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Governance and Ethics

Compliance
Central IT Integrity System

Exponential efficiency that impacts the business.

Central IT's Integrity System is designed to structure and systematize a set of internal integrity principles, guidelines and standards, and to underpin the adoption of actions and routines to maintain compliance and to prevent, detect and remedy misconduct, wrongful, irregular, fraudulent acts, and acts harmful to Central IT's interests and to the public and social interest, in accordance with the terms of the Brazilian Anti-Corruption Law – Law No. 12,846/2013 – and its implementing regulation – Decree No. 11,129/2022 – as well as all other laws aimed at combating corruption, fraud and money laundering.

The principles and guidelines of the Integrity System, aligned with our mission, vision, policy and values, serve as the reference for all Central IT employees and third parties, so that the Company achieves its corporate purpose in an ethical, honest and transparent manner.

Accordingly, employees and third parties must comply with and follow Central IT's policies and regulations, regardless of their hierarchical level.

The Integrity System is made up of the following documents and tools:

Central IT is committed to upholding the highest professional and ethical standards in conducting its business and to continuously raising the awareness of its employees and third parties about the need to combat corruption in any of its forms, money laundering and illicit accounting practices, and does not submit to any situation or influence involving bribery, extortion, kickback payments, revenue concealment or money laundering operations, or other illicit practices.

Central IT Code of Conduct

Our Code of Conduct and Compliance sets out the values, principles and rules that guide the behavior of all Central IT employees, partners and suppliers.

CODIGO-DE-CONDUTA-E-COMPLIANCE-CENTRAL-IT.pdf

Official document · PDF

Download

FAQ – Central IT Integrity System

Frequently asked questions about compliance, integrity and ethical conduct.

So what is Compliance?
Compliance refers to conformity with rules and regulations.
Conformity with what?
Conformity with the law and other applicable regulations.
But what laws and applicable regulations are these, exactly?
This refers to the legislation applicable to Central IT's activities, with particular emphasis on the Brazilian Anti-Corruption Law – Law No. 12,846/2013 – and its implementing regulation – Decree No. 8,420/2015 – and all other laws aimed at combating corruption, fraud and money laundering, as well as the standards that make up CENTRAL IT'S INTEGRITY SYSTEM.
Who must comply?
All Employees, Third Parties, Suppliers and Service Providers, and other individuals and companies acting on behalf of Central IT.
What is the Whistleblower Channel?
It is the communication channel available to employees, third parties and other interested parties, which allows the reporting of possible illicit activities or violations of the standards that make up Central IT's Integrity System, either identified or anonymously.
If I report a colleague who is acting in violation of the standards, will they know it was me who reported them?
No. The whistleblower's identity is protected whenever they choose to file an anonymous report. To ensure that whistleblowers who choose anonymity will never have their identity revealed, and that their information will never be leaked or tampered with, Central IT chose to use an independent Whistleblower Channel.
What should I do if I notice a violation of the Integrity System's standards?
You should file a report through our Whistleblower Channel or by sending an email to compliance@centralit.com.br.
How does the Whistleblower Channel work?
When filing a report through the Whistleblower Channel, the whistleblower may choose to identify themselves or remain anonymous, and record the content of their report, indicating the minimum elements needed to investigate and address the reported matter, namely: identification of the people involved, the date, period and place where the reported event occurred, and any other elements that may help clarify the irregularity.

Review the rules and policies that demonstrate Central IT's commitment to Information Security and data protection:

Have something to report?

Our Whistleblower Channel is available 24 hours a day. Your report is confidential and will be handled with the utmost seriousness.

Go to the Whistleblower Channel