Introduction


The Code of Conduct aims at establishing the ethical and conduct principles that should guide the internal and external members of INTRAGROUP.

The presence of INTRAGROUP in the national and international capital market and the participation of INTRAGROUP members in different business units, geographic regions and cultures, which constitute globalized and competitive markets, transparent transparency standards of operation and the attendance of relevant orders.

Our reputation and our credibility are the most important of the principles, the ethical principles that guide our contribution to maintaining the image of INTRAGROUP.

We emphasize our philosophy in Health, independence and freedom of expression; which will always be encouraged in INTRAGROUP.

The code chains must be observed by all members of INTRAGROUP, under the responsibilities and responsibilities.

Compliance with the code of conduct on the part of each member reaffirms one of the most important objectives of maintaining and consolidating INTRAGROUP's reputation.


Code of conduct

Preamble

Anyone who has an employment relationship with INTRAGROUP, for all purposes, will be called, simply, an integral member.

The guidelines established in this Code of Conduct apply to all members and also, where applicable, those who only have a commercial representative and / or statutory relationship with INTRAGROUP.


General Guidelines


1. Relationship with Members

The criterion for admission and promotion will be to meet the basic requirements of each function, in accordance with predetermined criteria and objectives. There will be no discrimination of religion, philosophical or political conviction, nationality, origin, genre, age, color, sexual preference, marital status or physical or mental disability.

2. Conduct of Members

INTRAGROUP expects its members, in the exercise of their functions, to take care and diligence that anyone uses in their personal affairs, that is, an honest and dignified conduct, in accordance with the laws and ethical standards of society.

INTRAGROUP expects all business matters, without exception, to be treated with secrecy and confidentiality.

3. Work Environment

INTRAGROUP expects, in the relations between its members, the cordiality in the treatment, the trust, the respect, the conduct honest and honest, irrespective of any hierarchical position, position or function.

Each member of INTRAGROUP will be able to guarantee to others a work environment free of innuendo or restrictions of any nature, avoiding possible constraints.

INTRAGROUP does not allow intrusion into the privacy of members inside or outside the work environment. Controls or inserts of any nature will be repudiated.

4. Responsibility for Conducting Business

INTRAGROUP's business must be conducted with transparency and strict observance of the law, and the members' responsibilities are to ensure their compliance.

This responsibility also involves the adoption of appropriate measures when they are aware of irregularities practiced by third parties that could compromise the name and interests of INTRAGROUP.

Any and all operations involving INTRAGROUP must be supported by skillful documents, covered by all legal formalities.

4.1. Responsibility of Members

It is the obligation of every member to know, understand and practice the provisions of this Code of Conduct.

The members will also be responsible for preserving the name and image of INTRAGROUP, within its remit.

4.2. Liability of Managers

Managers are obliged, among others, to act as follows:

5. Business Relations

INTRAGROUP expects its members to conduct business relationships in compliance with laws, legal market practices and, in particular, national and international standards relating to the economic order.

All members of INTRAGROUP are expressly forbidden to make any improper, doubtful or illegal payment or to favor, by granting undue benefits, outside the usual practices of commerce, customers, suppliers and competitors, to the detriment of others; as well as making such payments or granting privileges or advantages to civil servants or the like, either directly or by third parties.

5.1 Relationship with Clients

Satisfying the customer is the foundation of INTRAGROUP's existence. Therefore, it is a basic principle of INTRAGROUP's business action to serve the customer, with an emphasis on quality, productivity and innovation, with social, community and environmental responsibility, and with full respect for the laws and regulations of each product and region in which they operate.

Customers must be served courteously and efficiently and are provided with clear, accurate and transparent information. The client must obtain answers, even if negative, to his requests, in an appropriate way and in the expected term.

Customer expenses related to meals, transportation, stay or entertainment are acceptable provided justified by reason of work, carried out within reasonable limits and do not imply embarrassment or need for remuneration.

5.2. Relationship with Suppliers

The relationship with suppliers must be lasting, without prejudice to the principles of free enterprise and fair competition.

The selection and contracting of suppliers must always be based on technical, professional and ethical criteria; meeting the needs of INTRAGROUP.

They must be conducted by predetermined objective processes, such as competition or price quotation, to ensure the best cost / benefit ratio.

Business with reputable suppliers should be avoided.

Expenses with suppliers related to meals, transportation, stay or entertainment are acceptable provided justified by reason of work, carried out within reasonable limits, and do not imply embarrassment or need for remuneration.

5.3. Relationship with Competitors

The competitiveness of products manufactured and / or marketed by INTRAGROUP must be exercised on the basis of fair competition.

No comments should be made that could affect the image of competitors or contribute to the dissemination of rumors about them, and the competitor should be treated with the respect that INTRAGROUP expects to be treated.

It is expressly prohibited to provide strategic, confidential or otherwise in any way harmful information to INTRAGROUP's business to any third party, including but not limited to competitors.

5.4. Relationship with Relatives

The spouse, parents, siblings, children, uncles, nephews and cousins up to the second degree, including those of the spouse, are understood as relatives.

If a member wishes to conduct business on behalf of INTRAGROUP with one of his relatives or persons with whom his or her family members have a close personal relationship, or even with companies that are members of such company, they have a relevant participation in companies or hold a management position. member shall obtain written permission from his manager, who shall discuss the matter with the Board of ACADEMIA INTRAGROUP.

5.5. Relationship with Public Authorities

It is expressly forbidden for all INTRAGROUP members to offer gifts or benefits to public officials, their families or the like, either directly or by third parties.

6. Liberalities

The members of INTRAGROUP and their families should not give or accept gifts or favors from customers, suppliers or competitors that correspond to values above R $ 100.00 (one hundred reais).

If any member has received something above this value, and for any reason has not had the possibility of refusal, they must forward to the Board of ACADEMIA INTRAGROUP, which will make the appropriate donation. The member should make the necessary acknowledgments to the one who offered them, informing him of the destination given to those present.

7. Conflict of Interest

Members must ensure that their actions do not conflict with INTRAGROUP's interests, nor do they damage their image and reputation.

For exemplifying purposes only, some situations in which the member is facing a conflict of interest are listed below:

The member, confronted with any situation of conflict of interest, should promptly report what has happened to his manager, who may resolve the matter or discuss the matter with his or her manager or the Board of ACADEMIA INTRAGROUP.

8. Activities outside of INTRAGROUP

The members of INTRAGROUP should not engage in activities or engage in in organizations that compromise their dedication to INTRAGROUP or to adopt behaviors that generate conflict of interest with their responsibilities and attributions; or to act in any other segment whose duties may in any way compromise its efficiency, integrity, confidentiality and the safety of INTRAGROUP.

9. Relationship with Shareholders

Communication with the shareholders will be through the director of investor relations.

The relationship with shareholders and investors should be based on accurate, transparent and timely communication of information that will enable them to follow the activities and performance of INTRAGROUP as well as the search for results that bring positive impacts on the market value of INTRAGROUP.

The treatment provided to shareholders, regardless of the number of shares held, subject to legal restrictions. Everyone shall be provided with equal treatment of information.

10. Privileged Information

If any member has relevant and privileged information about the actions of INTRAGROUP, it is forbidden by law to negotiate, directly or indirectly, for any purpose, INTRAGROUP's actions, or even to disclose such information to third parties.

INTRAGROUP expects the member to observe the legal provisions on the subject, as well as any policy, instruction or guidance of INTRAGROUP accordingly.

By law, violation of this rule is criminal and civilly punishable.

11. Political Activities

INTRAGROUP will not restrict the political-party activities of its members. However, they must always act in a personal way and in a way that does not interfere with their professional responsibilities.

It is strictly forbidden to carry out political-partisan activities in the work environment and that involve, in any way, INTRAGROUP resources.

Members may not wear company uniforms when performing political activities.

It is strictly forbidden to advertise any form of political advertising on premises, vehicles, publications or any other property of INTRAGROUP.

The member who participates in political activity does so as a citizen and not as a representative of INTRAGROUP.

12. Use and Preservation of the Goods of INTRAGROUP

The members are responsible for preserving the assets of INTRAGROUP, which comprise facilities, machinery, equipment, furniture, vehicles, securities, trademarks, patents, and others.

It is not allowed to use equipment and other goods of INTRAGROUP for private use.

Access to the Internet and telephone, as well as the use of e-mails, software and hardware should be restricted to the professional activity of the member, subject to the other provisions established in policies, regulations or guidelines of INTRAGROUP.

Members are not allowed to use INTRAGROUP's address to receive private correspondence except in authorized cases.

13. INTRAGROUP Spokespersons

Only certain members are authorized by the management of the company to speak on behalf of INTRAGROUP and comment on it to the press or outside groups.

14. Accounting records

Transparency is fundamental to allow the correct evaluation of INTRAGROUP by market agents.

INTRAGROUP's accounting standards and practices must be rigorously observed, generating consistent records and reports and allowing a uniform basis for evaluation and disclosure of INTRAGROUP's operations and results. Therefore, it is necessary to ensure the accounting of any good, right and obligations that INTRAGROUP is obliged to do.

15. Environment

The balance of the environment and the preservation of nature are of fundamental importance for the business activity of INTRAGROUP.

INTRAGROUP has an active participation in the preservation of the ecosystems where its industrial units are located, either through the zeal and care in the manufacture, handling and transport of its products, either through the aid of the preservation of forest reserves, prevention of the waste of natural resources, promotion of conservation campaigns to raise awareness among the regional communities, as well as support for various public and private projects related to preserving the environment.

Therefore, it is the responsibility of each member to contribute to the conservation and improvement of the environment and its ecosystems.

16. Doubts

The guidelines of this code allow us to evaluate a large number of situations and minimize the subjectivity of personal interpretations of moral and ethical principles, but they do not necessarily detail all the situations that may arise in the daily life of each member. Therefore, in case of doubt in the application of the guidelines of this code, the area manager should be consulted.

17. Violations

Members are expected to comply with these guidelines in all circumstances.

A member who violates a conduct, practice or policy of INTRAGROUP, or who allows a subordinate to do so, will be subject to disciplinary action, including dismissal. The member who is aware of any violation of any aspect of this code by any person shall bring this fact to the attention of the manager of his area.

18. INTRAGROUP Council

INTRAGROUP will have the Board of INTRAGROUP, which will be responsible for judging the most serious breaches of this code and imposing appropriate disciplinary sanctions, as well as deciding on the clarification of doubts regarding its text.

The INTRAGROUP Board will meet whenever necessary.

19. General Provisions

This Code of Conduct will be in force as of this date. The guidelines for conduct contained in this code will be brought to the attention of all members.

No member may allege ignorance of the guidelines contained in this code under any circumstances or under any argument.

This Code of Conduct came into force on January 1, 2018.

 
The Intragroup

Founded in Brazil in 2001 in order to provide solutions through consulting service in specific business related to SAP® ECC, Hana, FI / CO, SD, MM, CRM, BW, NF-e (electronic NF) and all accessory Obligations Brazilian legislation.

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Consulting

With more than sixty employees in Brazil and other team in our branch in Pennsylvania, Intragroup proves a highly specialized team in the SAP® tools.

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Methodologies and differentials

Besides all global standard implementation with all country specifics needs within SAP® implementation methodology, Intragroup provides all SAP® tools consulting.

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The Code of Conduct

The Code of Conduct aims at establishing the ethical and conduct principles that should guide the internal and external members of INTRAGROUP.

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Malvern, PA – US

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