Code of Ethics

1. Introduction
askblue‘s responsibility extends to:

• Its Shareholders
To ensure good profitability of its investments and to regularly provide them with transparent and complete information.

• Its Clients
Committed to providing quality services and products, in the strictest respect for safety standards and environmental impact, whenever applicable.

• Its Employees
By being alert to the development of their competences, as well as their working conditions, particularly that which concerns their occupational health and safety.

• Its Suppliers and Associates
With the clarity and respect of the mutually contracted terms, askblue hopes to have their respect for the guidelines and behaviours clarified in this Code of Ethics.

• The Civil Society
By being part of the economic and social development of the regions or countries, which develops its activity, actively contributing to environmental preservation.

askblue also subscribes:

• The principles of The Universal Declaration of Human Rights (see attachment I);
• The principles of the International Labor Organization – Declaration of Philadelphia (see attachment II);
• The Ten Principles of the UN Global Compact (see attachment III).

Our conduct is guided by:

• The respect of the rules of free competition and the rejection of any form of corruption;
• The non-intervention in the political life of the regions or countries in which we develop our activity;
• Actively contributing to environmental preservation with a clear policy of sustainable development.

2. Application
The Code of Ethics defines employees’ expected conduct in various situations, guiding their actions from an honest and moral perspective.

It applies to every askblue employee, as well as their subsidiaries and branches. It shall also be applied to every Service Provider, Business Partner or third parties that interact with the Human Resources group.

3. Communication
The current Code of Ethics is available to be consulted by all employees and collaborators at any time. Human Resources shall inform all the new employees about the Code of Ethics, promoting their express agreement with it.

It is the managers’ responsibility to disclose the Code of Ethics to employees in their area, clarify all their questions, and see if there is an understanding of its content and application.

This Code of Ethics may be part of contracts and purchase documents issued to suppliers and it will be available for external consultation on our website.

4. Rules and Recommendations

4.1 Workplace Environment

• The workplace environment must be based on respect and order to prevent acts of sexual or moral harassment and any kind of discrimination based on race, colour, religion, sexual orientation, social status, nationality, age, political affiliation or any type of mental or physical disability.
• It is permitted to hire employees with a family relation, as long as they do not perform tasks with hierarchical subordination. All employees must be submitted to all stages of the selection process and privileges are not accepted concerning other candidates.
• All employees must contribute to the creation and preservation of a healthy environment and shall not participate in spreading disinformation (rumours) without proof. Any queries in this regard shall be resolved by the managers.

4.2 Compliance with the Laws

• Compliance with the laws and applicable regulations concerning the company’s activities must be observed at all levels of public administration (national and municipal) as well as in other countries where the company does business.
• The intellectual property of third parties, including copyrights, patents, and original documents, must be respected. Only the official use of software copies will be permitted.
• Accounting reports should reflect the entries of all credits and debits, not allowing any type of payment or receipt without registration.
• It is the Management and Financial Management’s goal to ensure the credibility of accounting and financial reports. Any attempt to undermine such credibility will be considered contrary to this Code and will be subjected to punishment according to its severity.
• Employees must condemn all actions that may be interpreted as anti-competitive, monopolistic, or contrary to local, national, or international laws that control competitive market practices. In case of queries in commercial processes, the company’s legal team should be consulted.

4.3 External Relationship

• Confidentiality of all the company’s strategic information must be maintained. Only authorized people can provide such information to third parties.
• Employees must not publicly criticize customers, competitors, suppliers, or other employees of the company.
• Employees must not practice acts of liberality at the expense of the company and shall not give or receive any type of direct or indirect personal advantage due to their positions (including lunches, tickets and/or trips).
• The company and its employees must not grant public entities, public employees or people occupying similar positions within the scope of their duties or for illicit favouring, any economical favour, such as money, presents, donations or any other favour, either directly or through third parties.

4.4 Use of Company Resources

• Company resources must not be used for any other purpose other than those defined by the company. It is not allowed to use property, equipment, business opportunities and company information systems or even their position for their own benefit or that of third parties, in detriment of the company’s interests.
• Employees, as well as their immediate family members, should avoid any business action or relationship that may create conflict between their own and the company’s interests.
• Employees must not have corporate involvement in askblue’s suppliers, clients, or competitors.
• Employees must not perform personal consultancy activities or technical assistance to suppliers, costumers and/or service providers.
• Employees must not engage in parallel activities that may conflict with working hours and/or their concentration in the workplace.
• Intellectual property of all programs, plans, projects, and software developed by the company belongs to askblue, even after the end of the existent contract.
• IT resources (computer, email…) shall not be used to disseminate emails or documents with indecent content, with a discriminatory or defamatory nature and rumours.

4.5 Social Responsibility

• askblue does not use child labour and does not purchase products or services from suppliers that knowingly make use of this type of resource, as well as those who keep workers in inhumane work conditions.
• askblue encourages its employees to participate in social activities, in volunteer work and any other type of activity which improves the community’s quality of life. Company donations can only be made after approval, following specific procedures.
• In addition to complying with the applicable environmental law, askblue promotes the rational use of natural resources, the preservation of the environment and recycling.

5. Transgressions and Penalties
The company’s administration and managers are responsible for ensuring full compliance with the Code of Ethics.

Upon becoming aware of conducts that are contrary to this Code, the employee must immediately inform the area manager or the company’s CEO.

All available channels can be used for the communication of transgressions: email, telephone, correspondence or personally to the company’s management.

The penalties applicable for non-compliance with this Code will be defined according to the severity of the transgression and may involve a warning, a suspension, a just cause for firing, or any other similar measures, according to the current legislation.

Practical examples/recommendations

a) Conflict of interests: consulting or being involved in askblue’s suppliers or competitors. Favouring the acquisition of products or services from companies whose owners have family/personal relations with askblue’s employees.

b) Sexual harassment: using the authority of the position to obtain sexual favours from a subordinate or someone at a lower level in the hierarchy.

c) Confidentiality: commenting on projects and internal company matters in open environments (airports rooms, restaurants, events…). Leaving documents with confidential information in printers (volume of business, products in development, company plans, reports…).

d) Moral harassment: the exposure of employees to humiliating and embarrassing situations, repetitive and prolonged during working hours while performing their job, being more common in authoritarian and asymmetrical hierarchical relationships, in which negative behaviours, inhumane and non-ethical relationships prevail, from one or more leaders to one or more subordinates, destabilizing the victim relationship with the workplace environment and the organization, forcing the person to quit their job.

e.g. Claiming credit for the ideas and work that belong to others, failing to recognize the merit of the results to whom they are entitled;
Employee’s public humiliation;
Giving someone tasks which are far below their capacity, done on a regular basis, with the clear purpose of demotivating them;
Treating subordinates with pejorative or derogatory terms.

e) Discrimination: Favouring people of a certain race or sex over others, not allowing equal opportunities for all employees. Making derogatory jokes about skin colour, physical disability, or sexual orientation.

Attachments
Attachment I – Universal Declaration of Human Rights
Attachment II – ILO Declaration of Philadelphia
Attachment III – The Ten Principles of the UN Global Compact