Code of Conduct and Compliance

1. Introduction

TECNAV SISTEMAS LTDA (Consultas Prime) establishes this Code to guide ethical conduct and compliance.

This Code applies to employees, directors, suppliers, partners and service providers.

2. Mission, Vision and Values

• Mission: deliver reliable data for safer decisions.
• Vision: lead the market through excellence and integrity.
• Values: ethics, legality, confidentiality, excellence and respect.

3. Ethical Principles

• Strict compliance with laws and regulations.
• Transparency and accountability in decisions.
• Impartiality and professionalism in all interactions.

4. Commitment to Data Protection

• Purpose and adequacy in data processing.
• Necessity: process only what is essential.
• Security, transparency and data-subject rights (LGPD/GDPR where applicable).

5. Customer Relationships

• Clear communication about services and terms.
• Confidentiality and fair treatment.
• Continuous service improvement.

6. Supplier and Partner Relationships

• Selection based on objective technical and ethical criteria.
• Mandatory legal and anti-corruption compliance.
• Zero tolerance for unfair or abusive labor practices.

7. Anti-Corruption and Fraud Prevention

• No bribery, facilitation payments or undue advantages.
• Accurate and transparent accounting records.
• Reporting and investigation of suspicious conduct.

8. Conflict of Interest

• Avoid conflicts between personal and company interests.
• Disclose potential conflicts promptly.
• No misuse of role or privileged information.

9. Information Security

• Shared responsibility for data security.
• No sharing credentials or sensitive information.
• Immediate incident reporting.

10. Whistleblowing Channel

• Confidential channel with optional anonymity.
• No retaliation for good-faith reports.
• Contact: [email protected] and +55 (11) 3042-1827.

11. Ethics and Compliance Committee

• Oversees adherence to this Code.
• Investigates reports and recommends actions.
• Promotes awareness and periodic reviews.

12. Sanctions and Disciplinary Measures

• Warning, suspension or termination for non-compliance.
• Contract termination for non-compliant partners.
• Legal action when applicable.

13. Final Provisions

• Code remains valid indefinitely.
• Applies to all related parties.
• Subject to periodic updates.

14. International Compliance

• Alignment with UNCAC and OECD anti-bribery principles.
• Adherence to FCPA and UK Bribery Act where applicable.
• Support for GDPR and global best practices.