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CODE OF CONDUCT AND ETHICS

PURPOSE AND VALUES

MISSION, apply our business model, achieving excellence with services, products and property protection, while further incentivizing the personal and professional growth of all those involved.

VISION, be a transformative company that fosters market relations with respected and modern ethical values and behaviors and a desired and differentiated brand for our customers and investors.

VALUES, achieve results based on our fundamental values in which we believe and propagate, such as ethics, transparency, sustainability, innovation, acceptance of diversity, social responsibility and human development.

Therefore, based on our values and proposal, we have prepared this Code of Conduct and Ethics in order to guide the relationship between “UNU Hotels & Resort” and its employees, as well as helping everyone ethically, correctly and safely in dealing with everyday corporate situations.

Acting in compliance with this document is the responsibility of each one of us which is why we request you to read it, live it and replicate it.


MESSAGES FROM THE DIRECTION

We have prepared and reviewed this Code of Conduct and Ethics from “UNU Hotels & Resort” to drive our team to reach its objectives ethically, with integrity and transparency. Through it, we have established the criteria, procedures and processes that we believe necessary for the legitimate and legal undertaking of our activities.

We understand that our credibility and respect for the brand/name which we operate owe themselves to the attitudes of all those who make up our team which is why it is our duty to clarify what we value, incentivize and reject within our organization.

The shareholders respect the code’s guidelines, set an example and ensure that their interests will be the service of “UNU Hotels & Resort” first and foremost, resulting in gains for everybody.

Ensuring the smooth running of the business is everybody’s commitment.

We thank you all for your hard work and dedication in understanding, complying with, replicating and ensuring everything that has been set out in this important document.

Francisco José de Almeida Salema
CEO and Partner


LETTER TO THE SERVICE PROVIDERS

“UNU Hotels & Resort” seeks to have relationships that are increasingly more transparent and sustainable with its employees, partners and customers.

Under this premise, we understand that all service providers who carry out services in a recurring manner actively contribute to the company’s organizational environment as well as the perception of both our internal and external customers regarding our brand.

Therefore, we extend the required reading and compliance of all criteria, procedures and processes set out in the Code of Conduct and Ethics to these partners.

SUMMARY

1. Relationship with Shareholders
2. Relationship with Employees

  • 2.1 Personal Interactions
  • 2.2 Social Media and Communication
  • 2.3 Harassment
  • 2.4 Training
  • 2.5 Product Commercialization
  • 2.6 Consumption of Alcohol and Other Drugs
  • 2.7 Human Rights
  • 2.8 Diversity
  • 2.9 Espionage and Competition
  • 2.10 Professional Ethics
  • 2.11 Independence and Impartiality
  • 2.12 Intellectual Property
  • 2.13 Own Resources
  • 2.14 Health and Safety
  • 2.15 Information Security
  • 2.16 Use of the Brand

3. Relationship with the Press


4. Relationship with Customers

5. Relationship with Suppliers

6. Relationship with Competitors


7. Relationship with Governmental Bodies

  • 7.1 Political Contributions


8. Environmental and Social Responsibility

  • 8.1 Combat against the Sexual Exploitation of Children and Adolescents.


9. Conflicts of Interests

  • 9.1 Guidelines
  • 9.2 Parallel Activities
  • 9.3 Free Gifts and Presents
  • 9.4 Events and Entertainment
  • 9.5 Nepotism (Relationship Degree) and Related People


10. Violations of the Code of Conduct and Ethics


11. Conduct and Ethics Committee


12. Communication Channels

 
 
 

1. Relationship with Shareholders

From the board of directors, the shareholders shall demand the creation and fostering of organizational values and a culture that drives the stakeholders to maintain their behaviors and actions guided by ethical and responsible behavior.

They are responsible for setting an example in complying with Code of Conduct and Ethics and ensuring full compliance and practice of it from the other employees, regardless of their qualifications and hierarchical level.

 

 
2. Relationship with Employees

We believe that behavior in the workplace shall be guided by the company’s values. Therefore, it is everybody’s duty to follow the instructions below:

 

2.1 Personal Interactions

Act honestly and fairly, with willingness, attention, courtesy and respect to all people with whom you have relationships on behalf of the company, respecting individual differences.

Maintain behaviors of consideration, collaboration and solidarity, guided by this Code’s principles and values.

Make an effort so that team spirit, loyalty, frankness, trust and consensus prevail among the people.

 

2.2 Social Media and Communication

Do not record meetings, events or conversations without the permission of those present.

Do not offend, defame, slander or negatively mention the name of “UNU Hotels & Resort” or any one of its companies or employees on social media.

Keep virtual work groups for professional purposes only, respecting the guidelines of this Code with regards to published messages and/or posts.

Prioritize using corporate message apps and email.

 

2.3 Harassment

Do not commit or be complicit to sexual or moral harassment, physical, gestural or verbal violence, humiliation, embarrassment, duress or threat.

Ensure a healthy work environment, with no insinuation or restrictions of any nature.

Collaborate in internal or external investigations of complaints related to its matter, not omitting information or documents of which you have knowledge.

It is prohibited to use the power of your role or privileges for your own benefit.

 

2.4 Training

Encourage constant professional development, thus contributing so such behavior is adopted by all.

Obtain certifications and necessary abilities to undertake your duties, mainly employees subject to regulation.

Keep an up-to-date professional record should you be a professional whose undertaken duties are subject to legal inspection bodies and professional councils recognized in Brazil.

2.5 Products Commercialization

It is prohibited for employees to commercialize (offer, purchase or sell) products of any nature on the company grounds, regardless of whether it happens during the working hours or not.

Those employees interested in commercializing products must inform the Human Resources Department for formal registration, assessment and authorization.

 

2.6 Consumption of Alcohol and Other Drugs

The possession or consumption of alcohol and other illegal drugs in the workplace is prohibited, mainly during the working hours, as is being in an altered state due to the use of such substances (only in corporate events will moderate consumption of alcohol be allowed).

Give instructions with regards to the prohibition of the consumption of tobacco and the suchlike in places that are not used for this purpose.

Communicate to the Human Resources Department situations where the use of medication may interfere with and compromise performance and safety in the workplace.

 

2.7 Human Rights

Promote the defense of Human Rights, through preventative, protective, reparative actions and conduct sanctions against situations where these rights are under threat or violation.

Encourage respect for individual and fundamental rights without any kind of distinction regarding the person.

 

2.8 Diversity

Encourage diversity as a basic factor of human development.

Discourage and report any form of discrimination and prejudice exercised in internal or external relationships, whether by color, religion, sexual orientation, political leanings, age, social status or physical and mental restrictions, committing yourself to respecting all guidelines, agreements, conventions and norms regarding the issues in question.

 

2.9 Espionage and Competition

Espionage will not be admitted by “UNU Hotels & Resort”.  We repudiate any practice in this sense, mainly from our partners and employees. Likewise, we do not admit the use of fraudulent and dishonest means to influence customers or competitors who do not hold up to our moral conduct and violate our values, the principals of commercial honest, good customs good faith.

 

2.10 Professional Ethics

Professionals, subject to state-controlled professions, must honor and respect the principles of human conduct and guidelines established for undertaking their activities.

No employee from “UNU Hotels & Resort” will be granted the right to claim lack of knowledge of the norms and guidelines from this Code which will be published and extensively divulged. It shall protect the mentioned interests, ensuring the confidentiality of its operations and the organization’s strategy, curbing the improper flow of information between sensitive areas and people.

 

2.11 Impartiality and Independence

We respect and endorse the duty of impartiality and independence; thus, any influence, pressure or interest will not be tolerated.

In all of our negotiations, we will make every effort to treat people fairly, carefully weighing up our responsibilities with all stakeholders.

Employees cannot engage in discriminatory practices that are against the applicable laws or the principles and policies established by “UNU Hotels & Resort”.

 

2.12 Intellectual Property

Preserve the intellectual property of “UNU Hotels & Resort”, mainly the information considered to be privileged, confidential or secret obtained due to your job, role or work relationships. Do not share it nor use it for your own benefit, or that of your relatives or third-parties, especially that which is known as commercial information.

 

2.13 Own resources

Ensure that the company’s assets are conserved. These include facilities, equipment, furniture, vehicles, values among others.

2.14 Health and Safety

Preserve the health and safety of the whole organization, especially in the workplace.

Find out your department’s escape routes and leave the passageways unobstructed.

Adjust your work post in accordance with the ergonomic techniques.

Avoid leaving the company premises without supervision when there are people visiting.

Inform the Human Resources Department whenever there is an accident, incident or in other situations that put your physical or personal integrity, or that of others, at risk in the work environment. (No type of physical or verbal aggression or threats of violence will be tolerated).

Correctly use the group or individual personal protection equipment.

Carrying, using, storing or transporting a gun on the company’s premises is prohibited.

 

2.15 Information Security

Pay attention to the correct use of computational resources, including but not limited to computers, cellphones, emails, internet access and communication software provided by “UNU Hotels & Resort”.

Ensure that access to information is obtained only by authorized people.

Preserve the original state of the information as it was conceived, with the aim of protecting it against improper, intentional or accidental alterations in its storage or transmission.

Ensure that only authorized users have access to the information and the corresponding assets whenever necessary.

Prevent the production, transmission or sharing of threats, such as: spam, mail bombing, viruses, messages of a defamatory, degrading, shameful, violent etc. nature.

Impede the acquisition, sharing, hosting and transmission of pornography, racist material or any other material that violates the current legislation from the country, moral and good customs and public order.

Be aware that mobile and landline resources, email and internet access records are of corporate use, and “UNU Hotels & Resort” is able to have access to them without any prior warning to the user.

Maintain the reliability of documents, records, accounts and information systems.

2.16 Use of the brand

Promote the correct use of the brand, respecting the marketing and communication guidelines.

The use of the brand will be duly approved by the competent areas and levels and will always aim to protect the company’s interests.

Ensure and safeguard the interests, integrity, brand and image of “UNU Hotels & Resort”, contributing to the strengthening of the organization’s reputation.

Be aware that the intellectual property regarding the company’s brand, logos, website and others developed for its projects belong solely and exclusively to “UNU Hotels & Resort”, as well as the developed software, systems and apps.

Obtain prior authorization from the Compliance Area to hold lectures, conferences, presentations, publications, academic and scientific projects, comments and any other form of external communication through which concepts, plans, results, strategies, name and image of “UNU Hotels & Resort” are exposed.

3. Relationship with the Press

Do not speak out on behalf of the company when you are not authorized to do so.

Use the internet and interact on social media in a distinct manner, differentiating between personal communication and corporate communication, when authorized.

Assess the content before expressing your personal opinion though these means, in such a way to consider these as public spaces and that the message content may impact the company’s reputation, even if the author does not put themselves forward as a representative or spokesperson.


4. Relationship with Customers

Courteous service with clear, precise and transparent information alongside the offer of products and services with a high-standard of quality are the aspects prioritized by the company.

The employees must serve the customers with professionalism and competency, offering suitable, fair and dignified treatment, respecting the customers’ interests and rights.

Preferential treatment to anybody for personal reasons is forbidden.

Provide all requested information in an up-to-date, clear, precise and transparent manner, allowing customers to make better decisions at all times.

Appropriately handle information and come up with suitable solutions to resolve problems that involve customers, valuing transparency and ethics.

Be receptive to customer’s opinions and pass on criticism to those responsible for its analysis with the aim of encouraging improvements in the activities.

 
5. Relationship with Suppliers

The hiring of third-parties shall comply with the stringent principles of fairness and transparency.  

 “UNU Hotels & Resort” reserves the right of substituting and/or cutting relations with all and any supplier who does not comply with environmental, labor or tax legislations as well as with the integrity, work health and safety which go against the company’s interests.

A fair pricing policy must be practiced in accordance with the market and must be compatible with the service quality and efficiency, seeking companies that are a reference in the operating segment and that stringently meet the reglementary norms from the sector, committed to programs of integrity and compliance.

The hiring of service providers will be based on ethical, professional and technical criteria and will have the aim of establishing long lasting relations, the capacity of assessing and full compliance of contractual obligations, thus mitigating the termination of the service provision in an abrupt and unilateral form.


6. Relationship with Competitors

Employees will avoid any collusion, anticompetitive discussions and/or agreements with competitors and will therefore use only fair and honest negotiation and sales methods.

Meanwhile they will avoid any sales practices that may be misunderstood as an attempt to impose undue pressure or to coerce any specific customers to buy a product or services under the condition of closing any possible busines.

 
7. Relationship with Governmental Bodies

For the purpose of this pillar, we will not tolerate any form of corruption. Under this context, employees are prohibited to perform the following conducts:

Promise, offer or give, either directly or indirectly, undue advantage to a public agent or a third person related to them;

Finance, pay for, sponsor or, under no circumstances, practice illegal acts as set out in the anticorruption law;

Use an official legal entity or individual person to hide or disguise the real interests or identity of the beneficiaries of the performed acts;

Hinder any investigation or inspection activities from public agents, entities or bodies, or interfere in their work, including in the scope of regulatory agencies and inspecting bodies;

Moreover, with regards to the participation in bids and signing of administrative contracts, employees are prohibited to:

Disrupt or defraud, through adjustment, combination or any other expedient, the competitive nature of a public bid procedure;

Impede, disrupt or defraud the undertaking of any public bid procedure;

Ward off, or seek to ward off, a bidder through fraud or offering any type of advantage;

Defraud a public bid or any resulting contract;

Create, in a fraudulent or illegal manner, a business entity in order to participate in a public bid or sign any administrative contract;

Gain advantage or undue benefit, in a fraudulent manner, from modifications or extensions of signed contracts entered into with a governmental body, without legal authorization when inviting to tender or in the respective contractual instruments;

Manipulate or defraud the economic-financial contracts entered into with governmental bodies.

7.1 Political Contributions

Employees are expressively prohibited to make political donations in the name of the company unless there has been specific instruction to do so.

Employees who may possibly decide to get involved in political activities must do so in their own name and not as a company representative. It is wholly prohibited to use their membership for any promotional purposes with this intention.

 
8. Environmental and Social Responsibility

“UNU Hotels & Resort” is committed to managing its businesses by fostering people’s well-being and solid economic growth. Bearing this in mind, all employees shall administer the aspects of their work in such a way that ensures environmental laws and recognized and adopted standards are complied with or exceeded.

8.1 Combat against the Sexual Exploitation of Children and Adolescents

With full adherence to the campaign headed by the Ministry of Tourism in the combat against the sexual exploitation of children and adolescents, “UNU Hotels & Resort” shall make every effort and full use of its resources to fight against the notorious practice by putting stringent processes and controls into place as well as constantly training its employees. The results of which will be released to its partners.

 
9. Conflicts of Interests

9.1 Guidelines

Avoid any situation that may result in a real or potential conflict of interest or that may be seen as such.

Employees will fully and fairly disclose any matters which may reasonably harm their independence and objectivity or interfere in their respective duties with their customers, potential customers and employers.

They must also ensure that such disclosures are relevant, presented in simple text and communicated effectively.

Extensively disclose to employers, customers and probable customers situations that involve any remuneration, payment or received or paid benefit to a third-party for the recommendation of products or services.

Decision making during the undertaking of your duties will be done objectively, based only on the best interests of “UNU Hotels & Resort” customers and must not be affected by any consideration of personal gain or gain of anybody else who is personally involved, including friends and family members.

Under no circumstances shall the employee approve products, request services or transact by themselves or for any customer with whom they are personally involved, including friends and family members. These decisions shall be passed on to other approval levels or to Compliance.

Conflicts of interests always occur whenever personal and professional interests go against the principles and values of “UNU Hotels & Resort” and may consequentially result in damage of any nature to the company.

The following are considered to be conflicts of interests:

9.2 Parallel Activities

Parallel activities are those which the employees undertake outside their workday, whether earning remuneration for carrying them out or not. Despite employees being free to do so, it is fundamental that the practice does not impact on their individual work and/or affect the institution’s image. Therefore, employees must abide by the following instructions:

Do not carry out parallel activities during the workday or within the company’s premises;

Do not carry out parallel activities for companies competing with the business of “UNU Hotels & Resort”;

Assess with the Compliance area invites to assume non-profit board roles in other businesses, or in any company, especially if there are any conflicts of interests;

Invites to run courses and/or give lectures, write texts or take part in activities complementary to those of “UNU Hotels & Resort” shall be assessed by the Compliance area.

9.3 Free Gifts and Presents

Receiving free gifts of up to the value of R$300.00 (three hundred reals) is allowed provided that it is of an institutional marketing nature. Receiving presents which involve the expectation of a return, will be subject to a consultation with the Compliance area.

Only previously authorized people can offer gifts on behalf of the company.

9.4 Events and Entertainment

Entertainment invites, including participation in workshops and courses related to company activities, may be accepted by employees from the company but the participation in such will be assessed along with the Compliance area.

Events held by the company will be of an institutional nature, whose intention will be to bring partners and customers together in the quest for an ethical business environment.

Therefore, invites to take part in such events will be extended to partners and people for whom the event matter is relevant. Any offer that is made will have the unique intention of strengthening partnerships without any expectation of retribution and/or compensation.

9.5 Nepotism (Relationship Degree) and Related People

The compensated hiring of direct and indirect employee family members of any degree will be prohibited if it is a direct hierarchical relationship or if they will be working in the same area. All other situations will be assessed by the Compliance area, taking any possible conflicts of interest into consideration.

Affective relationships that occur between employees will be respected. However, with the aim of minimizing any incidents of Conflicts of Interest, such relationships will have to be communicated to the immediate manager and the Compliance area.

Omitting information relevant to any existing connections between employees which may influence in process management decisions and such will not be permitted.

 
10. Violations of the Code of Conduct and Ethics

All employees will inform their immediate supervisor or the Conduct and Ethics Committee regarding any situation considered to be irregular, against ethics, the laws and this Code of Conduct and Ethics.

Any condition that raises doubt over its legitimacy or regularity, based on facts and information, will also be communicated.

No retaliation will be permitted against any member who reported concerns in good faith about non-compliances with the guidelines set out in the Code.

Violations against the Ethics and Code of Conduct will result in penalties in accordance with the gravity of the fact and a verbal and/or written warning, or contract suspension or termination, as well as other applicable legal measures.

Complaints that are unfounded, inconsequential, irresponsible or that are exclusively intended to harm others will also be subject to disciplinary measures.

 
11. Conduct and Ethics Committee

The assessment, investigation of suspect infractions or non-compliance with regards to the Conduct and Ethics Code, as well as the consideration of each case shall be the responsibility of the Conduct and Ethics Committee which will be made up of members chosen by Senior Management.

Exceptions or situations and matters not set out in this document will also be subject to the committee’s analysis and assessment.

 

 
12. Communication Channel

Employees should preferably deal with subjects related to this Code with the Compliance area. Nevertheless, if for any reason, they do not feel at ease to do so, they must report it their immediate direct manager. If there is still possible discomfort or restriction, they can resort to the company’s official Complaints Channel or report through the email: privacidade@unuhotels.com.br.

Any and every complaint or act of non-compliance will be handled with due confidentiality.

How to inform us:

privacidade@unuhotels.com.br or website www.unuhotels.com.br