1.  Purpose

This document establishes Induscabos’ Code of Ethics and Conduct, outlining the desired standards of behavior for employees and business partners, committed to high standards of integrity and sustainability. Induscabos maintains zero tolerance for unethical business practices, such as bribery and corruption. We expect our partners to uphold similar standards and conduct their business ethically.

2. Scope

This document applies to all employees and business partners (suppliers and clients).

3. General Conduct Guidelines

3.1. Conduct Guidelines for Employees

All employees contribute to a corporate culture characterized by cooperative working relationships. Tolerance and mutual respect are core values of both management and staff. Employees are expected to act ethically and responsibly, respecting each individual’s dignity. Workplace issues should be discussed collaboratively to find solutions. Mutual esteem is built on internal conviction and willingness to act, fostering a cooperative, tolerant, and open environment.

Induscabos expects all employees to promote a positive environment through respectful behavior. The opportunity to share diverse cultures and perspectives enriches everyone and motivates collaboration, forming the foundation of the company’s success.

3.2. Conduct Guidelines for Third Parties

Employees must be aware that their behavior represents the company. Their conduct affects both external reputation and internal culture. All employees should treat others as they wish to be treated, including clients and business partners. This also applies to partner employees working within Induscabos facilities. Ethical principles and respect must be upheld in public presentations and advertising.

4. Social Responsibility

We believe social responsibility is essential to our long-term success and applies to both employees and business partners.

4.1. Human Rights

Induscabos respects and supports full compliance with human rights. As an employee or business partner, you must:

• Respect the dignity, privacy, and rights of every individual
• Refuse to coerce anyone into performing work against their will
• Not tolerate inappropriate behavior, including gestures, language, or physical contact of a sexual, coercive, threatening, abusive, or exploitative nature

4.1.1. Non-Discrimination

An open-minded and unbiased approach to others’ opinions and attitudes is essential. We must respect diversity and treat all employees fairly and impartially. Discrimination based on gender, race, origin, or belief conflicts with our values.

4.1.2. Forced Labor

Induscabos condemns all forms of forced and compulsory labor.

4.1.3. Child Labor

Induscabos supports the eradication of child labor. Children must not be deprived of development, health, or safety. Their dignity must be respected.

4.1.4. Working Conditions

Induscabos opposes any exploitative working conditions.

4.1.5. Harassment

Induscabos does not tolerate any form of harassment. Harassment includes physical, verbal, or non-verbal behavior that interferes with performance or creates a hostile work environment.

Examples include:

• Sexual Harassment: Sexual advances, requests for sexual favors, verbal or physical conduct of a sexual nature, or display of sexually suggestive objects or images
• Moral Harassment: Verbal or physical conduct that disrupts another employee’s performance or creates fear or hostility, including abuse of authority or offensive behavior

Business partners must:

• Avoid discrimination based on gender, age, ethnicity, nationality, religion, disability, union membership, political affiliation, or sexual orientation
• Not tolerate or use child labor at any stage of operations, unless in full compliance with applicable laws
• Not use forced or prison labor and allow employees to leave freely with prior notice

5. Ethical Code

5.1. Doing What Is Right

Ethical behavior means doing what is right, even when no one is watching. It involves making decisions that reflect integrity, fairness, and respect for others. Employees and business partners must act responsibly and uphold the company’s values in all situations.

5.2. Trust

Trust is built through consistent ethical behavior. Induscabos expects all individuals to honor their commitments, communicate transparently, and respect confidentiality. Trust strengthens relationships and supports long-term success.

6. Conflict of Interest

6.1. Fair Negotiation

Employees and business partners must engage in fair and transparent negotiations. Decisions should be based on merit, quality, and value—not personal interests.

6.2. Avoiding Conflicting Interests

Avoid situations where personal interests conflict with professional responsibilities. Disclose any potential conflicts to management and seek guidance when in doubt.

6.3. Bribes, Kickbacks, and Other Payments

Induscabos strictly prohibits offering or accepting bribes, kickbacks, or any improper payments. All transactions must be lawful and transparent.

6.4. Anti-Corruption Law

Comply with all anti-corruption laws and regulations. Report any suspicious activity or unethical conduct immediately.

6.5. Financial Interests in Employees / Business Partners

Employees must not hold financial interests in companies that do business with Induscabos unless disclosed and approved. Business partners must avoid hiring or engaging with Induscabos employees in ways that create conflicts of interest.

6.6. Gifts, Entertainment, and Loans

Avoid giving or receiving gifts, entertainment, or loans that could influence business decisions. Modest, customary gifts may be acceptable if they do not create obligations or expectations.

7. Environmental Ethics

Induscabos is committed to environmental responsibility. Employees and partners must:

• Promote sustainable practices
• Reduce waste and conserve resources
• Comply with environmental laws and standards
• Support initiatives that protect the environment

8. Compliance with Laws

All employees and business partners must comply with applicable laws, regulations, and industry standards. This includes labor laws, environmental regulations, anti-corruption statutes, and data protection rules.

9. Confidential Information and Data Protection

Protect confidential information and personal data. Do not disclose sensitive information without authorization. Use company systems responsibly and safeguard against data breaches.

10. Good Practices

Encourage continuous improvement, innovation, and ethical leadership. Share best practices and support training initiatives. Promote a culture of accountability and excellence.

11. Sanctions

Violations of this Code may result in disciplinary action, including termination, legal consequences, or exclusion from business relationships. All reports will be investigated fairly and confidentially.

12. Communication

This Code must be communicated to all employees, suppliers, and partners. Induscabos will provide training and resources to ensure understanding and compliance.

We have a feedback channel for suggestions, compliments, or criticisms, where identification is optional. Email: ouvidoria@inducabos.com.br