Code of Ethics and Conduct

What this Code is for and who it applies to

This Code sets out the rules of conduct for everyone who works with and for uGlobally: partners, directors, employees, interns and service providers, including when they represent the company before clients, partners, funders or public bodies, in Brazil, the Netherlands or any other country.

It complements the applicable laws, including Brazilian Law No. 12,846/2013 (Anti-Corruption Law), Decree No. 11,129/2022, Law No. 14,133/2021 (Public Procurement), Law No. 13,709/2018 (LGPD), the EU General Data Protection Regulation (GDPR) and Dutch criminal anti-corruption legislation. Where this Code and the law differ, the stricter rule applies.

• uGlobally B.V.Vlamingstraat 4, 2712 BZ Zoetermeer, the Netherlands · KvK 70311862
• uGlobally B.V. Treinamento LtdaCuritiba, PR, Brazil · CNPJ 43.286.241/0001-51

Our commitments

• IntegrityWe do business honestly, without shortcuts, and we say no when the only way to win a contract is an irregular one.
• TransparencyWe are clear about what we deliver, at what price and with whom, and we record relevant decisions.
• RespectWe treat clients, partners, colleagues and communities with dignity, in every country where we work.
• ConfidentialityWe protect the information of clients and partners and use it only for the purpose for which it was entrusted to us.
• QualityWe only take on commitments we are able to meet, and we answer for what we deliver.

Anti-corruption and dealings with public officials

• It is forbidden to offer, promise, give, request or accept, directly or indirectly, any undue advantage to a public official, domestic or foreign, or to a person connected to them, or to an employee of a private company, in order to obtain or keep business or any other advantage.
• Gifts, meals and hospitality are acceptable only when they have symbolic value, are occasional, do not coincide with an ongoing procurement process and do not create an expectation of something in return. When in doubt, decline and report it through the channel in section 11.
• We do not make facilitation payments, nor donations to political parties or candidates on behalf of the company.
• Meetings with public officials about an ongoing procurement must have a defined agenda and, whenever possible, more than one uGlobally representative.

Tenders, accreditations and contracts

• We take part in tenders, accreditations and public calls with true and up-to-date documents, including certificates, declarations and CVs.
• It is forbidden to agree prices or bids with competitors, simulate competition, use inside information or interfere with the work of evaluation committees.
• We perform contracts on the terms signed. Any change to scope, deadline or value is agreed in writing with the contracting party.

Conflict of interest

A conflict of interest exists when a personal, family or financial interest may influence a decision taken on behalf of uGlobally. Anyone in that situation must inform the partners before acting and step away from the decision. This includes family ties or close relationships with people at clients, contracting bodies or competitors involved in the same process.

Service providers and partners

• We select service providers and partners on technical and price criteria, and we check their reputation and standing before hiring them.
• Contracts with service providers and partners include the obligation to comply with this Code and with anti-corruption laws.
• We do not use third parties to do what uGlobally itself is forbidden to do.

People and workplace

• We do not tolerate discrimination, moral or sexual harassment, or any form of violence or intimidation.
• We do not accept child labour, forced labour or conditions similar to slavery, nor do we accept them in our supply chain.
• We respect diversity of origin, gender, age, belief and orientation in our teams and in the programs we run.

Personal data and confidential information

We process personal data in line with the LGPD and the GDPR, as set out in our Privacy policy. Confidential information from clients and partners is shared only with those who need it to do the work, and is never used for personal benefit or for the benefit of third parties.

Records, payments and anti-money laundering

All income and expenses are recorded fully and accurately, with supporting documents. We do not accept cash payments of unidentified origin, nor transactions without a clear economic rationale or with parties we cannot identify.

Communication and training

Every partner, employee and service provider receives this Code at the start of their relationship with uGlobally and confirms in writing that they have read it. Once a year, the team takes part in a refresher session on integrity, anti-corruption and data protection, recorded on an attendance list.

Questions and reporting irregularities

Questions about this Code and reports of possible violations can be sent to info@uglobally.com with the subject "Integrity", including by people outside the company. Reports are handled confidentially by partners who are not involved in the matter. uGlobally does not allow retaliation against anyone who reports a possible irregularity in good faith.

info@uglobally.com · subject Integrity

Consequences

Breaching this Code may lead to a warning, termination of the employment or service contract and, where applicable, a report to the competent authorities.

Review

This Code is reviewed at least every two years, or sooner when the law or the way the company works changes.