Compliance & Ethics

Bound parties must:

• Offer solutions balancing the interests of all
• Stay open to dialogue, respecting diversity and freedom of expression without discrimination

Customer satisfaction:

• Professional, efficient treatment with dignity and respect
• Fast, on-time delivery
• Clear and comprehensive support

• Review business, HR, procurement, finance and contract procedures
• Monitor contracts with public administration
• Determine disciplinary measures (from warning to termination)
• Maintain the confidentiality of reports
• Validate the hiring of former public officials/politicians through anti-corruption due diligence
• Ensure rotation of Alfer representatives interacting with government authorities
• Zero political contributions: Alfer does not make contributions to political candidates or parties
• Promote the whistleblowing channel through training
• Maintain documentary evidence of all reports
• Respond to reports within 60 days
• Inform whistleblowers of conclusions when possible
• Regularly check CEIS, CNEP and state/municipal registries
• Conduct periodic compliance audits
• Implement Know Your Customer (KYC) policies
• Update customer registration data at least annually
• Formalize all contracts with clear terms and reasonable compensation
• Ensure transparent supplier hiring aligned with internal procedures

Prohibitions:

• Receiving cash for investment, compensation or payment
• Bound parties must formally report situations suggesting illegal activity

• Offer, promise or grant undue advantage to third parties (especially public officials)
• Sponsor anything without authorization for unlawful practices
• Obstruct inspections by public bodies
• Manipulate, defraud or hinder public tenders and contracts
• Accept or give gifts/favors above BRL 150.00 or finance travel/lodging for public officials without a legitimate reason and authorization

• Treat customers fairly, without personal or professional bias
• Identify situations that represent potential conflicts
• Forbidden to advise customers for personal gain
• The formation of partnerships between Alfer professionals and service providers or suppliers is expressly prohibited
• Hiring family members is only allowed without direct/indirect hierarchical subordination or managerial influence

• Careful handling in collecting, using, storing and transmitting data
• Monthly meetings of the monitoring committee
• Training programs on data protection
• Internal processes that mitigate risk in new products/services
• Periodic reviews of security policies
• A channel for personal data subjects to file complaints
• Traceability and security procedures during processing

General principles:

• Alfer's and the customer's interests prevail over individual interests
• Bound parties must formally report conflict or competition situations

Fair competition:

• Prevent anti-competitive practices
• Forbidden to use or share confidential information
• Forbidden to accept benefits (financial or otherwise) that influence the selection of partners, suppliers or collaborators
• Prohibited examples: trips, gifts above BRL 150, tickets, vehicles, real estate, clothing, profit-sharing
• No compensation, loans or benefits (home/vehicle remodeling)

Confidential information:

• Need-to-know access
• Treat as confidential with restricted disclosure
• Maintain confidentiality after termination (NDA signed)
• Respect individual privacy under Brazilian law
• Authorize and record any entry/exit of Alfer property

HR practices:

• Opposed to forced labor, abuse, child labor or illegal working hours
• Combat discrimination, harassment, pressure or intimidation
• Sexual harassment: the act of pressuring someone with the intent of obtaining sexual advantage or favoring
• Moral harassment: repeated and prolonged exposure to humiliating situations that destabilize the working relationship
• Discipline based on merit, reasonable compensation and freedom of association
• Aligned with the Universal Declaration of Human Rights

Environment and facilities:

• Rational and sustainable use of resources
• Immediate reporting of environmental accidents or risk of violations
• Quality standards for furniture, equipment and facilities

• Alfer reserves the right to monitor equipment, systems and networks (email, voicemail, internet, stored information) in accordance with applicable law
• Bound parties cannot share personal passwords or grant access to protected environments to third parties

• Accessible by email
• Widely publicized to professionals, directors, partners, service providers, suppliers, external partners, representatives and customers
• Anonymity guaranteed to all whistleblowers
• Whistleblowers are informed about the outcomes of investigations
• Alfer prohibits any retaliation against participants in good-faith investigations
• A third-party company processes the content of reports

• All activities must follow the established principles even without explicit reference
• Duty to inform Alfer of control weaknesses or conduct deviations, under penalty of negligence
• Duty to report any suspicion of misconduct via the whistleblowing channel
• Alfer encourages good-faith reports, fostering solidarity
• All contracts include anti-corruption clauses
• The Code is reviewed and updated in intervals of up to 1 year, in accordance with legislation and best practices
• Training and refresher courses are organized with the same frequency
• All bound parties must sign formal adherence and renew with new editions