CODE OF CONDUCT AND BUSINESS ETHICS

Innovativa was designed, thinking in transform crisis in opportunity. A experienced team of executives focused in interim management and consulting, with a professional portfolio to attend a broad variety of areas in a fast way, competences and expertise in the projects executions.


Guided by integrity, honesty, fair play and total compliance with law and applicable regulations.

 

Mission
 

Our intellectual capital  offer innovative solutions generating high strategic value to our customers.

 

Vision
 

Being a reference in the generation of strategic value to the client.

 

Values
 

Excellence / Commitment / Partnership / Credibility / Respect

 

Objectives of our Code
 

The Code of Conduct and Business Ethics (the "Code") is the basis Innovativa's commitment and his collaborators in relationships between shareholders, employees, customers, partners, competitors, suppliers and service providers, press/media, government agencies and regulators and the communities where we conduct our business with the best market practices in compliance with the laws, regulations and procedures for maintaining our reputation.

 

Integrity with laws and regulations
 

Innovativa and its collaborators are required to comply with federal, state and local laws and regulations, as well as internal applicable internal policies and procedures. These internal policies and procedures may go beyond what is required by law. However, if a law conflicts with this Code, Innovativa will obey the law.

Conflict of interest
 

A conflict of interest occurs when the personal interests of an employee or a third party compete with the interests of Innovativa.  In this situation, it may be difficult for the employee to act totally in the best interests of Innovativa. It is expected that all employees refrain from engaging in activities that conflict or appear to conflict with Innovativa´s best interests.
 

If a conflict of interest occurs, or if an employee encounters a situation that may involve or lead to a conflict of interest, the employee must communicate it immediately to the Executive Committee of Innovativa, to resolve the situation fairly and transparently.

Gifts, meals and entertainment
 

Member of innovativa are not allowed to accept or offer gifts, meals and entertainment to customers and suppliers, except in the following situations:
 

a) Promotional gifts of symbolic value and with the name of the offering company.
 

b) Paying meals to customers in a strictly business environment and in places and values that are compatible with the market.
 

Other situations not provided for, in this Code, must be submitted to the Executive Committee.

 

Business Opportunities

Any and all business opportunities must be analyzed, validated and authorized by the Executive Committee.

No employee may treat or distract businesses, enter into commitments, enter into contracts, make purchases or sales of any kind, individually or jointly, on behalf of innovativa.

The employee is prohibited from using information or position in Innovativa for undue personal gain, including the gain of family members or friends.

Insider trading

Insider trading, abuse of privileged information and information misuse are crimes, which means buying or selling securities of any company in person as long as you have material and non-public information about such company.

Information misuse means disclosing internal information about a company to a family member or friend, in order to allow the person to buy or sell securities of the company based on such information. Failure to comply with this rule may lead to disciplinary sanctions, as well as criminal prosecution.

 

Commercial and antitrust loyalty 

Innovativa is prepared to compete successfully in the business environment where it operates in full compliance with all applicable laws. In this way, all employees of innovativa are required at all times to follow the following rules:

Commercial policies and prices will be set independently, and in no event shall be agreed, formally or informally, with the competition or with other parties not related, directly or indirectly.

Customers or territories will never be shared or divided through agreements between innovativa and competition.

-Customers, suppliers and service providers will be treated fairly.

All employees, but especially those involved in marketing, sales and purchases, or who are in regular contact with the market and competition, have the responsibility to ensure that you know the applicable antitrust laws. In case of doubt, the Executive Committee should be contacted for advice.

Confidential and proprietary information

Confidential information consists of any and all information that is not, or is not yet, publicly knowledge, including trade secrets, patents, business plans, marketing and service plans, consumer views, engineering ideas, and manufacturing processes, product revenues, drawings, databases, records, wage information and any unpublished financial or other data. Unless required by law, the unauthorized use or disclosure of proprietary or proprietary information of Innovativa or third parties may be unlawful and may result in the imposition of civil and criminal liability.

Employees should not disclose confidential information or allow it to be disclosed. This obligation is in force even after the termination of the professional relationship of the collaborator with the customer or Innovativa. In addition, collaborators should use their best efforts to prevent unintentional disclosure of any confidential information, taking special care when storing or transmitting them.

Bribery and corruption

Employees are prohibited, either directly or through intermediaries, from offering or promising any kind of personal or improper financial advantage to obtain or retain business or other advantages of a third party, whether in the public or private sector. Employees should also avoid any activity or behavior that in any way may give rise to appearance or create the suspicion of accomplishment or the attempt to perform any improper conduct.

Employees should be aware that the provision or delivery of benefits unfit to influence the decision of a third party, even if such third party is not a member of the government or any sphere of public authority, may violate the law and lead the offender to disciplinary sanctions civil and criminal cases. Inappropriate benefits may consist of something of value to the third party, including service or consulting contracts for close and related third parties.

Employees should be aware that electoral laws prohibit any contributions from private sector companies to political parties or candidates. Innovativa does not make such contributions.

 

Diversity

Innovativa aims to create and maintain an environment that encourages collaboration, interaction, tolerance and respect with a strong and diverse team. Our commitment is to maintain a work environment free from discrimination and harassment, respecting the personal dignity, privacy and personal rights of all its employees, who undertake not to discriminate on the basis of origin, nationality, religion, race, sex, age or sexual orientation, or any kind of verbal or physical harassment.

Sustainability

Innovativa and its collaborators recognize that the well-being of present and future generations depends on the actions we take now. Our commitment is to develop our activities and offer sustainable solutions guided by the principles of transparency, ethics and respect for people and the law.


 

Contact information Executive Comittee


E-mail: compliance@innovativa.com.br
Phones: +55 11 5041 1151 | +55 11 5531 1049

© 2015 by innovativa - Executivos Associados. All rights reserved.

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