exercise caution when accessing public / open networks. Not all are reliable, so always try to use a VPN to access your data in the company.
Intellectual Property & Information Confidentiality
The Movile Group frequently produces valuable intellectual properties, such as patents, software, copyrights, product and service brands, as well as confidential business information, such as company strategy and planning, financial data and projections, new product development, secrets commercial, customer list, acquisition plans and other business combinations, sale of equity interest, important contracts and the like. This information must be protected against unauthorized use. All employees, as employees of the Group and after terminating their employment relationship, must keep confidential and must not disclose any of the Group's business secrets and economic and financial data as well as any confidential information or documents to anyone except employees and persons that require this information due to their role or association with the Group.
Movile values transparency and information sharing within the company, however, any information disclosed must be previously aligned and authorized by Movile's governing body and take appropriate measures to prevent the inappropriate use of this information.
The disclosure of Confidential Information will be subject to sanctions provided for in the applicable local legislation, including those related to unfair competition, industrial property and copyright law.
Relations with competitors and partners
Movile competes with its competitors in a fair and honest manner. All employees must respect their rights and deal fairly with customers, suppliers, business partners and competitors, in accordance with local law. It is not tolerated to obtain competitive advantages in a dishonest manner, either through simulation, adulteration, manipulation, abuse of privileged information, or intentional unjust professional practice.
Undue or facilitation payments: one should not authorize, offer, promise, give, request or accept money, gifts, entertainment, privileges, gratuities, benefits or other items of value intended to improperly influence any professional decision or create the appearance of impropriety.
Selection of suppliers: Movile's policy is to select suppliers based on the merits of its products, services and commercial practices, and to purchase supplies based on need, quality, service, price and other terms and conditions of sale. You should not establish a business relationship with any supplier if you know that your business practices violate local laws.
Confidential third party information: Third party information should be treated as confidential. In these cases, it is necessary to obey the terms of the confidentiality contracts eventually signed with third parties.
Free and fair competition: Our commitment includes respecting our competitors' rights to compete legally in the market and complying with all local laws during competition.
Relations with government entities
Movile is obliged to comply with all legislation where our service is performed, in particular the anti-corruption laws mentioned at the beginning of the Code. Our business needs must never be influenced by corruption. Therefore, it is against our policy to offer any advantage such as payments, gifts, gifts, or special agreements to government officials to facilitate or influence a particular process.
We deal honestly and within the law in any interaction with the government and our suppliers and partners must adopt the same practices when dealing with the Government.
Movile requires that its employees and collaborators not be involved in activities and situations in which their judgment and loyalty to the Group's interests are affected. All employees have a duty to avoid situations involving not only a direct conflict, but also situations that appear to conflict between their personal interests and the interests of the Movile Group.
Gifts, gifts, meals and entertainment
In the course of our activities we can receive or offer courtesies in order to build relationships. However, Movile does not allow any kind of courtesy to be offered or received that influences business or strategic decisions in an unethical or inappropriate manner that results in advantages for any of the parties involved.
The offering or receiving of courtesies is permitted when the following mandatory requirements and the specific rules for each courtesy listed below are respected:
The commercial purpose is legitimate.
It does not include cash payments.
There is no intention to unlawfully influence business decisions.
They do not affect conflicts of interest.
It does not involve agents or public entities.
They comply with laws and regulations.
They are reasonable under the circumstances in which they are given, on an occasional basis.
The following is how we classify the courtesies and how we should treat them:
Institutional item offered or received as a courtesy to publicize and advertise a brand, of daily use, containing the brand logo whose commercial value does not exceed US $ 35.00 (thirty five dollars). Examples of gifts are: diaries, pens, backpacks, key chains, caps and calendars. The offering and receiving of gifts are authorized by Movile as long as they do not violate the provisions of this Policy and local laws.
Item offered or received that does not fit the definition of a gift. Examples of gifts include wines, ties, watches, cigars, electronics, chocolates, flowers and other items for personal pleasure.
Movile recommends that its employees do not accept or offer gifts. In cases of offering and receiving gifts, employees must immediately send an email to firstname.lastname@example.org and make the item available for the People Team to carry out the appropriate guidance.
Event or activity that aims to provide fun, personal satisfaction to someone. Parties, concerts, sporting events, social events, trips, tours and the like are considered entertainment. These types of courtesy can create the appearance of business inadequacy and, therefore, require compliance pre-approval.
A meal can be offered to a third party or received from a third party without prior compliance approval, provided that:
The equivalent value of a meal does not exceed US $ 50.00 per person.
Do not include a spouse or other guest who is not directly part of the deal.
Participants are not public officials or politically exposed persons empowered to influence government or business decisions.
If a meal is offered or received for groups over 5 (five) people, a pre-approval of Compliance must be obtained.
Donations or sponsorships
Movile carefully considers donations or sponsorships, taking into account the following points:
It must not unlawfully influence a business outcome.
It must be done for a legitimate organization.
It should not include political donations.
In addition to the above criteria, the donation or sponsorship process must be formalized and approved by Legal and Compliance.
Money laundering is a crime that involves disguising the origin of illegal resources. Whoever carries out the operation causes the profit obtained through criminal activities (such as drug trafficking, for example) to be concealed or hidden in order to appear as a result of a legal commercial operation, being absorbed by the financial system naturally.
We must be attentive and verify that we are dealing with respectable customers and partners and with legitimate financial resources. In case of suspicion of illegal activities on the part of partners, end customers or employees, immediately inform Movile's Compliance team.
Any exceptions or doubts regarding the rules established here should be sent to the Compliance team through email@example.com
Attention! All employees and collaborators must follow the guidelines established by the Naspers code of ethics and business conduct, available on our Intranet.