Code of Ethics

This Code of Conduct applies to all Officers and Directors, members of the board and all employees in Grupo Guararapes, to clarify the conduct expected for professionals to carry out their activities. It is also applicable to the employees who are providing services to the Group, where the services are provided for in a contract.

To guide all the Group’s plans and actions so that they are based on respect for human beings, reflecting the company's commitment to ethical and transparent values in all its relationships, as well as integrity in conducting business.

Disseminate, to all Grupo Guararapes employees, the importance of having a formal policy on internal conduct, so that each one understands their role in the organization.

Clarify which behavior is considered appropriate in carrying out their professional activities.

To provide a clear understanding of the conduct to guide our business and relationships, and it must be present in carrying out our activities on a daily basis, thus building an ethical organizational culture.

3.1 Conflicts of Interest

The people related to the Code of Ethics must always act in a manner where their private interests, or those related to them, do not overlap with the interests of Grupo Guararapes.

A conflict of interest is any opportunity the employee has for a personal gain that may conflict with the activities, interests and image of Grupo Guararapes, as well as to carry out any other activity that conflicts with their work day.

3.2 Information

The employee shall maintain the confidentiality of data they obtain during their activities in Grupo Guararapes, such as information about employees, businesses, clients, suppliers, company strategies, among others. Therefore, it is prohibited to use this information for private purposes or pass it on to third parties.

If any information needs to be disclosed outside the company, including academic papers that focus on the activities of Grupo Guararapes, it must be authorized by their immediate superior and the Ethics Committee.

This obligation of confidentiality will remain valid even after their employment has been terminated at Grupo Guararapes.

3.3 Absences and Leaving Work

The employee shall notify their line manager if they are delayed, absent or have left work.

3.4 Personal Details

All employees shall inform the company of any change in their personal details (address, telephone number, marital status, surname and dependents).

3.5 Intellectual Property

Intellectual property developed or created by any employee while carrying out their professional activities is owned by Grupo Guararapes, even after their employment or contractual relationship has been terminated.

3.6 Internal Trade

 It is prohibited to trade products or services between employees on company premises.

3.7 Identification Badge and Time Clock

The identification badge is for personal use and is not transferable. It should be used in a visible place and in all company premises.

The identification badge must be swiped on the time clock according to the entry and exit times as provided for in their employment contract.

3.8 Working Day

Employees must strictly follow their working days. Overtime must be worked on exceptional occasions and only with the authorization of their superior, always respecting the collective agreements and/or agreements with unions in the region.

For external services, the employee must comply with the same workload as determined in their employment contract.

3.9 Property

It is the responsibility of all employees to look after Grupo Guararapes assets, preserving and conserving materials, work tools and the safety of our installations, furniture and other equipment, only using them for professional activities and within the usage policy.

3.10 Private Passwords

It is prohibited to share passwords with co-workers to gain access to internal systems, since passwords are personal and non-transferable.

Employees should be careful not to use passwords that are easy to figure out, such as date of birth, parents' name, registration number, sequential numbers, etc.

3.11 Eletronic Media

It is prohibited to divulge and use the Grupo Guararapes electronic media for specific subjects, as well as sending or receiving jokes, chain messages, improper content or other files.

The resources and equipment used in professional activities are the property of the company and should be used for the exclusive use of its interest. Thus, in order to preserve this use, Grupo Guararapes reserves the right to control and monitor its contents and usage.

3.12. Consumption of Alcoholic Beverages and Illegal Drugs

Grupo Guararapes does not allow its employees to consume or be under the effects of alcoholic beverages or illicit drugs during the work day or at the workplace, including travel, events, training and business meals.

3.13. Press Relations

Statements can only be made and the press given information (verbal or written) with the authorization of the Marketing department or the Director of your department.

Requests to photograph our building facades or inside buildings must also be authorized by the Marketing department or Director of the department to be photographed.

3.14. Personal Presentation and Uniform

Employees, in carrying out their professional activities, represent the image of Grupo Guararapes and, for this reason, must be suitably dressed, according to their function.

3.15. Comments and Suggestions

Grupo Guararapes supports and encourages the freedom of expression from all employees, in the form of comments or suggestions, so long as they are given to the departments responsible for resolving them.

3.16. Commercial Relationship with Former Employees

Former employees of Grupo Guararapes may only supply products or services to the company after a period of two years from their termination of employment and with the approval of the Legal Department.

3.17. Terminal of Employment

At the end of the employment contract, uniforms, identification badges, health care insurance cards and work tools (e.g. mobile phones, tablets, computers) must be returned.

4.1. Unconditional Respect

Relationships among co-workers should be governed by courtesy and respect. It is everyone's duty to invest in creating a harmonious work environment, with team spirit, solidarity and fellowship in all professional relations.

4.2 Health and Safety

Relationships among co-workers should be governed by courtesy and respect. It is everyone's duty to invest in creating a harmonious work environment, with team spirit, solidarity and fellowship in all professional relations.

However, it is the responsibility of employees to be aware of the standards and procedures for carrying out their professional activities, preserving their physical safety and that of their colleagues.

4.3. Equal Opportunities

The criteria used to select professionals will always be based on technical aspects, according to the potential of each candidate or employee. For the internal recruitment programs (PRI), performance assessment and recommendations by the line manager will also be considered.

4.4. Ethnic, Socio-Economic, Cultural, Religious and Sexual Diversity

Riachuelo shall not tolerate manifestations of prejudice based on race, color, age, gender, sexual orientation, religion, mental or physical disability, ethnicity, socio-cultural factors, nationality or marital status towards any person.

4.5. Psychological Harassment

Grupo Guararapes will not allow any type of harassment involving abusive conduct: behavior, words, acts and gestures that can damage your dignity and physical and mental integrity.

4.6. Sexual Harassment

Attitudes such as verbal, gestures or physical sexual proposals or innuendos are prohibited and considered sexual harassment.

4.7. Affective Relationships

Affective or kinship relationships between employees who have a degree of subordination or who work in departments where the work relationship may generate a conflict of interests is not permitted. Situations such as these should be notified to the Ethics Committee, who will verify the possibility of relocating one of the employees to another department of the company or, as a last resort, terminate the employment of one of the parties.

5.1. Relations with Suppliers

Grupo Guararapes interacts with its suppliers using legal, efficient and fair commercial practices, treating them with respect and honesty.

5.2. Choice of Supplier

A supplier must be chosen using ethics and suitability, considering quality, price and delivery.

5.3. Donations and Sponsorships

The distribution of sponsorship (linked to the Group's image) and donations on behalf of Grupo Guararapes are prohibited without prior authorization from the Management.

5.4. Anti-bribery and Anti-corruption Measures

It is prohibited to request or accept any type of payment, commission, gift or remuneration in relation to your professional activity at Grupo Guararapes, from customers, suppliers, intermediaries, counterparties or any other third party.

Not included in this prohibition: office supplies used daily with an estimated value less than R$ 30.00.

Grupo Guararapes always carries out its activities to minimize environmental impacts. It constantly re-evaluates and implements procedures that optimize the use of electricity, water, recycling, and others.

Grupo Guararapes recognizes its importance in developing the society, both in the generation of jobs for the community of which it is part, and in compliance with current laws. It supports and encourages employees to participate in social responsibility campaigns.

The relationship with our competitors should be based on ethics, avoiding any actions or practices that may define unfair competition. 

We maintain strict compliance with the legal, tax and labor requirements established by the legal agencies, through compliance with the legislation imposed and payment of tax and labor liabilities.

Grupo Guararapes understands the importance and respect for free trade associations for employees, seeking to maintain mutual respect with entities and associations focused on guaranteeing the interests of professionals of the category and market segments.

It is strictly forbidden to carry out, facilitate or be complicit in any act related to money laundering, financing terrorism and corruption. For the latter act, it is prohibited to deliver, promise or offer any kind of payment, commission, gift or remuneration to any authority, public servant, employee or executive of public companies or agencies, whether carried out directly by them or indirectly through persons or companies linked to them and is sent to the employee themselves, public servants or other person nominated by them. This prohibition extends to the authorities, employees or public servants in Brazil, as well as to any other country.

Each employee must be aware of the policies and practices stated in this Manual on Disciplinary and Ethical Conduct.

If any rule established in this Manual is violated, appropriate disciplinary measures will be adopted, guaranteeing the parties involved the full right to defend themselves and argue their case.

Taking the initiative to confess a violation of ethical conduct is encouraged and will be taken into account in determining the appropriate disciplinary action to be taken.

Omission when knowing of possible violations by third parties will also be considered unethical behavior.

The Ethics Committee is composed of the Audit, Legal and Human Resources Managers.

The members of the Ethics Committee shall continuously assess the timeliness and relevance of the standards contained in this document and its disclosure at all levels of the company. 

In case of doubt or non-compliance with the Code, contact the Ethics Committee.
Riachuelo: 0800 055 7611 / etica@riachuelo.com.br
Guararapes: 0800 777 4488 / etica@guararapes.ind.br

Last Update on June 27, 2018

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