Anti-corruption policy

Anti-corruption policy

This policy establishes the principles and guidelines governing the ethical and integrity of all employees, partners, suppliers and other stakeholders of Devops Technologies ("https://www.devops.srv.br"). Our commitment is to transparency, honesty and the fight against all forms of corruption, ensuring a fair and reliable business environment.

1. Definitions:

• Corruption: It understands the offer, promise, donation, acceptance or request of any undue advantage, of a financial nature or not, to influence a decision or action, to obtain undue benefit or to violate a duty of trust. Includes but is not limited to:
  
  • Bribery: To offer, promise or give something of value to a person with the purpose of influencing their actions or decisions.
  • Extortion: Demand or request something of value under threat or coercion.
  • Fraud: Deceiving or distorting information to obtain undue advantage.
  • Concussion: Demand, for yourself or for others, directly or indirectly, even if outside the function or before assuming it, but because of it, undue advantage.
  • Nepotism: Favor relatives or friends to the detriment of merit and equal opportunities.
  • Money Laundering: Hide or conceal the nature, origin, location, disposition, movement or ownership of goods, rights or values arising directly or indirectly from criminal offences.
• Collaborators: They include all employees, directors, counselors, interns and any other persons acting on behalf of Devops Technologies.
• Partners and Suppliers: Companies, organizations or individuals who provide goods, services or establish any kind of commercial relationship with Devops Technologies.
• Interested Parties: Any individual or entity that is interested or affected by Devops Technologies activities.

2. Principles Fundamental:

• Integrity: To act with honesty, ethics and transparency in all our activities.
• Compliance Cool: Strictly comply with all applicable laws, regulations and anti-corruption rules, including Brazilian legislation and those of other countries where the Site operates or has commercial relations.
• Zero Tolerance to Corruption: We tolerate no form of corruption, whether active or passive, direct or indirect.
• Transparency: Keep accurate and transparent records of all financial and commercial transactions.
• Liability: Each employee, partner and supplier is responsible for knowing and adhering to this policy.
• Complaint Channels: Ensure safe and confidential channels for reporting suspected corruption without fear of retaliation.
• Diligence due: conduct due diligence with respect to partners, suppliers and other stakeholders to assess and mitigate risks of corruption.
• Education and Training: Promote awareness and ongoing training on anti-corruption laws and this policy.

3. Guidelines and procedures:

• Gifts, Gifts and Hospitality: It is forbidden to offer, promise, give or receive gifts, gifts, entertainment or hospitality that can be interpreted as an attempt to influence decisions improperly. Any offer or receipt must be of modest value and comply with market practices and applicable legislation, and be duly registered when appropriate.
• Donations and Sponsorships: Any donations or sponsorship shall be carried out in a transparent and documented manner, with appropriate internal approvals, ensuring that they are not used for corruption purposes.
• Conflict of Interest: Collaborators should avoid situations that can generate conflict between their personal interests and the interests of Devops Technologies. Any potential conflict of interest must be declared and managed transparently.
• Public Sector Interaction: All interactions with public bodies and their representatives must be conducted ethically, transparently and strictly in accordance with applicable laws and regulations. It is strictly prohibited to offer or promise any undue advantage to civil servants.
• Internal Controls: Devops Technologies will maintain effective internal controls to prevent, detect and remedy acts of corruption, including segregation of functions, approvals at different levels and periodic audits.
• Registration and Accounting: All financial and commercial transactions must be recorded accurately and fully reflecting the true nature of transactions.
• Selection and Monitoring of Partners and Suppliers: Devops Technologies will implement due diligence processes to assess the risks of corruption associated with partners and suppliers, in addition to monitoring their performance and compliance with this policy.
• Complaint Channels: Devops Technologies will provide secure and confidential communication channels for employees, partners and other stakeholders to report suspected corruption or other irregularities, ensuring the protection of the whistleblower. Complaints will be investigated impartially and confidentially.
• Internal Investigations: Any allegations of corruption will be investigated internally and independently, with the application of appropriate disciplinary measures in case of confirmation.

4. Liabilities:

• High Administration: He is responsible for leading by example, promoting a culture of integrity and ensuring the implementation and compliance with this policy.
• Managers: They are responsible for disseminating this policy in their teams, ensuring their understanding and compliance, and ensuring an ethical work environment.
• Collaborators: They are responsible for knowing, understanding and fulfilling this policy in all their activities related to Devops Technologies.
• Partners and Suppliers: They are expected to act in accordance with the principles of this policy and the applicable anti-corruption laws.

5. Consequences of No Compliance:

Failure to comply with this policy may result in disciplinary measures, ranging from warning to contractual termination, in addition to other applicable legal sanctions. For partners and suppliers, non-compliance may lead to termination of contracts and other legal measures.

6. Revision and Update:

This policy will be reviewed and updated periodically to ensure its effectiveness and alignment with best practices and current legislation.

7. Provisions Final:

This Anti-Corruption Policy comes into force on the date of its publication and applies to all those involved with Devops Technologies. We believe that integrity and ethics are fundamental to the success and sustainability of our business.

1 May 2025

Devops Technologies