Acting with Integrity

Agindo com integridade

The SSA Group expects all its administrators, employees, and third parties to be committed to complying with applicable laws and the ethical and transparent guidelines outlined in this Code and our manuals, policies, regulations, and compliance standards.

Best Practices in the Workplace

The SSA Group expects consideration and mutual respect among its administrators, employees, and third parties, and prohibits any type of violence or intimidation in the workplace, ensuring a safe and healthy environment. We expect the building of respectful relationships free from aggressive, discriminatory, or intimidating situations. We are committed to avoiding unprofessional situations or those that negatively impact everyone’s work, so we do not allow or tolerate:

  • The use of offensive words, whether spoken, written, or gestured
  • The transmission of false or misleading information that could be considered slander, libel, or defamation
  • Any type of hostility, ridicule, or humiliation towards others
  • Any act of moral or physical violence, whether in the workplace or elsewhere
  • Any type of discrimination or conduct contrary to human rights.

Moral Harassment

Moral harassment exposes workers to abusive situations involving inhumane and unethical conduct repeated over an extended period in the performance of their duties, affecting the dignity and/or physical and/or mental integrity of a worker.

Sexual Harassment

Sexual harassment can occur through acts, insinuations, or forced physical contacts that represent a clear condition for maintaining employment, influencing career promotions, impairing professional performance, humiliation, insult, or intimidation.

We embrace diversity and ensure that all candidates, employees, and third parties have the same opportunities regardless of race, color, ethnicity, nationality, age, gender, religion, disability, sexual orientation, or any other factor. We believe that different perspectives broaden our vision and promote the creation of a more culturally diverse and enriched environment. We treat everyone equally and do not tolerate prejudice or discrimination in any relationship with our audience, whether clients, suppliers, service providers, or employees.

The SSA Group conducts its work guided by the principles of integrity, human dignity, rejection of prejudice and harassment, respect for life and freedom. Therefore, work that violates Brazilian labor laws is repudiated by the SSA Group.

We preserve the rights of our direct employees and third parties to a safe and healthy working environment, monitoring and ensuring the prohibition of forced or slave labor and the use of child labor.

What is child labor?
Child labor is the illegal situation or exploitation of children and adolescents under 14 years old when they perform tasks in exchange for money or false benefits.

What is forced labor?
Forced labor occurs when people are coerced into performing work through the use of violence or intimidation.

The SSA Group recognizes and respects the right to freedom of association to unions, associations, professional organizations, political parties or any other entities established for legitimate purposes.

Preserving our work community is associated with discipline, efficiency, and appreciation of people, so we expect the attitudes and positions of all our managers, employees, and third parties to reflect this concern by maintaining our work environment clean, organized, and in accordance with the rules for using our facilities.

The assets of the SSA Group are for strictly professional use. In order to add value to our business and optimize our resources, our assets must be protected and our resources saved, therefore, we do not allow:

  • The allocation of assets in violation of company policies.
  • The incorrect, negligent or reckless use of company resources and equipment.
  • The destruction or disposal of resources or assets in an incorrect or illegal manner.
  • Accessing or downloading pirated products through company equipment.
  • The removal of materials and/or equipment from the company without proper authorization.
  • Vandalizing any resource or asset, movable or immovable.

The SSA Group complies with the guidelines of the General Data Protection Law (LGPD), Law No. 13,709/2018.

This law was enacted to protect the fundamental rights of freedom, privacy, and the free formation of the personality of each individual. The law regulates the treatment of personal data, whether in physical or digital form.

The SSA Group treats its institutional information (related to its business) with confidentiality and secrecy, to ensure that it is not used to the detriment of our administrators, employees, third parties, clients, and suppliers. Therefore, we expect everyone to be committed to the confidentiality of the information that is in our possession.

What is information security?
It is the protection of a set of information, whether confidential or not, with the aim of preserving the value they have for an individual or company.

We expect everyone to be committed to the confidentiality of the information that is in our possession.

Information security is characterized by the preservation of:

  • Confidentiality – the security that the information is only accessible to authorized persons.
  • Integrity – the safeguarding of the accuracy, consistency, and completeness of the information and processing methods.
  • Availability – the guarantee that information is available and accessible to those who are entitled to it at the time of their need.

In this regard, we have some recommendations for our professionals:

  • Protect all confidential company information, such as personal data, internal reports, strategic data, and information about our industrial processes.
  • Company equipment and network should only be used for corporate activities.
  • Personal internet use during working hours is prohibited.
  • Access to websites is the responsibility of each user, and access to any page with inappropriate content is prohibited.
  • Sexually explicit material is prohibited from being displayed, stored, distributed, edited, or recorded through company resources.
  • The use of corporate email for sending messages that may compromise the image of the SSA Group before its clients and the community in general and/or cause moral and financial harm to the company is prohibited.
  • Do not execute or open internet links or attached files sent by unknown or suspicious senders.
  • Recording personal files (music, movies, photos, etc.) on the network drives and equipment of the company is not permitted.
  • Any need to acquire and/or install software, systems, or technology services must be previously approved by the IT department.
  • The use of illegal software (without licensing) is strictly prohibited. The IT Management may uninstall any software without a license without prior notice, in compliance with Law No. 9.609, of February 19, 1998 (Software Law).

The disclosure of institutional information of the SSA Group should always be done with the support and approval of the Marketing department, and only the president and directors are authorized to respond on behalf of the company. All internal and external communications of the SSA Group should ensure that the information is complete, ensuring transparency with due confidentiality. In the same vein, it is everyone’s responsibility to protect the company’s image and all its assets, so do not disclose information about our professional activities, take photos or make recordings within the production area and related areas without prior authorization.

The SSA Group values the respect and compliance with all health and safety legislation and regulations, which serve to protect our managers, employees, and third parties from work-related accidents or illnesses, guiding them towards the correct execution of their daily activities.

To ensure the safety of everyone, we must become aware of and respect the workplace health and safety regulations provided by the Specialized Service in Safety Engineering and Occupational Medicine department – SESMT, participating in all training sessions, lectures, and other events promoted by the company.

In order to guarantee the integrity of our employees and safety in our work environment, we do not allow:

  • The possession, use, and distribution of illegal substances on company premises.
  • The consumption of alcoholic beverages.
  • Engaging in professional activities under the influence of alcohol or any other hallucinogenic or narcotic substance.
  • Smoking on company premises.

What are prohibited substances in the workplace?
Alcoholic beverages, cigarettes, drugs, narcotics, hallucinogens, and any other substance that alters people’s normal consciousness.

Additionally, the SSA Group does not allow any person to carry firearms or stun guns in its work premises, except for employees and service providers released by law and duly identified, such as guards, security personnel, and escorts.

 

What is compliance?

Compliance, or conformity, is being in accordance with laws, regulations, and standards, whether they are internal or external.

At Grupo SSA, we do not tolerate actions that are not in compliance with legal requirements. Our culture and behavior are focused on complying with laws, regulations, and standards, and producing safe, authentic, lawful, and high-quality food products that meet Grupo SSA’s standards. Therefore, we believe that it is the duty of all our administrators, employees, and third parties to fully comply with them.

In this sense, Grupo SSA has an Ethics and Compliance Committee whose objective is to:

  • Monitor compliance with this Code of Ethics and Conduct and other company policies.
  • Evaluate and investigate complaints received regarding conduct that is not in compliance with Grupo SSA’s policies.
  • Implement disciplinary measures in case of proven misconduct or refer them, along with an analysis report, to the Board of Directors, via the Audit Committee, as appropriate.

The SSA Group understands that ethics, transparency, and reliability are the foundations of an honest and diligent work. Therefore, ethics go beyond compliance with laws: it is the starting point for our decision-making process.

All of our administrators and governance bodies are aware of and demand ethical behavior from our employees and third parties. Therefore, in addition to the prohibition provided for by Law No. 12,846 of August 1, 2013 (“Anti-Corruption Law”), practices of fraud, corruption, and bribery are strictly prohibited by the SSA Group.

What is fraud?
Fraud is an irregular act carried out to distort information, data, or facts that result in obtaining undue gains or harm to third parties.

What is corruption?
Corruption is the payment or receipt of values or benefits to obtain undue advantages. Corruption can involve representatives of public agencies, service providers, suppliers, customers, and transporters.

What is bribery?
Bribery is the act of paying or offering a benefit (gifts, presents, meals, trips, etc.) to a government representative, public agency representative, or private sector representative for the practice of an illegal act.

We do not tolerate:

  • Conduct considered fraudulent.
  • Favoring or benefiting public representatives, suppliers, or service providers.
  • Taking advantage of systemic flaws for personal gain.

Practical examples:

  • Favoring a particular supplier in a hiring process in exchange for some personal benefit.
  • Altering the stocks registered in the company’s system.
  • “Slacking off” at work to earn overtime.
  • Modifying data from a report to omit or alter information.
  • Offering some form of compensation (money, goods, or services) for the other party to do something that, within their functions, they should not do or to not do something that they should do.
  • Offering any type of financial or non-financial advantage to a public agent.
  • Taking possession of company merchandise and selling it illegally.
  • Replacing a high-value ingredient or part of the product with a lower-value ingredient or part without informing the consumer and competent authorities.
  • Fraudulent and intentional substitution, dilution, or addition made to a product or raw material to obtain profit, increasing the apparent value of the product or reducing its production cost.

Attention!
If you witness acts of fraud, corruption, or bribery, feel intimidated or incited to practice them, please contact the Ethics and Compliance Committee or make a report through our Ethics Channel.

The SSA Group is committed to conducting its business in a transparent and lawful manner. All of our financial operations must be properly recorded and substantiated.

We reject any form of illicit payment and/or receipt and promote disciplinary measures in case of proof of the practice, also respecting our Anti-Corruption Policy.

What is money laundering?
Money laundering is the practice of hiding the origin of money or assets derived from illegal means in order to make it appear legal.

What is terrorism financing?
Financing terrorism is contributing to the acquisition of an asset, good, or financial resource with the aim of financing criminals who have as their activity, even occasionally, terrorism (acts committed with the purpose of causing social or widespread terror).

Our administrators, employees, and third parties must be vigilant and prepared to identify and communicate situations involving conflicts of interest, acting with impartiality and performing their duties without their judgments and actions being influenced by personal interests that conflict with those of the SSA Group.

What is a conflict of interest?
Conflict of interest situations arise when administrators, employees, or third parties have interests that differ from those of the company. Conflict of interest occurs when any of them make decisions related to the company, but for the benefit of themselves, a family member, friend, or any other individual.

In practice: Conflicts of interest can occur, for example, when an employee provides services to a competitor of the SSA Group, or when an employee hires a supplier due to a personal relationship rather than the technical and commercial quality of the supplier.

Attention!
For a situation to be characterized as a conflict of interest, it is not necessary for there to be any harm to the SSA Group or financial gain resulting from the conflicting situation.

Our administrators, employees, and third parties are instructed on monitoring family relationships. Existing cases should be reported to the People and Management Department or the hiring department at the time of hiring or when identified. All situations involving family relationships will be evaluated and monitored by our Ethics and Compliance Committee.

Administrators and employees of the SSA Group are instructed on monitoring related parties. Existing cases should be reported to the Compliance and Risk Management Area, and the Ethics and Compliance Committee will individually analyze all cases.

What are related parties?
Related parties are, in summary, natural or legal persons with whom a company may negotiate under privileged conditions that are not common and standard due to their relationship or any other influence. For further information, refer to the Company’s Related Party Transactions and Conflict of Interest Administration Policy.

I am a related party of the SSA Group, what should I do?
Inform the Compliance and Risk Management Area and report the situation. There is no problem in being a related party, but the company will monitor this issue to ensure that the same opportunities and conditions are established for third parties who do not have the same relationship.

The administrators, employees, and third parties of the SSA Group may accept gifts or presents up to 20% of the current minimum wage, always aware that the acceptance cannot result in any duty or favor in return. If a gift or present of higher value is received under conditions that make its refusal impossible, it must be forwarded to the Compliance area for proper evaluation and decision. Please note that the receipt of gifts and presents in cash is not allowed. In the case of the concession of gifts, the criterion of being a company product or an institutional item, totaling a maximum value of up to 20% of the current minimum wage, must be respected. In case of doubts, consult the Compliance area.

Attention!
Additionally, the granting of gifts or presents to agents or representatives of public agencies is conditioned upon the approval of the Compliance area.

Any questions or exceptions to the limits and provisions provided in this Code of Ethics and Conduct should be forwarded to the Ethics and Compliance Committee, which will evaluate and make a decision.

Donations to be made on behalf of the SSA Group must be evaluated and approved by the Social Responsibility Department and the Compliance area. Sponsorships to be made on behalf of the SSA Group must be evaluated and approved by the Marketing Department and the Compliance area. In case of doubts, consult the Compliance area.

Attention!

Donations to candidates and political parties are prohibited by law.

The SSA Group always seeks to conduct its relationships with third parties based on ethics, transparency, reliability, and respect, and we expect our managers and employees to uphold these principles.

In addition to this Code of Ethics and Conduct, the SSA Group currently has several formal policies established to help guide activities and achieve its objectives, such as:

  • Disclosure of Information and Trading in Securities Policy;
  • Related Party Transactions and Conflict of Interest Administration Policy;
  • Risk Management Policy;
  • Administrator Compensation Policy;
  • Administrator Nomination Policy.

The customers of the SSA Group are companies that purchase and resell our products, as well as individuals and families who are our end consumers. Regardless of the category, all our customers are treated with commitment and efficiency.

In addition to complying with Law No. 8,078 of September 11, 1990 (“Consumer Protection Code”), we want to ensure their satisfaction, so we value the quality of our products and operational processes and are always open to listening to them.

Suggestions, compliments, or complaints about our products?
Call our customer service center – SAC – CUSTOMER SERVICE at 0800 648 9001.

Our suppliers, service providers, and production partners are relevant links in the SSA Group’s supply chain, and in order to maintain transparent and lasting relationships, we strive to ensure that our strategy, values, and principles are aligned. We ensure that the rights and obligations of both parties are preserved, and we establish transparent and ethical negotiation processes.

In this matter, it is essential that a solid and lasting relationship be established, as well as mutual trust with each supplier, service provider, and production partner, establishing relationships that value and apply our ethical precepts. We emphasize that we do not subject ourselves to any personal promises or advantages as a result of contracts.

Likewise, we require that everyone is committed to the culture, ethical guidelines, and integrity of the SSA Group, and must know and comply with our internal policies and regulations, including this Code and our Anti-Corruption Policy.

We maintain a rigorous due diligence process on our suppliers, service providers, and production partners to ensure that they also follow SSA Group standards with respect to legislation, ethics, and conduct.

We value good relationships with our competitors, especially for maintaining fair competition and a respectful environment with our peers. We prohibit any type of arrangement or combination with competitors and any unfair trade practices and espionage, always observing Law 12.529/2011, the Antitrust Law.

We demand that all administrators, employees, and third parties of the SSA Group maintain honest and transparent relationships with agents and public agencies. Therefore, we do not tolerate:

  • Privileges or favoritism towards representatives of public agencies, even with the intention of benefiting the SSA Group, as fraudulent, corrupt, or bribery practices are always harmful.
  • Offering privileges, bonuses, or personal benefits to any government authority or representative of public agencies.

Attention!
There are precautions that can help inhibit and prevent illegal acts:

  • Maintain courteous and professional dialogue with representatives of public agencies, discussing only relevant issues related to the reason for contact.
  • Do not request favors or unofficial assistance from representatives of public agencies to speed up any request or need of the SSA Group.
  • Remain impartial in political matters and express ideological and/or partisan opinions on a personal basis, avoiding any position that may be linked to the image of the SSA Group.
  • Always establish contact with public agents through formal means and with at least 02 (two) representatives of the company.

In case of doubts, consult our Public Agency Relationship Policy.

The SSA Group respects and recognizes the representative organizations of civil society, unions, associations, and other non-governmental organizations. We always seek open and constructive dialogue, safeguarding good relationships.