Code of Conduct
1. Definitions
All capitalized terms in this Code shall have the meanings listed below:
"Non-Disclosure Agreement": Any confidentiality agreement to which Attrus and/or Employees in the exercise of their duties are a party;
"Aggregator": Company that represents a group of other companies when engaging a Partner and Service Provider;
"Senior Management": Attrus' current board of directors composed of three (3) officers;
"Client": The legal entity that hires the services of Attrus, generally headquartered outside the Brazilian jurisdiction;
"Code": this Attrus Code of Conduct;
"Employees": These are all: partners and shareholders; directors; employees; temporary employees; interns; minor apprentices; Customers and/or individuals/legal entities that have a commercial relationship with Attrus;
"Conduct Committee": has the meaning set forth in section 4.13 of this Code;
"Attrus": Attrus Instituição de Pagamento S.A.;
"Merchant": Designation of a customer within the financial market or of an Aggregator's customer;
"Partners and Service Providers": Individuals or legal entities that provide services of any nature to Attrus, commercial or not, paid or unpaid, on an occasional or permanent basis, including, but not limited to, participants in payment arrangements and other service providers in general;
"SAC": Customer Service offered by Attrus, under the terms of current legislation; and
"User/End User": The individuals and/or legal entities that use the Client's services and/or platform(s).
2. Introduction and objectives
Attrus was founded in 2018 by three partners with the aim of revolutionizing the payments market in Brazil. It currently concentrates most of its employees at its headquarters in Nova Lima/MG, but has branches spread across Latin America and the United States of America, and several employees working remotely.
Innovation and total integration with customers, combined with the principles of ethics and transparency led the company to expand its activities to 4 more countries (USA, Mexico, Colombia, Chile and Cyprus) in approximately 3 years of operation.
Currently, with more than 107 customers spread across 5 continents, Attrus follows its growth plan without renouncing the values and principles that were agreed upon in 2017.
The services provided by the institution reach tens of millions of Users, in all the countries in which it currently operates.
- Knowledge
Attrus values all scientific and technical knowledge, acquired by its employees, that can be reverted to the activity of the payment market.
- Commitment
Attrus believes that without dedication and commitment, our goals of revolutionizing the payments market would not be achieved. Attrus employees work with unity, integrity and solidarity so that our goals are never just in the field of dreams.
- Results-oriented
This Code of Conduct is a guide of ethical and professional conduct so that all our Employees are aware of the rules that guide us in the pursuit of our results.
Exponential growth is something insistently sought in our work routine as long as it does not confront our premises of conduct that have guaranteed us to achieve the solidity of the present day.
3. Scope and Users
This Code applies to all Attrus employees, regardless of the country in which they are located, when they are: (i) exercising their professional capacity; or (ii) representing Attrus before third parties, even outside the work environment.
Without prejudice to other hypotheses, this Code will be applied whenever employees and Partners and Service Providers are interacting with each other, with Customers or with counterparties.
4. Guidelines
4.1. Selected topics
Some of the topics addressed in this Code require further detail. To this end, there are specific internal policies that complement it and must also be followed by all our employees. These same policies will be incorporated into the Attrus Compliance Program whenever a topic requires greater specification to be applied:
- Policy for Preventing and Combating Money Laundering and Terrorist Financing;
- Anti-Corruption Policy;
- Information Security Policy;
- Privacy Policy;
- Compliance Policy;
- Cybersecurity Policy;
- Internal Controls Policy;
- Risk Management Policy;
- Regulation of Internal Audit Activity;
- Customer Relationship Policy;
- Policy for the Preservation of the Value and Liquidity of Electronic Money;
- Disciplinary Measures Policy;
- Among other related policies and documents.
4.2. Scope
The reading and understanding of this document is the responsibility of each Employee and other people who participate in the company's activities, observing the provisions of item 2 of this Code. Attrus undertakes to present this material to all to whom this code is applicable and to inform them of the importance of adherence to the values and rules set forth herein, as well as of changes and/or updates to this material.
This content will be published on the Attrus website, for free access and consultation by all relevant parties, who, by reading it, express their irrevocable knowledge of the content provided herein.
4.3. Work Environment
The interaction between Employees is based on respect, transparency and team spirit. Therefore, it is everyone's commitment:
- Work so that, in the search for results, respect and awareness of interpersonal collaboration predominate;
- Respect human rights and labor relations;
- Ensure the integrity of work equipment;
- Diligent performance, always seeking the best interest of the institution and its Customers;
- Do not hide flaws or use false information to mislead others in the organization;
- Do not speak on behalf of the company without the prior authorization of the organization;
- Act in accordance with ethical standards and in accordance with current legislation;
- Recognize diversity, respecting differences and never discriminating by religion, color, ethnicity, nationality, age, sexual orientation, political position or fomenting any form of prejudice or hate speech;
- Combat and report any type of intimidation that may be characterized as sexual harassment or moral harassment;
- Preserve the integrity of the position, without using the function or information that results from the professional activity to influence decisions that may favor private interests and/or those of third parties;
- Respect intellectual property, recognizing the value and authorship of projects, ideas, proposals and initiatives;
- Always maintain the proper security and confidentiality of Attrus' internal processes and documents;
- Use the means of internal communication only for matters pertinent to the work and in a constructive manner;
- Use the materials made available by Attrus responsibly and appropriately, exclusively in work-related activities, ensuring the safety and preservation of equipment; e
- Contribute to compliance with this Code, as well as to resolve doubts about its application.
4.4. Conflict of Interest
Conflict of interest is the situation generated by the confrontation between a personal interest and an interest of Attrus. It can influence or appear to influence people's conduct and decisions.
It is important that we prevent people from being placed in situations of conflict of interest. Thus, Attrus' Employees, Partners and Service Providers, when performing their activities, routines and professional relationships, must always act in favor of Attrus' objectives, preventing personal interests from influencing their decisions or conduct, which could result in a conflict of interest.
Some examples of situations that are not allowed:
- Subordination relationship between family members (spouse, partner or relatives, consanguineous or related, in a direct or collateral line, up to the fourth degree, for example: father, mother, children, grandparents, grandchildren, nephews, cousins, uncles, fathers-in-law and brothers-in-law), and the employee must inform his immediate superior if he knows that any relative of his/her or person with whom he/she has intimate relations is participating in a selection process of the company or if he/she has this type of relationship with someone who work in any company in the group;
- Use of Attrus resources – such as facilities, equipment, email accounts, software, etc. – for private purposes;
- The practice of external activities that involve sharing information or knowledge of Attrus that is confidential;
- Favoring customers, suppliers, competitors or partners due to personal interest; e
- Acceptance of gifts, favors, advantages, gratuities and perks.
This list does not exhaust the situations of conflict of interest that should be avoided. If you have any questions, contact our Compliance team or contact Attrus' Customer Service.
4.5. Protection of information
Attrus deals with confidential information of its Customers and Users at all times. Taking care of this confidential information is essential.
Confidential information is understood to be any information whose unauthorized access may cause irreparable damage to the business and/or reputation of the organization, whether it is explicitly identified as "confidential" or not, in addition to that expressly described as confidential upon the signing of Confidentiality Agreements.
Personal data of our Customers and/or Users is considered restricted information. Personal data is any form of data that can be used to identify an individual. Attrus protects this data in order to protect people's privacy and their fundamental rights.
All information and data regarding Customers, Employees, suppliers, Service Providers and others, which are in the possession of Attrus, are treated with total confidentiality and in accordance with the General Data Protection Law (Law 13,709/2018), Bank Secrecy Law (Law No. 105/01) and Attrus' internal documents, as applicable, respecting privacy, private life, honor and image of the parties involved.
Therefore, we must maintain and preserve in the strictest confidentiality any and all information about Attrus and our Customers/Users made available to us, avoiding talking about it in public spaces or sharing it on social media.
We also need to exercise caution within Attrus' own facilities or when talking to fellow employees, as not everyone needs to have access to all information at the same time. In addition, we must refrain from naming third parties (entities or otherwise) publicly, as Attrus may be bound by Confidentiality Agreements with these parties.
The Employee is solely responsible for his/her passwords (telephony, electronic means and systems) for access, which are personal and non-transferable. Never disclose your passwords to your co-workers, or those closest to you. In this way, you ensure the security of Attrus' information and data.
4.6. Clients and Partners and Service Providers
Attrus is committed to integrity and will conduct its business relationships in a transparent and fair manner. We wish to work with Customers/Users, suppliers, Partners and Service Providers who share our values, who respect them and who act in accordance with the rules contained in this Code.
In the relationship with Customers/Users, suppliers, Partners and Service Providers, it is the duty of all Employees:
- Act with transparency and impartiality;
- Fulfill contracts signed with third parties;
- Assume an open and interested posture in relation to criticism, suggestions and requests;
- Ensure that the customer/supplier receives a clear, accurate and satisfactory response to their questions and requests;
- Recognize and communicate any errors made by the supplier/customer;
- Respect privacy, ensuring that information about the customer/supplier is treated confidentially and used only with their knowledge; e
- Base the decision to buy and sell products, as well as to hire or provide services, exclusively on technical and professional criteria.
Every Employee must ensure the quality of the services offered by Attrus and our suppliers. Any violation of this Code must be reported through the compliance@attrus.com address, or in case of complaint, through the official reporting channel available on our website (attrus.com), which contains the step-by-step instructions to do so, including anonymously.
4.7. Prevention of fraud, bribery, corruption and money laundering
Employees must value ethics and integrity in all their business relationships, never promising, offering or accepting payments that are not strictly related to the activity developed within the contractual parameters made between the parties. Attrus has zero tolerance for actions that are or resemble bribery, bribery, corruption, money laundering, among other crimes.
Bribery or bribery are amounts paid to government agents to speed up or facilitate a process. Corruption is the phenomenon by which public or private agents abuse the power entrusted to them so that, in exchange for
illegitimate benefits, give preference to the private interests of the corruptors. The practice of "money laundering" consists of concealing the illicit origin of certain financial assets so that they appear to have a lawful origin. These practices should be avoided at all costs.
In our business relationships with third parties – Partners and Service Providers or Customers/Users, Attrus rejects any incentive that may distort the scope of the established business relationship, also disapproving any and all conduct in order to offer any benefit for the beginning or maintenance of its business relationships or the practice of crimes.
Employees, Partners and Service Providers, Customers/Users must comply with Atrus' internal policies and documents related to, but not limited to, the prevention of the practice of money laundering and terrorist financing crimes, internal manuals, compliance practices, among other specific and internal Attrus documents.
4.8. Gifts, gifts and hospitality
Exchanging gifts, gifts, and entertainment is an acceptable way to establish business relationships and to show consideration in the business environment. When giving or receiving gifts, gifts and entertainment, it is very important that we use common sense, following a few steps:
- comply with legal criteria;
- only offer or accept gifts, gifts and hospitality if the item and its value are proportionate to the business relationship established;
- not to influence or appear to influence our decisions or the decisions of those with whom we have business relationships; e
- not to favour or appear to favour a specific trading partner.
Favors or benefits that have commercial value, offered by customers, suppliers, partners, third parties, public agents or other public or private entities, must be refused.
It is forbidden to accept or offer entertainment that may embarrass third parties, employees or Attrus, such as those that have a sexual nature.
4.9. Donations and sponsorships
Donations and sponsorships are common actions in business relationships and allow involvement with the community, as long as they occur in accordance with the law. Attrus values donations and sponsorships that have a philanthropic character, based on social interests and support cultural, educational and sports institutions, as long as they do not represent or appear to represent favoritism or benefit for Attrus or any of its Employees.
Donations by Attrus, or through Attrus, to political parties, candidates for public office or political campaigns are not permitted. Donations to these entities by individuals who are partners, shareholders or members of Attrus' Senior Management are also not allowed.
Any charitable contributions, support or sponsorship that aim to influence business decisions or serve personal benefits, direct or indirect, are prohibited. Donations for religious purposes, donations to individuals or donations through cash are also not allowed.
Attrus does not allow donations or sponsorships to entities linked to public agents, their advisors or family members.
All transactions related to donations and sponsorships must be properly accounted for and reported to the Compliance area.
4.10. Image and reputation
Employees are the face of Attrus. Whenever we are in the position of representative of Attrus, in professional or social situations, we must follow the corporate values and principles of integrity expressed in this Code, not adopting postures or attitudes that compromise the image, reputation and interests of Attrus.
Thus, as an Employee, your personal attitudes can reflect on Attrus' reputation, whether they are demonstrated in person or through social networks.
Attrus values diversity and respects differences and, like all Employees with access to Attrus' official communication channels, should not publicly manifest themselves, through these channels, on topics such as politics, religion, beliefs or sports. On their personal channels, Employees should avoid making any mention of Attrus (use of official hashtags, for example) when expressing themselves on these topics.
4.11. Violation of this Code
Failure to comply with the provisions of this Code of Conduct, by an Employee or by any person who is part of the commercial and work relationship with Attrus, will be rigorously investigated according to the procedures of the Conduct Committee, ensuring the anonymity of those involved. All Officials have a duty to cooperate with ongoing research processes.
4.12. Conduct Committee
It is the collegiate responsible for evaluating violations:
- the Attrus values;
- to this Code of Conduct;
- the policies that derive from it or that will derive from it; e
- to the relevant legislation.
It is also solely responsible for defining the disciplinary and/or legal measures to be taken.
The Conduct Committee is also responsible for:
- evaluate and refer cases not provided for in these documents;
- submit to the C-Level a proposal for any changes to this Code or its policies; e
- deliberate on the form, content and level of disclosure of cases of violation, after their closure.
4.13. Who to ask for guidance?
When you have questions and/or suggestions about what to do or about the application of this Code, please contact our Compliance team.
Your questions and suggestions addressed to compliance@attrus.com will also be answered.
4.14. Attrus Whistleblowing Channel
Violations of this Code, as well as occurrences of illegal or irregular conduct or other issues that may cause damage to Attrus, must be reported by Employees, Partners and Service Providers or third parties, through Attrus' complaint/communication channel, which can be accessed at: "https://i3dvdja9a3o.typeform.com/fpcanaldenuncia?typeform-source=www.Attrus.com"
Attrus guarantees the confidentiality and security of the channel, so that it can be used anonymously or not, without the people who use it suffering any type of retaliation.
The channel for suggesting improvements to the Compliance Program and questions about this Integrity Program and its documents is the e-mail compliance@attrus.com and subsidiarily ouvidoria@attrus.com
5. Publication
Any new document or modification of an existing document should be made available to all interested parties.