Code of Conduct

Decision making

When we make decisions at our company, we must first ask ourselves a few basic questions:

Is such an act prohibited? Is this act consistent with our Code of Conduct? What would others think about this decision?

If we are not comfortable with the responses to these questions, we do not move forward with the decision in question.

We bring any questions or concerns to leadership, our colleagues, the Compliance Officer, the legal department, Human Resources or forward them through our Communications Channel.

Good sense and ethics requires a change in perspective.

The opinions of others matter. Our colleagues, clients and society as a whole share an interest in what we do. People need to be able to trust in what we say and do. Not everyone needs to agree with us, but we must always make sure that the actions we take are respectful, honest and fair.


Our values are a uniting force that establishes the “Cesbe way” of doing business. Cesbe’s core values are first and foremost the interests and results that we seek.


People and ideas deserve respect. Respect means paying attention and showing empathy and compassion. Disagreements, opposing ideas and even conflicts can be positive if they are resolved in a respectful manner.


We all want to work with someone we can trust. We must therefore act on our promises with integrity and a sense of justness in accordance with the Law.


We seek to be prudent and take those involved or affected by a given situation or decision into consideration. This requires effort and reflection vis-à-vis a wide range of situations.


Rules are not a substitute for common sense. Rules may in some cases actually work against our intended objectives. Common sense is our greatest asset in avoid such issues. If a company law or rule does not make sense, it must be reported in order for the possibility of changing the rule in question to be assessed. It is important to note that until these rules are changed, we must continue to comply with their provisions, even if we do not agree with them.

We don’t have all the answers. And that’s not a problem – as long as we respond to issues in the best possible manner. We’re in this together. Whenever you need to make a difficult decision, it is important that you speak with others. Common sense is a skill that can be developed by involving others and hearing out other points of view. Remember, when you seek out help, you contribute to everyone’s learning process.

Our day-to-day routine may cause us to overlook the obvious. Before acting, take time to reflect on whether you are doing things the “Cesbe way” and adhering to this Code, applicable laws and Safety Standards and demonstrating solid judgment. There’s always time to think before you make and act on a decision.

We talk about the mistakes we make and see them as learning opportunities. We all make mistakes, and they can be extremely valuable learning opportunities if the right people know what happened and adjustments are made based on experience and relevant knowledge. However, it is important to understand that there is a difference between making a mistake and neglecting the manner in which we do business and ignoring the Law, this Code of Conduct or our values. Negligence puts us all at risk. There’s no room for ignoring important issues at Cesbe.


What we do

When something can be improved or is not being done correctly, we take action. We are all expected to contribute to continuous improvement and act whenever we identify an issue. By reporting issues, the company will be able to hear employees out and act.

How we do it

Share your ideas and experiences with regards to potential improvements.

If a requirement or procedure can be improved, let us know. You must also notify Cesbe if appropriate measures have not been taken to protect the company from a potential risk in terms of business activities, legislation or regulations.

Ask questions when things are not clear.

Cesbe offers provides all members of the organization with access to colleagues that are able to answer questions, solve problems and give advice. We also offers an exclusive anonymous Communications Channel. If you’re not sure what to do, ask – we’ll be sure to help you!

Intervene when something’s wrong.

Mistakes happen. When they do, it’s our job to help correct them. If something doesn’t feel right, or if it looks like this Code of Conduct, principles and practices, or legislation are being compromised, it is your duty to report the problem. Ignoring a potential compliance and ethics issue can allow a relatively small error to worsen and become a major problem that results in harm to you, your colleagues, and the company.

How to report an issue

If you have questions or concerns, ask.

If you are concerned about what will happen when you report an issue, speak with your local leadership, Human Resources, or the Compliance Officer.  They can respond to your concerns and answer any questions you may have about the process.

You can also use our Communications Channel.

Cesbe’s Communications Channel is completely external and independent. It is available 24 hours a day, seven days a week, in Portuguese or Spanish to respond to any concern you may have. It is important to remember that our Communications Channel can be used anonymously at the following web address and telephone number:


Confidentiality and a policy of non-retaliation are basic premises under this Code.

The Ethics and Compliance Committee has professionals available that are able to investigate your concerns. Additionally, a post-investigation integrity program has been implemented to ensure that the process remains fair, impartial and respectful.


What we do

We do our work safely. People’s lives and health are our main priorities. Cesbe is committed to offering an accident-free environment.

We comply with Occupational Health and Safety Laws and Standards in the various environments in which we operate and work to continuously improve our performance and protect the lives of all individuals by consistently improving our systems, organizational culture and procedures.


Cesbe has published specific manuals for the areas of Environment and Occupational Health and Safety. Please enter in contact with our HSE (Health, Safety and Environment) teams for more information.

How we do it

We provide our people with the training they need to perform.

Our people are trained to recognize the risks that are inherent to the activities they perform and how to carry them out safely. We must strictly adhere to guidelines issued by Cesbe’s safety teams.

We continuously promote safe behavior.

Safe work does not only involve the use of Personal Protective Equipment (PPE), but also safe behavior. We must identify and avoid dangerous working conditions and remain alert to potential hazards. If you have a safety concern, don’t risk it.

What we need to remember

Each of us is responsible for creating and maintaining a safe environment.

Protect yourself and those around you from accidents. We must work together to ensure that the work environment remains clean, organized and unobstructed, thereby contributing a safe and healthy space. Never carry weapons while performing activities on behalf of the company, unless you have received specific authorization to do so in accordance with company practices.

We know that health also means safety.

Eating well, exercise and proper hydration are essential to carrying out our day-to-day activities at Cesbe. It is important to maintain a balanced diet, drink water and exercise regularly. Working while under the influence of both licit or illicit substances, including alcohol or prescription drugs, is completely unacceptable. If you or your colleague are not in the proper state of mind and conditions of health to safely perform an activity, notify your supervisor, Human Resources or the Health and Safety team.

Report any unsafe conditions or accidents, even when an injury has not occurred.

If you identify an unsafe environment or that safety guidelines are not being strictly adhered to, notify the Safety team, your supervisor, or Management immediately. All accidents and near misses must be reported. Immediately reporting such events will help improve safety conditions for all by contributing to the development of accident prevention standards.


What we do

We seek to maintain a respectful, inclusive and safe work environment. It is essential that we are all given the same opportunity to contribute and achieve success. This is the type of workplace from which everyone benefits. Discrimination, harassment and unsafe working conditions are unjust and directly opposed to the “Cesbe way”.

How we do it

All work-related decisions at Cesbe are made on the basis of merit.

We do not limit the opportunity for growth or progress at our company based on age, family responsibilities, disability, ethnicity, gender, gender expression, sexual orientation, religion, pregnancy, or other personal characteristics that are protected under the law.

We treat everyone with respect.

We don’t tolerate any form of harassment. Do not tolerate offensive, degrading or abusive conduct in the workplace. Improper conduct includes being verbally aggressive, bullying, sexual harassment, intimidation and offensive behavior. Violence and the threat of violence are also unacceptable.

What we need to remember

People should feel free to express themselves at work.

In order to be both productive and engaging, work environments must be diverse and inclusive and places in which employees feel comfortable and respected.

Employee representation.

We respect our employees’ right to join, or refrain from joining, representative unions and organizations of their choice.

Our standards are applied to contexts outside the company.

Remote workplaces, external meetings, business travel and team social events are considered work-related contexts. In any situation it is important to consider how your behavior can affect your colleagues and the company’s reputation


What we do

We excel in a market based on free and fair competition. We seek to be consistently competitive on the marketplace based on the quality of our services, solutions, innovation, pricing and other means permitted under the law.

How we do it

We respect our competitors.

Competition is a healthy aspect of business and we seek to set ourselves apart on the market by offering better solutions, services and prices. We strive to achieve the quality and reliability that are part of the offer we make to clients.

There is no place for bribery and corruption here.

It is of the utmost importance that we do not discuss or make agreements with competitors, suppliers, clients or government bodies that are not consistent with the Law, this Code of Conduct and the dictates of common sense. Under no circumstances do we accept, nor do we offer bribes consisting of entertainment, gifts, payments, or anything of value in order to obtain or retain business, or secure an undue advantage.

What we need to remember

The manner in which we compete is as important as the results we obtain.

The manner in which we interact with our competitors and contractors must be in strict compliance with the law and antitrust regulations.


What we do

We do not engage in bribery with anyone, anywhere, or for any reason. We recognize that our refusal to participate in corrupt activities could potentially hinder our business activities in certain markets, but bribery is something that is simply unacceptable at Cesbe. We are consistent and unwavering in our stance on corruption and have proven time and time again that we can achieve our business objectives without taking unacceptable shortcuts.

How we do it

Refrain from offering bribes or practicing acts of bribery, never allowing others to act in such a manner on our behalf.

Great care must be taken when offering something of value – including money, gifts, favors, or entertainment since such an act may be seen as an attempt to improperly influence someone’s professional actions or decisions. Always use common sense and, whenever in doubt, work together with the Compliance Department to better understand what you can and cannot do.

What we need to remember

What if offering a bribe or kickback seems like the only option?

Even if you believe a bribe is necessary or if someone is pressuring you to offer a bribe, it is important that you refrain from doing so and report the situation. The company will make sure that the right people are involved in order to find the best solution moving forward. We will forgo business opportunities or carefully review our objectives in situations in which we cannot resolve the issue immediately.

How we do it

Refrain from offering bribes or practicing acts of bribery, never allowing others to act in such a manner on our behalf.

Great care must be taken when offering something of value – including money, gifts, favors, or entertainment since such an act may be seen as an attempt to improperly influence someone’s professional actions or decisions. Always use common sense and, whenever in doubt, work together with the Compliance Department to better understand what you can and cannot do.

Never offer bribes, even if doing so is considered “normal” in society.

Bribes are small payments or gifts made to government officials in exchange for the speeding up of a routine process or service. If you feel it’s necessary or are under pressure to make this kind of payment, it is important that you don’t. Talk to the Compliance Department about how to best handle the situation instead.


What we do

We make sure that information is protected and secure for competitive, ethical, and legal reasons.

In most cases, sharing information is something positive. However, sometimes it’s something that is outright wrong.

Throughout the course of our work routines, it is only natural that we will at some point have access to privileged and confidential information involving Cesbe’s business strategy, such as projects, budgets, investments, business models, significant changes within the company, employee and supplier data, etc.

Carefully consider the information you use and understand our specific obligations with regards to collecting, processing, storing and disseminating such information.

How we do it

We protect the competitive advantage that our work offers.

If the information in question provides a competitive advantage, or if a competitor would conceivably want to gain access to such information, then it is potentially confidential and requires protection. We may only disclose Cesbe’s proprietary information when it is necessary in best serving our interests and only once adequate protection has been put in place to prevent misuse. Some examples of sensitive business information include budgets, technical solutions, designs, technologies, strategies and financial information.

We respect the privacy of all.

We implement appropriate measures in order to protect personal data collected, maintained and used by the company.

We respect confidentiality and intellectual property rights held by others.

We also seek to protect proprietary confidential information with which we have been entrusted by other companies.

What we need to remember

Regardless of whether a situation involves information that is confidential or not, it is essential that you use your common sense and adhere to the provisions provided for under the Law and this Code of Conduct.

It is important to remember that, while it is embarrassing to lose sensitive information, information in itself is not cause for embarrassment. We protect information for commercial, legal and ethical reasons – we do not hide things that, although they might be unpleasant, people have a right to know.

Passwords and other access codes to internal systems are personal and non-transferable.

You are responsible for your password. Cesbe does not allow passwords to be shared and considers the password’s owner fully responsible for its use. Any and all events that present a risk must be reported.

Negligence is one of the main causes behind the loss of information.

Our technology can help protect information, but you are our first line of defense. Be skeptical and make sure you know exactly who you’re interacting with. Sometimes the loss of information may result from theft of an non-encrypted laptop or flash drive or a conversation on an airplane regarding a confidential matter.

Other times, information may be compromised due to an eagerness to collaborate with external partners without first adopting information protection measures.

We must be particularly careful with information in public places.

Negligence is one of the main causes behind the loss of information. We recommend that you only discuss Cesbe’s business when necessary and with a significant level of neutrality and discretion. When we speak on the phone we must respect the confidentiality of the information and adopt a discreet tone of voice. Restaurants, classrooms, airports, taxis and events require special attention in terms of the use of information. Computers must be used in waiting rooms and on board airplanes, for example, while taking due caution to prevent theft and the exposure of strategic and confidential information.


What we do

We make fair and objective decisions.

Actual or potential conflicts of interests occur whenever an employee’s activities overlap with their job responsibilities, whether such responsibilities are of a personal, financial, political or social nature. A conflict of interest may occur, for example, when we negotiate with family members, close friends or with companies at which family members and close friends work, or when we have an ownership interest in a potential supplier’s company.

In a similar manner, gifts and entertainment may in some cases influence professional decisions and are therefore prohibited at Cesbe.

How we do it

Reveal potential conflicts of interest.

We must report actual and potential conflicts of interest in order to ensure that we are able to find a way to mitigate the conflict in question. Most people overestimate their ability to make objective decisions when faced with conflicting personal interests.

Do not accept or offer gifts or entertainment in an attempt to compromise the professional judgment of others.

Gifts, meals, hospitality and entertainment must be provided within the limits of the highest standards of ethics and integrity. Such an offer cannot be linked to undue personal gains, rewards for closing a business deal or the implicit or explicit exchange of favors or benefits. No forms of gifts, invitations or hospitality should be regularly accepted since they may appear to offer an undue advantage.


What we do

We maintain records that are honest, complete and accurate.

Our financial statements and accounting and business records are maintained in an appropriate manner. We know that transparency and accuracy are fundamental to achieving our desired business results.

How we do it

Our financial statements are accurate and comprehensive.

The entire Cesbe team, not just the finance and accounting departments, shares a responsibility and obligation to ensure that documentation and records are accurate. This requires organization, comprehensiveness and accuracy of forms, registrations, orders, expense reports, invoices, measurements, or any other document that represents financial or commercial activities, including budgets.

We comply with standards and legal provisions.

We have an obligation to ensure that our financial and accounting records and reports are accurate as required under applicable laws, applicable accounting standards and our internal policies. We fully cooperate with all audits, lawsuits and government investigations.

What we need to remember

Maintain the records required under the law and by the company.

The company has a document storage policy in place that defines which documentation needs to be filed and for how long. These schedules ensure that the company has the information it needs to carry out operations and that we are able to fulfill legal requirements. It is essential that you adhere to the instructions provided under the policy and keep the documents it describes.

Signs of potential fraud in records.

Alteration or simulating of dates of documents and contracts; entry of revenues and expenses during an incorrect period; incompatibility in data between documents, in particular quantities, invoices issued to clients at incorrect prices, and suppliers receiving payments above or below market averages, may be signs of fraud. Attention to detail is of the utmost importance.

Consider the different forms of documentation we handle on a daily basis.

These documents include reports, timesheets, records for payroll and benefits, payroll withholdings, travel expense reports, requisitions, purchase orders, service orders, receipts for goods and services, inventory records, transport documents, tax invoices, receipts, daily work records, tax collection forms, tax declarations. Everyone must adhere to established standards for accuracy.


What we do

We are committed to sustainable growth. Achieving sustainable growth is dependent upon the integrity of our internal and external supply chains. We seek to actively contribute to the development and improvement of society, to the quality of life of people and to the protection and restoration of the environment.

How we do it

We contribute to eliminating abuses of labor rights within our supply chain.

Child or forced labor or any other violation of the dignity and rights of any person are not tolerated at Cesbe. We are all responsible for certifying that any service provider or supplier used by the company shares these same values.

We seek to reduce the impact of our business activities to the furthest possible extent.

Environmental responsibility is essential to the manner in which we carries out our activities. We are committed not only to strictly complying with environmental legislation, but also seeking out sustainable solutions. The conscious use of resources and the search for alternatives that are less aggressive on the environment is present throughout our entire chain of business activities.

What we need to remember

We work with suppliers that share our commitment to compliance and integrity.

Who we choose to work with throughout our supply chain and how our partners and suppliers operate affects our reputation and our business. If you are selecting a new supplier or reevaluating a current one, it is important to make sure they understand our principles and are aware of anything that may be contrary to our standards.


Our organization’s culture influences our actions, and there are many different factors involved in the development of a corporate culture.

We recognize the important role that our people play and require that everyone assume responsibility for conducting our business activities. The engagement of everyone at the organization is a main premise for business success at Cesbe.

Those entrusted with leading the company have a special responsibility to shape our corporate culture and our teams’ work environment. Directors, managers, supervisors, coordinators, and forepersons must ensure that their teams:

  • Are aware of and fully understand this Code and Cesbe Principles and Practices relevant to their work;
  • Be willing to report Ethics and Compliance issues;
  • Understand that the company is open to hearing their concerns;
  • Realize that we do business with integrity while placing an emphasis on honesty, fairness and respect.

Preserving a healthy and compliant culture is much more difficult than simply telling employees to abide by the rules. Authentic leadership is central in establishing a consistent organizational culture. Demonstrate what it means to act with integrity. Gain the trust of their team by addressing the contents of this Code of Conduct.

Leading others requires courage, consistency, and credibility. Remember that being a leader is about inspiring others to follow oneself, creating a sense of community and an environment that is constructive and challenging.

If a person reports suspected misconduct, remember that they are fulfilling their duty as an employee and must be treated with respect. Do not attempt to investigate issues alone; immediately contact the Compliance Department or use Cesbe’s Communication Channel in order to allow the company to objectively address the matter.


This Code contains mandatory provisions that apply to all employees, officers and directors at Cesbe, whether established in Brazil or overseas, as well as anyone acting on our behalf. Violations of this Code or Compliance Principles and Practices may result in disciplinary action, including potential termination of employment contracts.

Cesbe holds a fair and reasonable expectation that the behaviors manifested by partners, suppliers and service providers will at no time contradict, under any circumstances, the guidelines contained in this Code of Conduct, particularly while they are on company premises, interacting with employees or acting on behalf of Cesbe.

This Code applies to Cesbe Participações S.A., and the entirety of its direct and indirect subsidiaries, which are referred to collectively as Cesbe or the company.