Code of Ethical Conduct

Introduction

The Code of Ethical Conduct of Approach Comunicação Integrada Ltda sets out the rules that govern the agency’s commitment to act ethically, transparently, in compliance with the law and Human Rights, in a responsible and fair manner.

These are the company’s principles for meeting internal and external rules and standards for dignified conduct toward its employees and stakeholders — the press, clients and the community.

It is addressed directly to Approach partners, employees, interns, suppliers and service providers, and indirectly to clients, the community and the press, so that everyone knows Approach’s view of corporate ethics, client and press relations, competitive processes and public tenders, and conflicts of interest involving information or conduct. This is a guide on how to act at the agency or on its behalf with integrity and responsibility.

Corporate ethics

Partners, managers, account teams and interns at Approach Comunicação work to ensure a professional stance that preserves the image, reputation and credibility of the agency and its clients.

Using any information of any kind belonging to the company, its clients or suppliers for personal benefit is prohibited. Client information will only be disclosed after formal approval. Confidentiality of client data and information will be maintained until the client authorizes disclosure.

Professionals are responsible for safeguarding Approach’s physical and intellectual assets.

Acts of corruption are not tolerated. We consider an act of corruption to be the offering or promise of an undue advantage to a public or private agent, directly or indirectly, to obtain or award business or to cause that agent to perform, omit or delay an official act, for one’s own benefit or that of third parties, directly or indirectly.

Approach partners or employees, in any role or position, may not accept or offer an undue advantage in relation to clients, service providers or suppliers. An undue advantage consists of accepting or offering items of value — symbolic, branded or economic — in exchange for benefits of any kind. Such items of value include cash payments, gifts, favors, travel, entertainment, job offers, contracts of any duration, or similar.

Accounting or document fraud by our partners or employees in the company’s name is not tolerated.

Any form of favoritism in the workplace is not tolerated.

Relations between employees and the company are guided by ethics, respect, cordiality and solidarity.

We strive to offer a dignified, comfortable and suitable workplace for our employees, both in physical structure and organizational climate.

We expect our employees to take a professional, proactive, responsible and fair stance. We do not confuse informality with permissiveness.

We prioritize delivering communications services and products at the highest quality. We are guided by excellence in service, and by clarity and objectivity in relationships.

We value diversity in the workplace and do not tolerate any discriminatory practice of any kind — race, gender, identity, religion, culture, politics, ethnicity, class or social condition — and we do not allow any practice of moral or sexual harassment.

We condemn practices of any kind that harm organizational and personal health, whoever causes them, such as sexual and moral harassment, physical, gestural or verbal violence, intimidation, humiliation, disqualification, embarrassment, coercion, threat, omission and other forms of abuse.

Approach Comunicação does not use illegal, informal, child or slave labor.

We work within the laws and standards that govern our city, state and country, as well as the rules of international organizations.

Client relationships

Approach always works for client satisfaction, offering quality, reliable services at a fair price and honoring established agreements.

The relationship of Approach partners and employees with any employee or representative of our clients must be respectful and ethical, aiming for the best results for both parties during the provision of our services.

We respect and share with our employees our clients’ ethics, conduct, compliance and policies for the best service delivery and to avoid any breach of client rules.

We respect the confidentiality of sensitive information and do not disclose any information about client companies without their prior authorization and content approval.

Provide clear, complete and timely information to support the client’s business decisions, and keep in total confidentiality the information obtained as a result of the business relationship.

We also respect our competitors and our clients’ competitors. We do not act unfairly, whether to favor a client or attract another player. We therefore treat competitors respectfully so as not to denigrate others’ products and services, nor plagiarize actions and concepts.

Media relationships in communications services

For the better execution of our products and services, we maintain day-to-day relationships with the press and other forms of dissemination (across all online and offline media), guided by ethics, transparency, cordiality and market rules, always observing mutual respect.

We believe in the independence of the press and other media and communication channels in disseminating information provided by the agency on behalf of its clients. We do not support any practice of extra advantages for content publication, nor illegal payment for any use, including pressuring groups or individuals.

We also value relationships with influencers to disseminate our clients’ content as a way to expand reach ethically and responsibly.

Competitive ethics and public tenders

Every partner, employee or professional acting on behalf of Approach Comunicação Integrada must observe a transparent relationship with public officials, following the company’s ethical principles.

Public bodies primarily contract services through public tenders. We uphold the highest standard of ethics and transparency in dealings with any public body and take part in tenders in compliance with applicable law, respecting the limits of the notices, prioritizing competitive ethics, and neither offering nor seeking any undue advantage or privileged information in tender processes.

We do not make any kind of political donation, including of services, to political campaigns or to candidates for elective public office.

In private commercial competitions, our employees must strictly follow the contractor’s instructions on supplier-selection procedures, without seeking advantages that diverge from competitive ethics.

Conflicts of interest

Conflicts of interest are situations that can affect the image, reputation and business of Approach Comunicação, its partners, employees, suppliers, service providers or clients in the performance of services provided by Approach.

This does not mean Approach is barred from providing services to competing clients in the same economic segment. Our partners and employees must observe and respect each client’s contractual conditions and act to preserve the confidentiality of information they access in providing our services.

In relationships with suppliers, Approach and its employees must ensure that the contracting of products and/or services is based exclusively on market and quality criteria, without interference of any kind that could constitute privilege or discrimination.

In relationships with competitors, the agency observes the principles of ethics, cordiality and fair, loyal competition. We do not tolerate anti-competitive practices such as price fixing, market allocation among competitors, or any other practice that prevents a free and fair market.

Our employees and partners must preserve the confidentiality of competitive information.

Questions

If in doubt about the most appropriate conduct, the employee should seek help from their supervisor or the Human Resources department.

Ombudsman

Approach’s ombudsman is a dialogue channel with our internal and external audiences, as well as partners and suppliers. Any irregularity found or conduct contrary to our code of ethics may be reported there. Messages sent through this channel will be treated confidentially and respectfully, and we will seek to understand the issue in order to resolve it quickly and in accordance with the law. This channel will also be responsible for continuous improvements in our internal and external relationships.

Messages should be sent to: ouvidoria@approach.com.br