Code of Ethics and Conduct

INDIKATORE CONSULTING AND SOFTWARE DEVELOPMENT LTDA, CNPJ: 28.683.491/0001-31 Address: R 1822, 330, Room 02 Box 01, Centro, Balneário Camboriú, SC, Brazil, Zip Code: 88.330-484, Contact email: contato@indikatore.com.

1. INTRODUCTION AND PURPOSE
This Code of Ethics and Conduct establishes the fundamental principles and values that guide INDIKATORE CONSULTORIA E DESENVOLVIMENTO DE SOFTWARE LTDA. (“INDIKATORE”, “our company” or “we”), registered with the CNPJ under no. 28.683.491/0001-31.
Ele se aplica a todos os colaboradores, incluindo diretores, administradores, empregados, estagiários e aprendizes, prestadores de serviços, parceiros de negócios, fornecedores e quaisquer terceiros que atuem em nome da INDIKATORE.
Our goal is to foster a culture of integrity, transparency, and accountability, ensuring that all our operations and business relationships comply with laws, regulations, and the highest ethical standards. This Code serves as a guide for decision-making and conduct in all our activities, strengthening INDIKATORE's reputation and the trust of our stakeholders.
2. OUR CORE VALUES
● Assertiveness: We base our communication on accurate data and consistent analysis, ensuring that each piece of information shared is clear, well-founded, and contributes to strategic decisions.
● Helpfulness: We act with proximity and empathy in all interactions, seeking to understand the needs of our customers and partners to offer agile, practical solutions appropriate to each context.
● Innovation: We apply a disruptive and creative approach to problem-solving, using modern methodologies and emerging technologies to generate value, efficiency and differentiation in each project.
● Integrity and Honesty: We act with integrity, honesty, and transparency in all our relationships and transactions, both internal and external. We reject any form of deception, fraud, or bad faith.
● Respect and Dignity: We value diversity and treat all people with respect, courtesy, and dignity, regardless of their origin, race, ethnicity, gender, sexual orientation, religion, age, disability, or any other characteristic. We promote a work environment free from harassment and discrimination.
● Excellence and Quality: We strive for the highest quality in our products, services, and processes. We are committed to continuous improvement, innovation, and delivering solutions that exceed our customers' expectations.
● Responsibility and Commitment: We take responsibility for our actions and their consequences. We fulfill our commitments and honor our contracts, always acting responsibly towards society, the environment, and the communities where we operate.
● Confidentiality and Security: We strictly protect the confidential information of INDIKATORE, our customers and partners, as well as the personal data under our care, in compliance with applicable laws and regulations, such as the LGPD.
3. GENERAL CONDUCT IN THE WORKPLACE
3.1. Professional Behavior: Everyone must maintain professional, ethical and collaborative behavior in the workplace, promoting a climate of mutual respect.
3.2. Harassment and Discrimination-Free Environment: We do not tolerate any form of harassment (moral, sexual, virtual) or discrimination based on race, ethnicity, religion, gender, sexual orientation, social status, etc. Reports will be treated seriously and confidentially.
3.3. Use of Company Resources: INDIKATORE's resources (including equipment, systems, vehicles, and information) must be used responsibly, ethically, and exclusively for work purposes. Personal use is permitted only if it does not interfere with professional activities, does not generate undue costs for the company, and does not violate internal policies.
3.4. Occupational Health and Safety: INDIKATORE is committed to providing a safe and healthy work environment. All employees must follow safety standards and report any unsafe conditions or practices.
3.5. Personal Data Protection: The processing of personal data, whether of customers, employees, partners, or third parties, must strictly follow our Privacy Policy and the General Data Protection Law (LGPD). Data collection, use, storage, and sharing must be done only for legitimate purposes and with the appropriate legal basis.
4. RELATIONSHIP WITH OUR STAKEHOLDERS
4.1. Clients: We are committed to excellence in service and the delivery of innovative, high-quality solutions that meet the needs and exceed their expectations. We maintain transparent, honest, and proactive communication with our clients. We respect the confidentiality of client information and protect their data with the utmost rigor.
4.2. Suppliers and Business Partners: We select suppliers and partners based on objective criteria, such as quality, competitiveness, reputation, and adherence to our ethical and legal standards. Our relationships with suppliers and partners are guided by transparency, mutual respect, and fair competition. We conduct appropriate due diligence to ensure that our partners also comply with anti-corruption laws and ethical principles.
4.3. Competitors: We compete fairly and ethically, respecting competition laws and avoiding anticompetitive practices such as cartels, price fixing, or the exchange of confidential information. We do not denigrate or disseminate false information about our competitors.
4.4. Government and Public Officials: We maintain a transparent and legal relationship with government agencies, always in compliance with applicable laws and regulations. We do not offer, promise, or give, directly or indirectly, any type of bribe, facilitation, or undue advantage to public officials, as detailed in our Anti-Corruption Policy. Interactions must be strictly professional and documented when necessary.
4.5. Community and Environment: We act as responsible corporate citizens, contributing to the social and economic development of the communities where we operate. We strive to minimize our environmental impact by promoting sustainable practices in our operations.
5. CONFLICT OF INTEREST
5.1. Definition: A conflict of interest arises when an employee's personal, financial or third-party interests (such as family and friends) may unduly influence or appear to influence decisions or actions taken on behalf of INDIKATORE.
5.2. Duty to Disclosure: It is the duty of every employee to immediately identify and disclose any situation that constitutes or may constitute a conflict of interest. Disclosure must be made to immediate management or to the Whistleblower/Compliance Channel.
5.3. Conflict Management: INDIKATORE will evaluate each conflict of interest situation and determine the best way to mitigate or resolve it, which may include abstaining from participating in certain decisions, reallocating tasks or other measures.
6. ANTI-CORRUPTION AND BRIBERY
6.1. Zero Tolerance: INDIKATORE adopts a zero tolerance policy against all forms of corruption and bribery, whether active or passive, direct or indirect, in the public or private sector.
6.2. Prohibition of Improper Payments: It is prohibited to offer, promise, give or accept any undue advantage (money, gifts, travel, favors, entertainment, employment opportunities) with the aim of influencing a business decision or obtaining an undue benefit.
6.3. Facilitation Payments: Small facilitation payments (also known as “tips” or “expediting kickbacks”), intended to speed up or secure the execution of a routine action to which one is already entitled, are expressly prohibited by INDIKATORE.
6.4. Gifts and Hospitality: Gifts, presents, and hospitality expenses (meals, events, etc.) must be of reasonable value, not intended to cause undue influence, infrequent, and in compliance with internal policies and applicable law. They must be transparent and properly recorded.
6.5. Accounting Records: All financial transactions must be recorded accurately, completely and transparently in the company's accounting books and records, preventing any form of concealment of undue payments.
7. PROTECTION OF INFORMATION AND INTELLECTUAL PROPERTY
7.1. Confidential Information: All employees and third parties who have access to INDIKATORE's confidential information (such as strategies, financial data, customer information, trade secrets, source codes) must protect it with the utmost rigor and use it only for the purposes for which it was granted.
7.2. Intellectual Property: INDIKATORE's intellectual property (including software, patents, trademarks, copyrights, and designs) is a valuable asset. Unauthorized use, copying, distribution, or modification of any intellectual property of the company or third parties is prohibited.
8. REPORTING CHANNEL AND NON-RETALIATION POLICY
8.1. Duty to Report: All employees and third parties who are aware of or suspect any violation of this Code, laws or internal policies have a duty to report it.
8.2. Reporting Channels: Reports can be made confidentially and securely via email at contato@indikatore.com. Anonymous reports are possible, but we encourage identification to facilitate the investigation.
8.3. Confidentiality and Investigation: All reports will be treated with the utmost confidentiality and investigated impartially, diligently and transparently.
8.4. Non-Retaliation: INDIKATORE ensures that there will be no retaliation of any kind against anyone who, in good faith, reports a suspicion or ethical concern, even if a subsequent investigation does not confirm the violation. Retaliation is a serious violation of this Code and will be severely punished.
9. CONSEQUENCES OF VIOLATION
Violation of any provision of this Code of Ethics and Conduct or related policies may result in severe disciplinary measures, which may include, but are not limited to, warnings, suspensions, termination of the employment or partnership contract, without prejudice to applicable civil, criminal and administrative liabilities, in accordance with Brazilian law.
10. TRAINING AND COMMUNICATION
INDIKATORE will provide periodic training to disseminate the principles of this Code and Compliance policies. Constant communication about ethics and integrity is essential to strengthening our culture.
11. REVIEW AND APPROVAL
This Code of Ethics is valid for an indefinite period and may be updated whenever necessary to ensure its relevance, effectiveness and compliance with changes in laws, regulations and best market practices.
12. FINAL DECLARATION
This Code of Ethics and Conduct represents INDIKATORE's institutional commitment to integrity, transparency, and accountability in all its relationships and operations. It reflects the principles that guide our decisions and behavior and is mandatory for all those acting on the company's behalf.
Upon becoming aware of this Code, each employee, partner or third party declares that they are aware of its content and undertakes to faithfully comply with its guidelines, safeguarding INDIKATORE's reputation and values.
This document comes into force on the date of its publication and will remain in force until a new version is formally approved and published.

Balneário Camboriú/SC, May 1, 2025.

INDIKATORE CONSULTORIA E DESENVOLVIMENTO DE SOFTWARE LTDA