CODE OF ETHICS AND COMPLIANCE

AD Digital Integrity Program

Ethical Behavior:

Aggo straight, do well, without harming others. It's being altruistic, it's being calm with your personal conscience. It is also about acting in accordance with the moral values of a given society. Any ethical decision has a set of fundamental values behind it.

1. Definitions

1.1. What is Compliance?

Compliance is an organized program to strengthen and structure an internal culture of integrity. This is an organized process and not just a document of intent.

1.2. What is the Code of Ethics?

The Code of Ethics is just one of the steps in aligning an integrity program, which establishes the basic guidelines and provides for the minimum conduct expected of an employee in the company. It seeks to align each employee with the vision, ethics, values, mission and ethical limits of their work in the company.

So you must ask yourself: What is the difference between Ethics and Morals?

Briefly, the differences between the two terms are: Morality predicts right and wrong; ethics predicts good and evil. Morality is specific and normative conduct; ethical values are principles, the result of reflection on actions and standards of conduct.

While Moral is formed by intrinsic values and formed by the culture and personal experience of each person, therefore reflecting on their personal values and conduct.

Ethics is linked to the individual's behavior towards society in the name of something or some group that he represents, in this way it can be formed by guidelines and directives from that something or group so that all its individuals have standard behaviors in accordance with the values of that group.

1.3. Integrity Program

What is it and what is it for?

An integrity program is the set of institutional measures and actions aimed at preventing, detecting, punishing and remediating fraud and acts of corruption. In other words, it is a structure of organizational incentives – positive and negative – that aims to guide and guide the behavior of public agents in order to align them with the public interest. Instituting an integrity program does not mean dealing with a new subject, but using themes already known by organizations in a more systematic way. 

In this sense, the instruments of an integrity program include guidelines already adopted through internal audit, correction, ombudsman, transparency and corruption prevention activities, programs and policies, organized and directed towards promoting institutional integrity. 

Integrity management is considered a fundamental component of good governance, a condition that gives other activities carried out by the government and individuals, not only legitimacy and reliability, but also efficiency. 

A well-developed integrity management, where all systems (correction, internal controls, ethics management, among others) are well coordinated, encourages agents to make decisions based on technical criteria, and not based on private interests, which , in turn, increases the quality of the provision of public services.

 

What are the four axes of the Integrity Program?

• Support from Senior Management

• Responsible Body – Compliance Officer

• Risk analysis

• Continuous Monitoring

1.4. What are RISKS?

Risks are events with negative impacts on achieving an objective. RISKS ARE POTENTIAL EVENTS THAT ARE NOT CERTAIN.

It is very important, before talking about risk assessment, that you know the objectives you want to achieve. 

Effectively conducting a risk analysis involves a planning phase, interviews, documenting and cataloging data, analyzing data and establishing necessary measures and remediation.

1.5. ChatGPT

ChatGPT is an intelligent virtual assistant in the online chatbot format with artificial intelligence developed by OpenAI, specialized in dialogue launched in November 2022. The chatbot is a language model adjusted with supervised and reinforcement learning techniques.

1.6. Corruption

Whether directly or indirectly, undue advantage to a public agent, or a third party related to him.

For the purpose of achieving an improper benefit, such as obtaining or maintaining business or government authorization.

2. INTEGRITY AND PROGRAM COMPLIANCE – DIGITAL AD

Created: May 29, 2023

Updates: 00

Regulation:

• Law 12,846 of August 1, 2013

• Decree 11,129 of July 11, 2022

• Law 14,133 of April 1, 2021

2.1. LEGAL BASIS: But what would an Integrity and Compliance Program be?

Pursuant to Article 56 of Decree No. 11,129 of July 11, 2022, for the purposes of the provisions of this Decree, an integrity program consists, within the scope of a legal entity, of the set of internal mechanisms and procedures for integrity, auditing and encouraging reporting irregularities and the effective application of codes of ethics and conduct, policies and guidelines, with the aim of: 

I – prevent, detect and remedy deviations, fraud, irregularities and illicit acts committed against public administration, national or foreign; It is

II – foster and maintain a culture of integrity in the organizational environment.

Single paragraph. The integrity program must be structured, applied and updated according to the characteristics and current risks of the activities of each legal entity, which, in turn, must guarantee the constant improvement and adaptation of said program, aiming to guarantee its effectiveness .

2.2. Validity and Effectiveness of the Integrity and Compliance:

The validity and effectiveness requirements of an integrity and compliance program, in accordance with article 57 of Law 11,129 of 2022, will be evaluated regarding its existence and application, according to the following parameters:

I – commitment of the legal entity's senior management, including the councils, evidenced by visible and unequivocal support for the program, as well as the allocation of adequate resources;

II – standards of conduct, code of ethics, integrity policies and procedures, applicable to all employees and administrators, regardless of the position or function performed;

III – standards of conduct, code of ethics and integrity policies extended, when necessary, to third parties, such as suppliers, service providers, intermediary agents and associates;

IV – periodic training and communication actions about the integrity program;

V – adequate risk management, including its analysis and periodic reassessment, to make necessary adaptations to the integrity program and the efficient allocation of resources;

VI – accounting records that completely and accurately reflect the transactions of the legal entity;

VII – internal controls that ensure the prompt preparation and reliability of reports and financial statements of the legal entity;

VIII – specific procedures to prevent fraud and illicit activities within the scope of bidding processes, in the execution of administrative contracts or in any interaction with the public sector, even if mediated by third parties, such as paying taxes, being subject to inspections or obtaining authorizations, licenses, permits and certificates;

IX – independence, structure and authority of the internal body responsible for applying the integrity program and monitoring its compliance;

X-channels of denunciation of irregularities, open and widely disclosed to employees and third parties, and mechanisms intended for the treatment of complaints and the protection of good faith complaints;

XI – disciplinary measures in case of violation of the integrity program;

XII – procedures that ensure the prompt interruption of detected irregularities or infractions and the timely remediation of the damages generated;

XIII – appropriate, risk-based diligence to:

  1. a) hiring and, as appropriate, supervising third parties, such as suppliers, service providers, intermediary agents, dispatchers, consultants, commercial representatives and associates;
  2. b) hiring and, as appropriate, supervision of politically exposed people, as well as their family members, close collaborators and legal entities in which they participate; It is
  3. c) carrying out and supervising sponsorships and donations;

XIV – verification, during mergers, acquisitions and corporate restructuring processes, of irregularities or illicit acts or the existence of vulnerabilities in the legal entities involved; It is

XV – continuous monitoring of the integrity program with a view to improving it in preventing, detecting and combating the occurrence of harmful acts provided for in art. 5th of Law No. 12,846, of 2013.

  • 1º When evaluating the parameters referred to in the caput, the size and specificities of the legal entity will be considered, through aspects such as:

I – the number of employees, employees and collaborators;

II – revenue, also taking into account the fact that it is qualified as a micro-enterprise or small company;

III – the corporate governance structure and the complexity of internal units, such as departments, directorates or sectors, or the structuring of an economic group;

IV – the use of intermediary agents, such as consultants or commercial representatives;

V – the market sector in which it operates;

VI – the countries in which it operates, directly or indirectly;

VII – the degree of interaction with the public sector and the importance of contracting, investments and public subsidies, authorizations, licenses and government permissions in its operations; It is

VIII – the number and location of legal entities that make up the economic group.

  • 2 The effectiveness of the integrity program in relation to the harmful act being investigated will be considered for the purposes of the assessment referred to in the caput.

2.3. If AD Digital has a Code of Ethics, does it also have, in itself, a Compliance Program?

No. The Compliance Program requires a long process of effective implementation and guidance of a culture within the corporation. In other words, it is a series of actions that lead senior management and its staff to act coherently, ethically and in accordance with current legislation.

Therefore, this document is part of a set of actions taken by AD Digital so that its employees are guided and properly trained in accordance with the Corporation's ethical values. The actions are:

  • Presentation and availability of the Integrity Program – Code of Ethics to everyone;
  • Personal training during Onboarding;
  • Daily monitoring of employees' activities, by the Board and AD Compliance Officer, as well as resolving specific doubts;
  • Signing of Declarations and Commitments by the Board of Directors of AD Digital.

2.4. Purpose of the Integrity Program and Compliance by AD Digital

With commitment and corporate responsibility, DIGITAL AD Its main purpose is to build and maintain trust among all its employees, partners, customers, government entities and the community it serves. This commitment is expressed primarily by this Code of Ethics and Conduct – INTEGRITY AND PROGRAM COMPLIANCE – which is designed, structured and repeatedly reviewed around the standards that reflect our culture, mission and values, with the aim of perpetrating a culture of integrity, sustainability, honesty, transparency and good conduct policy.

2.5. AD Digital Culture

Over almost three decades of existence, AD Digital has gained recognition from its customers and partners for being an innovative company committed to delivery. And we owe this to our culture, which permeates all areas of the company and guides everything we do. But what are the VALUES that are part of this culture? And what is your influence on people inside and outside AD?


COMMITMENT AND COLLABORATION IN EVERYDAY LIFE

At AD Digital, we go to great lengths to perform our work with excellence; We are always willing to exceed expectations in our deliveries. And it is only through teamwork, with commitment and focus, that we can achieve great results.

Our team is made up of diverse and multidisciplinary professionals, each one a protagonist in their area of expertise and all with autonomy to achieve our biggest objective: delivering incredible things. We are engaged, agile and committed to the success of our customers, partners and employees.


A HISTORY OF PERSEVERANCE AND CHARACTER

Over the course of 26 years of history, we have faced countless challenges alongside customers and partners. We follow various transformations and movements in the technology market, always making our business more flexible and reinventing ourselves to support our customers on new journeys.

This resilient spirit is already an intrinsic part of AD Digital’s culture. With each new market cycle, new challenges will arise and we will be there again, fighting until we find a solution in partnership with our customers.


TRANSPARENCY AND FRANKNESS ARE PART OF OUR DNA

Trust is the foundation of our business. For this reason, we seek to maintain a clear and honest communication network with customers, partners and employees. For us, at AD Digital, working with transparency is both a sign of respect and an invitation to join hands and walk together on another new journey.


Innovation: DELIVERING AMAZING THINGS

For our team, innovating is not a differentiator, but rather a natural activity, like breathing and walking. We think big, and then we take small steps towards the goal of better serving our customers. We explore new ideas and are inspired by the ideas of others, with the aim of discovering the new and unlocking the true potential of people, ecosystems, projects and technologies.

2.6. Top Management Commitment

  • Examples of Compliance with the Rules:The board adheres to the rules and is a concrete example of good behavior. Inspiration is the best way to guide employees to act ethically and responsibly.​

 

  • Involvement in Prevention:The board proactively engages in prevention efforts and develops activities aimed at promoting the good message about corporate integrity.​

 

  • Written Declarations:The certificates signed by the Board demonstrate their involvement and ethical recognition with the Company's new standards.​

 

  • Constant Interaction:Whenever possible, one of the board members tries to be present during training, especially when large groups are involved, thus facilitating interaction.​

2.7. Anti-Corruption Policy

  • The practice of corruption, in the context of the relationship with the Public Sector, by Third Parties and Collaborators, including their co-owners, directors, administrators, employees, interns, service providers and outsourced workers, is prohibited and considered a serious violation of these Rules.

    Under no circumstances are Collaborators or Third Parties authorized to pay or receive from public agents any form of bribe or bribe, including any undue advantage (as defined below), or give or receive undue benefits to private agents, inside or outside the Brazil, in any activity related, directly or indirectly, to AD-Digital, as provided for and detailed in the subsequent sections of these rules.

    Problems caused by corruption

    Corruption is one of the great evils that affect society.

    • Generates political, social and economic costs/damages.
    • It compromises political legitimacy.
    • It weakens democratic institutions and moral values in society.
    • It causes an environment of insecurity in the economic market.
    • In practice, it takes different forms, from offering small amounts to speed up the granting of a license to major fraud in bidding procedures.

    What is undue advantage?

    Undue advantage comprises any type of advantage promised, offered or given to a Brazilian or foreign public agent, to a relative of the public agent or to a third person related to the public agent, in exchange for a benefit or expectation of benefit for himself, for AD -Digital or any related Third Party. Such an advantage is not limited to cash payments, and may include, depending on the circumstances, for example, gifts, meals, job offers, among other valuable goods.


    What is a public agent?

    For the purposes of these Rules, a public agent is any person who, even if temporarily or without remuneration, (I) performs a public function; (II) work or hold a position in a federal, state or municipal public body, Brazilian or foreign; (III) works or holds a position in a company or institution controlled or administered by the Government; (IV) represents or holds a position in a political party; or (V) is a candidate for political office.

    Examples of public agents are:

    • Tax and Government Agents;
    • Municipal, state, federal or military guards and police;
    • Firefighters and Military of the Armed Forces;
    • Ministers, Judges, Judges, Prosecutors, Prosecutors and Defenders;
    • Presidents of the Republic, State Governors, Mayors of Municipalities;
    • Senators, Federal and State Deputies and Councilors;
    • Public employees in general, whether gazetted or not;
    • Notaries or Notaries and Registration Officers or Public Registrars;
    • Employees, Members or Representatives in general of state-owned companies and mixed-capital companies, such as: Petrobrás, Caixa Econômica Federal, Banco do Brasil, Correios, Furnas, Eletrobrás, etc.;
    • Employees, Members and Representatives in general of authorities and foundations, such as: CADE, CVM, BACEN, BNDES, IBAMA, FUNAI, etc.;
    • Employees, Members and Representatives in general of regulatory agencies, such as: Anatel, Ancine, Aneel, Anvisa, etc…

2.8. Risk analysis

Generally, risk analysis involves, among other measures, interviews with employees different from the company and analysis of documents and takes into account a series of factors such as the country in which the parties involved are located, field of activity, sales to the public administration, use of third parties, form of marketing, etc.​

2.9. Internal Relationship

MUTUAL RESPECT

The success of a company does not depend exclusively on the quality of its products and/or services to be considered successful. At AD DIGITAL we believe that success is linked to credibility and to this end we make an essential commitment to ethics in all our actions, especially in the process of hiring our Employees, Third Parties and Suppliers.

Our principles of conduct and ethics manifest our interest in treating customers, employees and suppliers respectfully, always offering professional, harmonious and transparent treatment.

Our Code of Conduct and Ethics represents our commitment to defending what we believe in, following a responsible, ethical, transparent stance and mutual respect among everyone.

As a condition for hiring, any and all contractors must undertake, for themselves and their Representatives, to: (I) respect Federal Law No. 12,846 of August 1, 2013, Federal Law 14,133 of April 1, 2021, the Decree No. 8,420 of March 18, 2015, Decree No. 11,129 of July 11, 2022 and any and all other applicable anti-corruption regulations, Brazilian or foreign (together, “Anti-Corruption Legislation”); and (III) respect the provisions of these rules or maintain and respect its own anti-corruption rules, equivalent to those set out in this document.

Subject to the ethical limits set out in these Rules, AD-Digital, its commercial partners and collaborators, in accordance with their best interests and at their sole discretion, must also observe the following rules:

  • AD DIGITAL employees and Third Parties may not subcontract the services entrusted to them, in whole or in part, without prior and express approval from AD-Digital, and such subcontracting, when expressly authorized, is subject to the subcontractor obtaining adherence to the present Rules or demonstration that they follow their own anti-corruption rules equivalent to those set out in this document;
  • AD DIGITAL employees and Third Parties may not hire directly or indirectly (through another legal entity) an employee of a Commercial Partner or Customer, whether or not they were involved in providing the service or supplying goods. Unless there is prior communication, with a common agreement established between the parties involved (AD Digital and Employer). In the case of a former employee, the restrictive period of 12 (twelve) months after the termination of the contract will be considered.

Violation of Anti-Corruption legislation or these Rules of Conduct and Ethics by the Employee and/or Third Party will result in a violation of the contract signed with AD-Digital, giving the latter the right to terminate the contract in advance, or dismissal from work for just cause, without loss and damage recovery.

OBLIGATIONS

In addition to ensuring compliance with the provisions of these Rules, employees/suppliers/third parties must ensure that their Representatives, when providing services, especially when they are on the premises of AD-Digital and its customers or interacting with AD-Digital contractors or even representing AD-Digital in any way, observe the following provisions:

I – Respect for others

During the provision of services, employees/suppliers/third parties must treat any and all people with respect, and acts of moral, sexual harassment or other abusive conduct will not be tolerated.

II – Political Activities

Political activities cannot be carried out within the premises of AD-Digital and its customers. Employees/suppliers/third parties who wish to engage in political activities must do so in their personal sphere, outside the premises and service provision hours and without any type of association with AD-Digital.

III – Work Safety

Employees/suppliers/third parties must comply with all occupational health and safety standards, whether set out in Brazilian legislation or in internal policies published by AD-Digital.

IV – Use of goods and resources

The use of assets and resources, such as communication devices, computers and corporate cell phones, from AD-Digital, especially those made available to employees/third parties, must be done responsibly and conscientiously, for professional purposes and never in conflict with the objectives of AD-Digital or the provisions of these Rules.

In relation to such assets and resources, employees/third parties are prohibited from:

Using corporate internet access, corporate email or computers and other AD-Digital equipment for illegal, unethical or inappropriate activities in the work environment, such as gambling, pornography, committing crimes, etc., with reservations authorized cases of necessary access, due to the professional duties carried out.

Share passwords and/or use corporate internet access, corporate email or computers and other AD-Digital equipment in violation of the respective information security policies and use of social networks adopted by AD-Digital.

Use AD-Digital assets, resources, internal reports or information for your own benefit or to favor third parties.

V – Image and brands

Employees/Suppliers/Third Parties must ensure the preservation of AD-Digital's image and brands. This means having attitudes consistent with AD-Digital's values and adopting the following attitudes in your daily life:

  • Always refer to AD-Digital and/or AD Employees and Suppliers respectfully.
  • Do not use AD-Digital brands outside the scope of your professional activities and only to the extent expressly authorized in the contract.
  • Interact with other organizations always in a professional manner.
  • When applicable, always use uniforms or items with AD-Digital brands responsibly.
  • Inform the competent areas of AD-Digital of any situation in which there is misuse of brands and/or damage to the image of AD-Digital.


CONFLICT OF INTERESTS

Collaborators/Suppliers/Third Parties must contribute to an environment free from conflicts of interest, with the conduct of business and/or decision-making in the face of a potential conflict of interest being prohibited. Suppliers are also prohibited from using AD-Digital's visibility or prestige to influence authorities or obtain personal advantage, whether material or otherwise.


COPYRIGHT AND INTELLECTUAL PROPERTY

THE COLLABORATOR declares to be aware that any and all rights arising from or related to the work performed by him/her, directly or indirectly, with the services provided as a result of this contract, will belong exclusively to AD DIGITAL, in accordance with current legislation.

Law 9609/98 Art. 4 Unless otherwise stipulated, the rights relating to the computer program, developed and prepared during the term of the contract or statutory relationship, expressly intended for research and development, or in which the activity of the employee, service contractor or civil servant is foreseen, or even, which arises from the very nature of the charges relating to these relationships.

At this point and in accordance with Article 49 of Law 9610 of 1998, the assignment and transfer in favor of AD DIGITAL is also the subject of this contract, expressly, in full, on a universal and free basis, on an irreversible and irrevocable basis, for the purposes of use at any time, for the purposes of economic use or not, in Brazil and/or abroad, of all copyrights on documents in general relating to Works that have already been or are still created by the ) COLLABORATOR within the scope of the working relationship with AD DIGITAL, such assignment covering the creation, improvement, writing, review, editing, translation, adaptation and any and all activities that give rise to copyright protection in relation to the aforementioned Works, which arise, directly or indirectly, from the activities carried out by the COLLABORATOR due to the relationship maintained with AD DIGITAL.

The provisions of the Clause above are valid for as long as the Work is protected by copyright.

The PARTIES undertake to comply with the provisions of Law 9,610/1998 – which provides for copyright; Law 9,609/98 – which provides for the protection of intellectual property of computer programs and their commercialization in the country; to Law 8,666/1993 – Public Administration Tenders and Contracts Law, legislation relevant to administrative matters and Public Law, and the following clauses and conditions:

RIGHT TO USE IMAGE

THE COLLABORATOR authorizes the use of his/her image in any and all advertising material to be produced by AD DIGITAL, for an indefinite period, definitively, without any cost to AD DIGITAL.

This authorization to use an image declares the authorization to use the COLLABORATOR's image, expressly and irrevocably, free of charge, even if it is used for commercial purposes.

Agreement with this clause grants authorization to use the image throughout national and international territory, in all forms of use, as long as the legislation established in the territory where the image will be used is respected, without causing any moral or criminal harm to the assignor.

2.10. External Relationship - Customers

RELATIONS WITH PUBLIC AGENTS

  1. Prohibition of offering undue advantage

Collaborators and Third Parties are prohibited from promising, offering or giving, directly or indirectly, undue advantage to a public agent (as such terms have already been defined previously), Brazilian or foreign, their relatives or third person related to them, with a view to obtaining any favoritism or expectation of favoritism, directly or indirectly linked to the Employee or Third Party's relationship with AD-Digital, in accordance with the definitions in these Rules.
By “favoring”, we mean any attempt to influence an act or decision of a public agent in their official capacity, such as, for example, the issuance of licenses or public authorizations, customs clearance, the signing or extension of contracts with public entities, acting in inspections, making decisions on the acquisition of advertising space, among others.

The following are considered “relatives” of a person, for all purposes of these Rules: their ancestors and descendants in a straight line, their siblings, their spouse or partner, and also their ancestors and descendants in a straight line and their siblings. your spouse or partner.

 

  1. Gifts and courtesies for public officials

Under no circumstances may gifts, courtesies or benefits be offered or granted to public agents and their relatives or to third parties related to them with the aim of influencing public authority decisions in favor of the interests of AD-Digital or employees or third parties. For the purposes of these Rules, benefits or advantages include – but are not limited to – gifts, courtesies, dinners, lunches, trips and accommodations.

Subject to the other provisions of these Rules, the offering of gifts, courtesies, benefits, tickets, travel, accommodation, food expenses and similar to public agents who have any relationship with AD-Digital must always be previously and expressly approved by AD-Digital. . When analyzing such requests, the provisions of the AD-Digital Code of Ethics and Conduct and policies relating to this topic will be observed.

Even in the event of authorization by AD-Digital, the offering of gifts, courtesies, benefits, tickets, travel, accommodation, food expenses and similar to public agents by Employees or Third Parties, even without the purpose of influencing decisions, cannot have excessive value or being outside socially acceptable parameters.
In addition to following these Rules, the offering of any gift or courtesy must respect the ethical standards of the respective public institution of which the agent in question is a member.

Gifts, trips and meals can represent something of value to the recipient. For this reason, it is important to avoid situations in which they can influence, or appear to influence, public agents in their decisions.

 

  1. Sponsorships and donations

Sponsorships or donations to non-governmental entities, authorized by law, will be permitted as long as they are not used to influence decisions by public agents, nor are they in disagreement with these Rules or any internal regulations of the entity.

Sponsorships or donations of a political nature or to political candidates or parties are not permitted: (I) in the name of any of AD-Digital; or (II) that could be interpreted as a form of undue advantage (as defined in item 1.2) and that are related, directly or indirectly, to AD-Digital.

 

RELATIONSHIPS WITH BUSINESS PARTNERS

  1. Gifts and Courtesies for Private Business Partners

In relationships with private commercial partners, Employees and Third Parties must also always act with ethics and integrity, avoiding any situations that may be or appear to be an act of corruption or that are not in line with the best business practices recognized by the market. In businesses related to AD-Digital, payment and/or receipt of any amounts not expressly provided for in the contract is not permitted, and high-value gifts, trips and meals that are not justifiable and that are not in accordance with the best business practices used in the market.

For the purposes of this Rule, private business partners are companies or private entities or their respective owners, directors, administrators, employees, interns, representatives and third parties, with which Collaborators or Third Parties conduct or intend to conduct business.

 

  1. Gifts and Courtesies Offered by Business Partners

Within the best practices of commercial relationships and professional courtesy, Suppliers and/or Commercial Partners are permitted to offer gifts or courtesies to AD-Digital Members, provided that all the following conditions are respected: (I) the gifts and courtesies do not have excessive value ; (II) are socially acceptable; (III) follow market practices; (IV) there is no expectation, on the part of the offeror, of obtaining, in return, any type of advantage or benefit from AD-Digital; (V) receipt of the gift or courtesy does not have or appear to have an impact on AD-Digital's business decisions; and (VI) that the provisions of these Rules are observed.

 

Suppliers and/or business partners must be aware that any gifts offered to AD-Digital employees, in violation of these Rules, will be returned, and, if return is not possible, receipt must be communicated to the Compliance/ Legal department at AD-Digital, who will decide on its destination, such as donations to charities.

Gifts of symbolic value or given as recognition of a commercial relationship or social excellence, such as trophies, commendations, statues, medals or plaques, may be accepted, without restrictions, by AD-Digital Members.

AD-Digital Employees and Third Parties are prohibited from asking suppliers for gifts, courtesies or any type of advantage for their own benefit, for the benefit of their family members or people related to them, whether personal or professional, in the context of their activities at AD-Digital.

Additionally, AD-Digital Employees and Third Parties cannot accept other personal benefits offered by the Supplier, such as discounts outside the market standard. Discounts on partner products or services can only be accepted when part of an agreement between AD-Digital and the supplier.

 

AD-DIGITAL REPRESENTATION AND INFORMATION – CONFIDENTIALITY

Employees, Suppliers, Commercial Partners and Third Parties are prohibited from expressing themselves or assuming any obligation on behalf of AD-Digital, except with the express authorization of its representative, vested with powers to do so, in the strict authorized terms and based on powers of attorney or contractual instruments that have been formally granted or celebrated with AD-Digital.

Collaborators, Suppliers, Commercial Partners and Third Parties may not use AD-Digital's brand, name or other intellectual properties for any purpose, except with prior written authorization from AD-Digital's legal representatives.

Unless expressly authorized by AD-Digital, Employees, Suppliers, Commercial Partners and Third Parties may not disclose, in whole or in part, confidential information to which they have had access due to a commercial relationship with AD-Digital, without prejudice to the specific provisions of the contract regarding confidentiality and civil and criminal liability for damages caused.

Employees, Suppliers, Commercial Partners and Third Parties have the duty to protect and safeguard all non-public information concerning AD-Digital and its businesses, even after the end of the commercial or institutional relationship. Non-public information, for the purposes of these Rules, means any information that AD-Digital has not revealed or made generally available to the public, which may include, for example, information related to its contracts, creations, launches of new content , programs, formats or channels, important administrative changes, executive and talent compensation, partnerships, mergers and acquisitions, strategic and commercial plans, financial data, prices, commercial proposals and costs of products and services.

Electronic files and printed documents and their copies must be stored in a secure location, and their sharing can only occur in the AD-Digital work environment.

 

THE COLLABORATOR expressly declares to maintain confidentiality, whether written or verbal, or in any other way, of all data, scientific and technical information and all materials obtained with his/her participation, which may include, but not limited to: techniques, drawings, copies, diagrams, models, flowcharts, sketches, photographs, computer programs, processes, projects, as well as any and all products that result from the provision of services The DIGITAL AD and/or the end customer of AD DIGITAL, not being able to reveal, reproduce, use or give knowledge, under any circumstances, to third parties, of data, scientific information or materials obtained with its participation without prior analysis by the CONTRACTING PARTY.

 

DATA PROTECTION

The “Applicable Data Protection Laws” will be applicable to this Integrity Program, which means all laws, rules and regulations that govern the processing of personal data specifically, the LGPD, in addition to the rules and regulations adopted by the competent protection authorities of data.

 

ChatGPT

When it comes to data privacy and confidentiality, we know that any information entered into ChatGPT, if chat history is not disabled, can become part of your training dataset.

Therefore, under the terms of this Integrity Program, we inform you that it is STRICTLY PROHIBITED to insert sensitive information, confidential, proprietary or confidential organizational or personal data into prompts and public LLM tools, as these may be incorporated into responses for users outside the company.

3. COMPLIANCE OFFICER

Dr. Lucilene Almeida da Costa

Attorney

OAB/SP nº 387635

Responsibilities/Autonomy:

  • Prepare and sign the Integrity Program;
  • Train and guide all Employees regarding the corporation's Compliance rules;
  • Support the corporation's senior management in carrying out its activities, mitigating risks that could affect the integrity of the company;
  • Participate in Tenders;
  • All activities related to Government Relations

4. REPORTS

4.1. Phases of a Report/Complaint

4.2. Reporting Channels

Reports can be made anonymously or not, through the following channels:

Jorge Augusto Hassen
President

Daniela Helena Machado e Souza
SVP

Hugo Augusto Nascimento
CTO

Hugo Martins Carvalho
CFO