Assaí Code of Ethics

BEING ASSAÍ GOES LIKE THIS 

Our values

Simplicity. Passion for what we do. Customer focus. Commitment to results. Ethic.

We are constantly evolving, and with each challenge we reaffirm what we are. Our culture is present in everything we do, and that is why we get stronger day by day. We are thus, made of enthusiasm and courage to go further.

We're unique. #WeAreAllAssai

OMBUDSMAN AND COMPLAINTS

Illegal or unethical conduct at work is contrary to this Code. Thus, any suspicious activity must be reported to the Ombudsman's Channel, regardless of the position or the situation of whoever practiced it. ASSAÍ, through its responsible areas, as indicated in the Policy of Consequences and Disciplinary Measures, undertakes to investigate all reported situations, with impartiality and total confidentiality, as well as to adopt the applicable measures and punishments with consistency. ASSAÍ guarantees the anonymity of those who report.

Ombudsman
(Monday to Saturday, from 8am to 8pm) Assaí 0800 7773377 ouvidoria@assai.com.br 

We will not tolerate any type of retaliation against anyone who questions or reports in good faith. We want a work environment where everyone feels comfortable pointing out problems, clarifying doubts and sharing concerns. To this end, in addition to having a channel that guarantees the anonymity of whistleblowers, we will treat all reports confidentially, under the care of a committee of people oriented to ensure confidentiality and act to prevent retaliation and discrimination of any nature. If you have any doubts about the content of this Code, talk to your manager. The People Management, Legal and Compliance areas can also help you.

For more details, access the Corporate Standard - Contact and Investigation by the Ombudsman, available on the Intranet*

ETHICS COMMITTEE

At ASSAÍ, we have the Ethics Committee responsible for the management of this Code, which must ensure that it is known to all employees and audiences who relate to us, as well as ensuring its effectiveness and its efficacy.

SIMPLICITY

Valuing our origin. We are simple, and we are proud of it. Always looking for an objective, clear, practical and effective way of working. Being considerate and respectful to everyone. Knowing how to listen, empathize and collaborate, in whatever position is occupied. We are all Assaí!

IMAGE AND REPUTATION

Both the image and reputation of ASSAÍ are important attributes before our customers and society. We must ensure respect for the name and the good use of our brand. We protect our intellectual property and make sure that our brand, domain and industrial designs are properly registered to prevent misuse by third parties. We do not allow employees and business partners to make use of or advertise the corporate name, registered or registered brands, logos or any other distinctive signs of ASSAÍ without the express authorization of our responsible areas.

For more details, access the Corporate Standard - Information Security Incident Management available on the Intranet*

We must maintain the confidentiality of information to protect our reputation.

INFORMATION SECURITY

We must keep in mind that the security of information of our ASSAÍ is essential for the smooth running of our business and to avoid fraud, crimes, damage to the image and liability for the use of information in an improper and unethical way. We must use the company's tools and resources, such as e-mails, computers, internet access and cell phones, in a responsible and careful manner. We protect ASSAÍ internal information. We treat our knowledge, trade secrets, business strategies and any financial or price information about our business with care and confidentiality, to ensure that they are not used to our detriment.

We are committed to the confidentiality of the personal information of our employees, customers and business partners, and we do not use or disclose your data without express authorization. Use our tools responsibly. Do not access inappropriate sites.

INSIDE INFORMATION

We do not allow employees to disclose ASSAÍ confidential information to third parties, nor to use it to obtain their own advantage or that of third parties in an improper manner. The use of privileged information from ASSAÍ to obtain undue financial advantages in trading on the stock market or other means is considered an illegal practice, and those involved may suffer sanctions provided for the internal rules of ASSAÍ, as well as criminal measures. and/or administrative measures applied by the competent regulatory agencies.

For more details, access Assaí’s Trading Policy for Securities Issued available on the Intranet *

Do not talk about work topics in public places. Avoid information leakage. 

CUSTOMER FOCUS

Being clear about who we are, what we offer and who our customers are. Considering the customer in each decision making. Having a sense of urgency to solve problems that impact the customer. Ensuring a service with respect, friendliness, agility and efficiency.

CUSTOMER RELATIONS

We treat our customers with respect. We fight any type of violence and do not tolerate any form of discrimination based on age, gender, sexual orientation, race, color, disability, religion, marital status, nationality and/or gender expression. We are always ready to foresee their needs, understand them and attend to their interests, requests, complaints and suggestions, either in person or via customer service channels.

We must offer quality products and services, in the best time and in the best possible way, reflecting the responsibility that characterizes our performance in the wholesale sector. We only provide true information, with agility and transparency, to establish a relationship of trust with our customers. We act ethically in our business: we do not tolerate undue favoritism to one customer over another. 

Each of our employees must be committed to the consumer's rights and follow all laws applicable to their activities. We do not allow the use of our customers' information for any purpose without their consent.

PASSION FOR WHAT WE DO

Enjoying what we do and enjoying serving. Seeking emotional balance in all our attitudes. Being committed and motivated to deliver better. Being a protagonist and making a difference.

USE OF GOODS AND RESOURCES

To develop our activities, we have access to financial resources, tools and equipment that are owned by ASSAÍ. We are responsible for the protection and conscious use of such goods and resources, which must be used properly and always for the exclusive benefit of ASSAÍ.

Manager, you are responsible for validating your budget and managing your expenses. Make sure the cost is reasonable, is directly related to the interests of ASSAÍ and has supporting documentation. All expenses must follow the internal rules, with the approval of the competent authorities and the due payment processes.

For more details, access the Corporate Standard – Acceptable use of technological resources and the Advance and Reimbursement of Expenses Standard available on the Intranet*

RELATIONSHIP WITH SUPPLIERS, SERVICE PROVIDERS AND COMMERCIAL PARTNERS

All transactions and all business must be geared towards the objectives and values of ASSAÌ. We are committed to implementing fair, impartial and transparent negotiations and practices in business relationships with our suppliers and partners. We demand that the choice of partners is made to guarantee the best interest of our ASSAÍ, based on objective criteria and not allowing favors of any kind.

We reject slave or informal labor, child exploitation and inhuman and degrading working conditions in our organization and in all links of our chain.

All of our suppliers, service providers and business partners must comply with laws and regulations, know our values and respect the ethical principles of this Code. We expect responsibility from our partners in handling the confidential information to which they have access during our business relationship.

For more details, access the Corporate Standard - Indirect Purchasing Authorization Limit and Corporate Standard - Management of Purchase Contracts for Products and Services for internal use available on the Intranet*

We must always be impartial and transparent in the choice of our business partners.

We are attentive to the socio-environmental challenges of our supply chains and seek to contribute to mitigate their impacts.

RELATIONSHIP WITH COMPETITORS

We respect our competitors and are committed to promoting fair and just competition, in accordance with the Competition Law. We do not admit abuse of a dominant position or arbitrary commercial practices, such as agreements to determine or control prices, establish operating territories, among others.

All information that ASSAÍ, through its leaders and collaborators, wishes to obtain from its competitors must be acquired by lawful, honest, ethical means, in accordance with the applicable legislation

ENVIRONMENTAL RESPONSIBILITY

ASSAÍ is concerned with the environmental impacts arising from its operations. We are committed to the responsible and conscious use of natural resources and their management, aiming to reduce the environmental impact caused by our activities.

We work and guide our daily behavior in order to adopt best practices for protecting the environment and respecting environmental legislation. We encourage efficiency in water consumption and proper waste management and measures to avoid waste of food and materials. We also incentive conscious consumption from our customers through products and services that respect the environment. 

DONATIONS, CONTRIBUTIONS AND SPONSORSHIPS

ASSAÍ offers donations or sponsorships in a transparent and responsible manner, which must be recorded in the accounting books of ASSAÍ and the beneficiary entities, and can be analyzed and audited at any time by the Responsible Department and the Internal Audit of ASSAÍ.

It is forbidden to offer any donation or sponsorship in exchange for favoring or undue advantage, with the intention of bribing or obtaining preferential treatment, which may generate a conflict of interest, seeking to influence the decision of a Public Agent, or which, in any way, violate the provisions of Law No. 12,846/13 (“Clean Company Law”) or, specifically, violate the rules set out in this Code and the Anti-Corruption Policy of ASSAÍ. It is also not acceptable to donate and/or sponsor specific individuals (individuals). Only to beneficiary entities shall be favoured, unless provided for in the regulation of campaigns approved by the Executive Board or if approved by the Ethics Committee.

For more details, access the Corporate Standard - Donations, contributions and sponsorships available on the Intranet*

Donations to political parties and candidates are prohibited!

COMMITMENT TO RESULT

Being productive and agile to solve problems, seeking solutions and achieving goals. Having an owner's attitude, critical vision and being able to always perform collaboratively. Together we are stronger! Optimizing expenses by ensuring the low-cost model that allows you to offer the best price. Being open to change and oriented towards innovation.

RELATIONSHIP WITH SHAREHOLDERS AND INVESTORS

We value and take care of the investments of our shareholders, in order to generate growth and financial return, with maximization of the value of our companies. We practice the principle of transparency and adopt the best Corporate Governance practices. We are committed to the accuracy and integrity of the information disclosed in our Financial, Social and Environmental Statements, meeting the interests of our investors and other audiences.

Attention: Commercial relations between shareholders and the company Assaí are permitted, whether as an individual or through other companies, as long as they follow the Policy on Transactions with Related Parties, with exemption, transparency, ethics, competitiveness and no conflicts of interests.

For more details, access Assaí Policy for Disclosure and Use of Relevant Information and Secrecy Preservation and the Policy for Transactions with Related Parties available on the Intranet*

RELATIONSHIP WITH THE PRESS AND SOCIAL MEDIA

Our relationship is based on trust and credibility with our customers, investors, employees and business partners. Therefore, we take care of our relationship with the press and social media so that our institutional information is treated and disclosed in an impartial and appropriate manner, without any space for undue favoring, and only by the spokespersons designated by ASSAÍ.

We recognize the importance of social media in communication and defend freedom of speech. The disclosure of public information on ASSAÍ's activities must always be done with discernment and responsibility from the employees.

For the correct evaluation, the Corporate Communication area - which comprises Press Relations, External Communication and Corporate Marketing - must be involved in all ASSAÍ external communication processes, ensuring the alignment and sharing of communication guidelines. This includes interviews, official announcements, data sharing or any ASSAÍ materials, and participation in lectures and events as a representative of the Company.

For more details, access the Corporate Standard - Conduct on Social Networks and the Corporate Standard - Corporate Communication available on the Intranet*

CARE FOR OUR PEOPLE

Valuing Our People, recognizing good contributions and achievements. Respecting and valuing diversity and offering equal opportunities to all. Ensuring a safe and welcoming environment that provides balance and engages people. Offering opportunities for growth and development to Our People.

RESPONSIBILITY OF OUR LEADERS AND EMPLOYEES

Each of us is responsible for incorporating the values of ASSAÍ in our daily lives and in our decisions. Our leaders must lead by example, knowing how to listen and observing opinions, discussions and different ideas which may represent a new way of learning and improving our processes.

We respect our employees. We encourage interaction and cooperation between areas and employees, in order to disseminate knowledge and best practices, raising our standards of quality and productivity.

COMMITMENT TO THE PROMOTION OF DIVERSITY AND INCLUSION

We value our people and offer opportunities to all those who want to engage their talent. We promote inclusion and value diversity and respect for people and their beliefs. We promote, on a daily basis, the best shopping experience to our customers, long-lasting and virtuous relationships with our partners, customers and suppliers, in addition to positive impacts in communities and every audience with which we relate.

To us, the representativeness and development of our employees are priorities. We understand that diversity is a value and a lever for performance and socioeconomic innovation, in addition to being essential in a business that has the customer as its focus.

We want to guarantee a work environment which respects differences, aiming at the well-being and personal fulfillment of each employee. We reject any form of discrimination for any reason. We guarantee access to employment and professional development in the different work teams, based exclusively on the competence of each one through clear evaluation criteria and promoting equal opportunities, in addition to facilitating access to individual training.

For more details, access the Diversity and Human Rights Policy available on the Intranet*

ASSAÍ does not tolerate any type of discrimination, violence or harassment. If you experience something or know of such an attitude, please report it.

Here at ASSAÍ, we cherish the inclusion and development of people with disabilities, gender and racial equity, age diversity and respect for LGBTQIA+ rights.

SOCIAL ORGANIZATIONS AND MOVEMENTS

We promote a quality dialogue with the unions and employee representation groups of the company, endeavoring to ensure that this practice develops in a constructive manner, considering the mutual respect and common interest of the company and its employees. We respect the regulations in force and provide reliable information in a timely manner to representatives of employees and union bodies.

We do not belong to political groups or organizations, but we recognize their legitimacy. We respect the freedom of choice of our collaborators to join parties, unions and social movements, as long as they do not use the image or speak on behalf of ASSAÍ.

CONFLICTS OF INTEREST

We expect our employees to act with ethics and integrity, respecting the laws and internal regulations, and always in the best interest of our company and our customers. We trust that our employees act with loyalty to our ASSAÍ and do not harm our business for the benefit of their personal interests, acting with transparency and loyalty in the face of conflicts of interest.

Make sure to always talk to your manager in these situations: Personal investments and other jobs that might be in conflict with ASSAÍ's interests or hinder your activities as an ASSAÍ employee; Kinship or friendship relationships that may result in undue favor.

For more details, access the Corporate Standard - Conflict of interests available on the Intranet*

Never break laws and internal rules to achieve goals. You damage your reputation and that of our company.

HEALTH, SAFETY AND WORK ENVIRONMENT

We want a safe and healthy work environment. We follow the rules and procedures related to health and safety at work, obey technical training specific to our role, use our own equipment and avoid risky situations.

We encourage leaders and their teams to take inclusive actions and do not accept inappropriate behavior in the workplace, which must be censored and reported immediately to the Ombudsman Channels. Pay special attention to:

● Abuses of power and harassment;

● Any type of discrimination based on age, gender, sexual orientation, race, color, disability, religion, marital status, nationality and / or gender expression;

● Hostility or jokes about the conditions of others, as well as lies or defamation of colleagues;

● Possession of any type of weapon;

● Smoking in a prohibited place, as well as the use of alcohol, drugs or illegal substances;

● Gambling-related activities.

For more information, access the Corporate Standard – Safety and health at work available on the Intranet*

ETHICS

Respect and comply with the law, policies, standards and codes of conduct. Be honest, ethical and transparent in what you do. Act impartially aiming at the best for the sustainability of the business. Fulfill what was agreed, honoring all the commitments assumed in favor of the company.

COMPLIANCE WITH LAW, REGULATIONS AND INTERNAL STANDARDS

We respect all laws, principles, rules and regulations, national and international, applicable to our businesses, following the highest standard of business ethics.

We ensure that our rules and procedures are known and respected by all. In case of doubts, we must consult the internal rules or the departments and responsible areas to ensure an adequate performance.

Our leaders must always set an example of ethical and honest behavior, maintaining effective controls to prevent fraud and ensure compliance with the law and our standards.

ANTI-CORRUPTION AND MONEY LAUNDERING FRAUD PREVENTION

ASSAÍ does not allow, does not tolerate and will punish all possible forms and situations of corruption, fraud or bribery, whether by offering or demanding, or by receiving things of value, involving or not public officials. Stakeholders, including suppliers and service providers, must fully understand and comply with the Brazilian Anti-Corruption Law (Law 12.846 / 13), the United States Foreign Corrupt Practices Act - FCPA and the French Anti-Corruption Law Sapin II, as well as ASSAÍ's rules, policies and internal procedures. ASSAÍ, in turn, is committed to updating, disseminating and offering training to such audiences.

ASSAÍ will not provide financial support or any assistance to any individual involved in criminal activities. It will also not provide any assistance in procedures in which individuals or legal entities seek to hide the resources of criminal activities or make them appear lawful, in compliance with the Law on Money Laundering Crimes (Law No. 9.613 / 98).

For more details, access the Corporate Policy - Anti-Corruption available on the Intranet*

We believe that acting preventively, with the help of everyone, is the best way to become efficient in combating irregular practices.

INTERNAL CONTROLS AND ADEQUACY OF ACCOUNTING RECORDS

We act transparently and honestly in relation to our records and controls, which accurately reflect all financial and commercial transactions carried out, ensuring that these will be promptly transcribed in ASSAÍ books and records. We guarantee the integrity of such operations, and do not, under any circumstances, admit that they are carried out for fraudulent purposes or to cover up misappropriation of the assets of the Company.

The veracity and precision of the accounting and financial information of our ASSAÍ are the responsibility of all the employees involved, who must ensure its quality and maintain appropriate reports and supporting documentation. We fully cooperate with our external and internal auditors, and we do not tolerate the omission or falsification of our records to achieve goals and results.

GIFTS, PRESENTS, TRAVEL AND ENTERTAINMENT

We must not offer or accept gifts, presents and invitations that aim to influence or reward business decisions, exchange of favors or undue advantages. Corporate gifts are acceptable up to a certain amount and frequency, which must be reported to the manager. Gifts and hospitality above these limits - such as invitations to meals, trips and events - received at a business or home address must also be communicated to the manager.

Avoid accepting products or gifts from suppliers. This creates a conflict of interest.

For more details, access the Corporate Standard - Gifts, presents, travel and entertainment available on the Intranet*

RELATIONSHIP WITH PUBLIC POWER

We interact with the government in an ethical and transparent manner. We understand that it is illegal to pay or offer anything, directly or indirectly, in cash or anything of value, to Public Agents, in order to influence their activities or obtain undue advantages for personal benefit or for ASSAÍ.

We collaborate with inspections and investigations conducted by the Government. We actively participate in Class Associations and recognize their importance and legitimacy for our business. We understand that Class Associations must represent our interests and we trust that their interactions with the Government are always strictly within the law.

For more details, access the Tax Inspection Service Policy and the Procedure  for Relationships and Agreements with the Government available on the Intranet*

ABOUT THIS CODE

This Code, including its attached Policy of Consequence and Disciplinary Measures, which is an integral part of it, is not intended to encompass all the issues and possibilities mentioned therein, and should be used as a complement and reference to the rules, policies and internal procedures of ASSAÍ.

To learn more about our Code of Ethics, our rules and our internal procedures, consult the Intranet or access the Institutional Site.

References to ASSAÍ include all of its branches and subsidiaries. All employee references include executive officers, directors, officers and employees of ASSAÍ and its affiliates and subsidiaries.

Those who practice acts that violate the ASSAÍ Code of Ethics or its essence will be subject to the applicable legal and administrative sanctions, as provided in civil, criminal and labor laws.

Pursuant to the Policy of Consequences and Disciplinary Measures, the sanctions applicable due to the violation of the precepts set out in the ASSAÍ Code of Ethics by its employees will be measured on a case-by-case basis, taking into account: (i) the nature and seriousness of the breach; (ii) the offender's history, as well as his or her responsibilities; (iii) attenuating or aggravating circumstances of the infraction committed; (iv) the means used and the aims pursued; (v) the risks involved; and (vi) the possible consequences of the sanction. The applicable sanctions may include warning, suspension and even termination of employees involved by fair dismissal.

In the case of violations by suppliers of goods and service providers, the penalty may be a warning, suspension and even punitive breach of contract.

This Code does not create a working relationship or any contractual right between ASSAÍ and its employees and/or third parties and commercial partners. Nor is this document a guarantee of specific treatment in certain situations.

The guidelines presented in this Code will be applied on a case-by-case basis. Exceptions must be considered by the ASSAÍ Ethics Committee. Assaí provides periodic and mandatory training to all its employees on the Code of Ethics.

* The Intranet is the Internal Communication channel which, in addition to other content and features, gathers all the policies and normative procedures of Assaí for consultation and is available for access exclusively through the internal network of the company.