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Code of Ethic and Conduct
 

We are always concerned with creating a better work environment where our people feel well, so we created our Ethical Code to aligne the people's actitude to the culture of our company. Our Ethical Code  guides our team on what type of conduct is expected from Elper company, thus creating a healthy and transparent work environment!

 
 

ELPER Automotive Systems Ltda

ETHICAL CODE

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4.2. Attributions of the Committee:

· Define the ethical principles to be observed by all members of the staff, performing periodical reviews of such principles, and forwarding it for approval by the Managing Director of ELPER Automotive Systems;

· Promote the broad knowledge and application of the ethical principles in the course of the activities performed by all staff members.

· Evaluate all cases brought to the committee level, regarding breaches of ethical principles foreseen in here, and/or evaluate situations that are not foreseen in here.

· Ensure secrecy about the denouncing party, when expressly requested by such party, except for cases involving the need to act as witness on a court of law;

· Evaluate and decide cases brought to it, within the shortest possible timeframe, observing the limit of 30 days from the date when the case have been brought up;

·· Recommend to the Board of ELPER Automotive Systems the steps to be taken whenever conflicts of interests are detected.

· Identify new situations within the internal administration routine or within the businesses of ELPER Automotive Systems, which are not covered by this policy, recommending its review.

 Request, whenever necessary, for evaluation of the issues, the support from internal or external auditors.

· Handle all matters brought to it within absolute secrecy and preserving the interests and image of ELPER Automotive Systems as well as of the involved staff members.

5. COMMITMENT LETTER
All staff members, when receiving the Ethics Code, shall get acquainted with its contents, and subsequently shall sign a Commitment Letter. Through such letter, each staff member acknowledges to know the Ethics Code and the Conduct Ethics Standards adopted by the company, undertaking to care for its application.

When signing the letter, the staff member shall declare eventual conflicting situations, or situations that may fit within those listed in here, including his eventual participation in other companies.

Once signed the letter, it will be filed along with the staff's records.

The procedures to implement and file the Commitment Letters will be set by the HR Division.

The Commitment Letters, once signed, are valid for an undtermined time, being the Ethics Committee in charge of deciding about its periodical renewal, particularly in cases of this letter review, which may have significantly changes in the terms.

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