Advertising and Marketing Commercial Actions

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CONTENTS

1. PURPOSE

2. GUIDELINES

2.1 General Guidelines 2

2.2. Relationship with and Respect to the Consumer

2.3. Impartiality of Communication

2.4. Diversity and Inclusion

2.5. Conscious Consumption

2.6. Specific Guidelines

3. REFERENCES

4. DEFINITIONS

 

1. PURPOSE

The purpose of this document is to present the general and specific guidelines for conducting the commercial advertising and marketing actions of the Company with the goal of ensuring compliance with the applicable regulations and good practices in marketing, sales, and advertising activities, ensuring that the communication of products and services is done in a responsible, ethical, and transparent manner, respecting all precepts of sustainability, diversity & inclusion, human rights, and consumer rights, in line with the guidelines of all other Policies of Assaí.

2. GUIDELINES

2.1. General Guidelines

2.1.1. Marketing actions are part of our strategy for relationship and engagement with our stakeholders. We seek to satisfy the needs of our stakeholders through quality products and services that meet the advertised features and expectations in a transparent, respectful, consistent, and coherent manner. Such actions must communicate offers and/or messages clearly and ensure compliance with what is agreed upon.

2.1.2. Based on such actions, we seek to raise awareness and engage our stakeholders through our communication channels, fostering more sustainable practices and attitudes with less environmental and social impact and ensuring the representativeness of Our People and of our customers.

2.1.3. This Policy shall comply with all Corporate Policies, Procedures, and Regulations of Assaí. Likewise, it shall ensure full compliance with the laws in force on the distribution of advertising materials, promotional actions, and visual communication of all products and services, complying with the specifications and standards defined by regulators in the Country (at the federal, state, and municipal levels) in order to ensure that, if a violation occurs, it is immediately corrected.

2.2. Relationship with and Respect to the Consumer

2.2.1. Any and all marketing actions, campaigns, and/or advertising published in the media and/or in any sales channel, including the internet, social networks, television media, sales platforms, and/or physical outlets, shall be respectful, clear, objective, accessible, and transparent, ensuring the diversity and representativeness existing in society and among customers and employees, as well as in line with the Consumer Protection Code, with the Code of Ethics of Assaí, and with the Policy on Diversity and Human Rights, among others rules that address the topic, particularly those mentioned in the references contained in chapter 6 – “References.”

2.2.2. Our marketing, promotion, and sales practices are regularly assessed by specialized personnel from Assaí, always seeking to improve our practices and policies. Assaí is responsible for establishing mechanisms that ensure compliance with the law and with internal policies on the sale of products and services, as well as on product labeling and consumer information, seeking to constantly encourage conscious consumption, sustainability, health, and well-being in our brands and businesses.

2.2.3. Regardless of the means in which communications are disseminated/broadcast, we provide relationship and customer service channels (Customer Area), as well as a channel for all stakeholders to report situations of violations of our policies and of our Code of Ethics (Ombudsman).

2.2.4. We are committed to the confidentiality of the personal information of our customers, employees, and other audiences, subject to the terms and conditions of our Privacy Policy.

2.3. Impartiality of Communication

2.3.1. Any and all commercial or institutional communications shall be impartial and free from stereotypes, discriminatory content, prejudice, hate speech, or favoritism and shall necessarily ensure that the values and principles of Assaí are observed and complied with. No disrespectful, prejudiced, or discriminatory forms are tolerated or accepted. Communications are committed to being inclusive and representative and ensuring respect for all people, in accordance with our Code of Ethics, with the values of the Ser Assaí é Assim Culture, and with our Policies on “Diversity and Human Rights” and “Relationship with the Community and Stakeholders.”

2.4. Diversity and Inclusion

2.4.1. In order to ensure that everyone is respected in communication and advertising actions and in other promotional materials for Assaí products and for its Exclusive Brands, all those involved in communication actions (both internal and external) are responsible for ensuring the production, validation, and dissemination of content free of discrimination, unconscious biases, or stereotypes and that comply with the principles of accessibility, representativeness, clear language without barriers, and sustainable consumption.

2.4.2. Find out more by reading our Policy on Diversity and Human Rights, our Inclusive Guides on Race, Gender, Generations, LGBTQIA+, and People with Disabilities, and our Antiracism Handbook.

2.5. Conscious Consumption

2.5.1. The promotion of conscious supply and consumption is one of the pillars of the actions and a commitment of Assaí in the value chain. As a link between thousands of suppliers and millions of customers, we are aware of our responsibility to co-build, together with our chain, more sustainable products and services and encourage our consumers to choose such products.

2.5.2. Communication is essential in this pillar to inform and sensitize consumers about conscious consumption, a concept that, according to Instituto Akatu1, can be defined as follows: “Consumption with better impact, without excesses or waste, and based on choices that contribute to the sustainability of the planet so that there is enough for everyone forever.”

2.6. Specific Guidelines

2.6.1. ​Internal Engagement & Awareness

2.6.1.1. We understand that the implementation of and adherence to this Policy depends on the engagement of internal teams from leadership to operational areas. Thus, the employees of the Company involved in the Communication and Marketing process are frequently trained and refreshed in unconscious biases, combating discrimination, diversity, inclusion, human rights, racial literacy, respect for consumers, inclusive communication, combating stereotypes, and other best practices relating to the promotion, sales, and communication of our products and services from the perspective of sustainable consumption.

2.6.2. ​Relationship with Suppliers

2.6.2.1. All suppliers are required to follow the laws and regulations, know the values and respect the ethical principles established in our Code of Ethics, and establish business relationships in an integral and exemplary manner, in accordance with the standards established in the Supplier Ethics Letter.

2.6.3. ​Contracting of Suppliers

2.6.3.1. The contracting of communication vehicles, event and/or advertising agencies, and promotional actions, among others, shall always be based on technical, legal, and ethical conduct criteria that attest to the capacity for the action and adherence to the Supplier Ethics Letter.

2.6.3.2. All service providers are subject to the obligations set forth in the diversity and human rights clause contained in our contractual drafts.

​2.6.4. Provision of Communication and Marketing Materials

2.6.4.1. The Marketing Department is responsible for the brand, product, and service communication strategy of Assaí. When necessary and in line with the communication proposal, advertising materials and institutional campaigns shall be made available in all stores and/or other vehicles and media. For such purpose, it is necessary to prepare and provide directional guides for all teams involved, which contain the quantity to be disclosed and guidelines on arrangement, time, spaces, and other points regarded as important to ensure the best operationalization and communication to the consumer.

2.6.4.2. The production of any material by any area, store, or team without proper formal consent from the Marketing teams is prohibited. Likewise, the use or mention of the Assaí brand(s) and/or of any product on electronic, printed, or internet ads without authorization from such department is prohibited.

​2.6.5. Promotions

2.6.5.1. Any and all commercial promotions shall have its own regulations, with clear and transparent rules on the scope, duration, impacted audience, participation methods, and prize redemption methods (if applicable), emphasizing clear and objective communication with participants.

2.6.6. ​Monitoring and Validation

2.6.6.1. In order to ensure that marketing and sales practices comply with the requirements established the Consumer Protection Code, as well as with other rules on such practices, Assaí relies on its legal area, which is responsible for validating and assessing any and all communications and/or materials relating to marketing and sales practices to consumers, as well as to laws and rules on products.

2.6.7. ​Exclusive Brands

2.6.7.1. This Policy also covers any and all communications involving our Exclusive Brands, which are developed with strict quality control and following market trends and needs.

2.6.7.2. As a marketing strategy, we seek to adopt a line of communication that contemplates entrepreneurship, engaging our customers, consumers, and other stakeholders in the adoption of increasingly conscious habits and promoting access to quality products at an affordable price.

2.6.7.3. Assaí has an internal assessment process at the legal department of the Company, which is responsible for ensuring compliance with the laws on consumer information, as well as on marketing and sales practices.

​2.6.8. Products (Labeling)

2.6.8.1. For our Exclusive Brands, the content of labels complies with the laws in force and with the rules that govern each type of product, with instructions for use, information on handling and conservation, description of substances that can generate social and environmental impacts, and information relating to the health and safety of consumers.

​2.6.9. Restricted Products

2.6.9.1. We are committed to compliance with all laws and guidelines on the sale, communication, and dissemination of restricted products, such as alcoholic beverages and cigarettes.

​2.6.10 Whistleblowing Channel

2.6.10.1. Failure to comply with the rules and guidelines established herein may be regarded as a severe fault and may be subject to the application of sanctions based on all Policies and on the Code of Ethics of Assaí.

2.6.10.2. As an official tool for receiving complaints, grievances, and reports of violations of and non-compliance with this Policy, Assaí provides the Ombudsman channel to all its stakeholders, the purpose of which is to investigate and properly address all incidents, ensuring adherence to and coherence with the ethical, institutional, and universal values of the relationship of Assaí with its audiences.

2.6.10.3. Violations of this Policy, of the Code of Ethics of the Company, or of any item in the Supplier Ethics Letter can be reported through the channel at assai.com.br/ouvidoria. Each complaint shall be investigated confidentially and, as the case may be, anonymously.

​2.6.10.4. Contact:

  • Website: assai.com.br/ouvidoria

  • Telephone: 0800 777 3377

  • Email: ouvidoria@assai.com.br

  • Opening hours: Monday to Saturday, from 8:00 A.M. to 8:00 P.M.

2.6.11. Policy Updating

2.6.11.1. This Policy is valid for an indefinite term, without prejudice to the provisions contained therein.

2.6.11.2. Assaí reserves the right to revise it as often as it sees fit.

3. REFERENCES

3.1. The following are an integral part of this Policy:

3.1.1. Code of Ethics;

3.1.2. Inclusive Guide on Race;

3.1.3. Inclusive Guide on Gender;

3.1.4. Inclusive Guide on Generations;

3.1.5. Inclusive Guide on LGBTQIA+;

3.1.6. Inclusive Guide on People with Disabilities;

3.1.7. Antiracism Handbook;

3.1.8. Information Categorization Policy;

3.1.9. Corporate Communication Policy;

3.1.10. Privacy Policy;

3.1.11. Policy on Diversity and Human Rights;

3.1.12. Policy on Relationship with the Community and Stakeholders; and

3.1.13. External documents:

3.1.13.1 Consumer Protection Code (Law 8.078/1990);

3.1.13.2 National Council for the Rights of Children and Adolescents (CONANDA) Resolution No. 163/2014;

3.1.13.3 National Advertising Self-Regulation Council (CONAR) Self-Regulation Code;

3.1.13.4 Law 9.294/1996 (Restrictions on the use and advertising of tobacco products, alcoholic beverages, medicines, therapies, and pesticides); and

3.1.13.5 Uncodified laws issued by the Brazilian Health Regulatory Agency (ANVISA) and by other regulators.

4. DEFINITIONS

4.1. Communication: Means a process that involves exchange of information between two or more interlocutors through mutually understandable semiotic signs and rules.

4.2. Diversity: Means the set of cultural, biological, personal, social, economic, and other characteristics that make each individual a unique being. In the business context, it is related to the representativeness of different groups that make up society, our customers, and our employees, taking into account gender, sexual orientation, gender identity, races, people with disabilities, generations, and beliefs, among others.

4.3. Exclusive Brands: Means the product brands that are part of Assaí, i.e. Econobom and Chef. Exclusive Brands are developed with strict quality control and following market trends and needs.

4.4. Marketing: Means a set of strategies and actions for the promotion, dissemination, and sales of our products and services aimed at strengthening our brands, captivating new customers, and retaining customers that already buy our products and services.

4.5. Interested Parties or Stakeholders: Also known as strategic audiences, means all relevant audiences with interests that are of concern to Assaí, or individuals or entities that directly or indirectly assume any type of risk in the face of society. The following are included: shareholders, employees, the community, customers, suppliers, governmental authorities, and non-governmental organizations.

4.6. Commercial promotion: Means non-routine actions with a specific purpose. It is the offer of value experiences and actions that provide the strengthening of our brands, such as promotional coupons, special promotions, and gifts, among others.

4.7. Advertising: Means a marketing strategy that involves buying space in a media vehicle to promote a product, service, or brand for the purpose of reaching our target audience and encouraging them to buy our products and services. It may be described as “commercial advertisement.”