Code of Ethics, Conduct and Fighting Corruption | Segura®

Commitment to Integrity | Segura®

Integrity is a non-negotiable value in our culture. It guides our actions and decisions and sustains trust in everything we do. We operate in a dynamic environment, constantly striving to exceed expectations while upholding the highest ethical and professional standards.

Expected conduct

•Respect, inclusion, and open dialogue; valuing diversity and individual contributions.
• Recognition of merit, collaboration, and teamwork.
• Compliance with laws, policies, and training; care for company assets.
• Responsible sharing of non-confidential information.
• Learning from mistakes; acting with diligence and integrity.
• Conscious consumption and environmental care.
• Voluntary participation in internal initiatives, without pressure or disclosure of amounts.
• Promptly reporting questions or potential violations to managers or designated channels.

Anti-Corruption

According to Brazil’s Federal Court of Accounts (TCU), corruption is the abuse of entrusted power to obtain private gains—financial, political, or any other undue benefit.

• Principles: zero tolerance for improper advantages; prohibition of facilitation payments; due diligence on third parties; accurate accounting controls and records; periodic training.
• Legal basis: Brazilian Anti-Corruption Law, FCPA (United States), UK Bribery Act, MACC Act — Section 17A (Malaysia), and anti-corruption laws of Saudi Arabia, the UAE, and Egypt.

Harassment

Moral (psychological) harassment

As defined by the TCU, moral harassment consists of abusive, repetitive, and prolonged conduct—through words, behaviors, acts, gestures, or writings—that harms a person’s dignity or physical/psychological integrity, degrades the work environment, or compromises performance.

Sexual harassment

As defined by the Public Labor Prosecution Office (MPT) with the International Labour Organization (ILO), sexual harassment in the workplace is sexual conduct—by words, gestures, physical acts, or other means—proposed or imposed against someone’s will, causing embarrassment and violating their sexual freedom.

Relationships and Professional Conduct

• With employees: respect, transparency, safety, and quality of life at work; compliance with internal policies and zero tolerance for any form of harassment. Monitoring of corporate communications may occur, in line with policy and law, to prevent illicit acts.
• With customers: clear contracts, transparency, and no misleading or high-pressure practices. Focus on value, quality, and experience.
• With suppliers: objective and ethical selection; rejection of human rights violations; legal, labor, environmental, and safety compliance; prevention of conflicts of interest.
• With partners: relationships based on integrity, trust, and a “Partner Centric by Design” approach, with cooperation and agile support throughout the lifecycle.
• With competitors: fair competition; no cartels, industrial espionage, or misuse of information; compliance with antitrust laws.
• With public officials: ethical and lawful conduct; prohibition of undue benefits; prevention of money laundering and overbilling.
• With stakeholders and authorities, handled by Executive Management or a designated representative, with accurate and timely information.

Social Responsibility

Segura® is committed to acting responsibly in the communities where we operate. We expect every employee to foster good relationships, respect others’ interests, and contribute to collective aspirations.

Reporting Channels

We provide a Speak Up Channel on our website. Whenever you identify or suspect conduct that violates our Code of Ethics, laws, or policies (such as harassment, discrimination, fraud, corruption, misuse of data, or security violations), please use the channel.