Compliance.

Compliance and Ethics Actions

With the commitment to promote ethics in the business environment, 7COMm Group has been developing ongoing actions to comply with the laws, norms, standards and regulations established for our activities, as well as to improve the process of training, prevention, detection and treatment of non-conformities.

Our priority is to always act guided by integrity, ethics and transparency.

Code of Conduct and Corporate Ethics

Alongside our rejection of all forms of fraud and corruption, some of the guidelines guiding 7COMm Group ethical and integrity actions are present in our Code of Conduct and Corporate Ethics. The document (in existence since 2014) was updated in October 2021 in order to renew and reinforce the importance of the ethical dimension in our operations, recognizing the evolution of concepts and legislation that underpin integrity-related topics.

Prevention of Money Laundering and Terrorist Financing

We are committed to mitigating the risk of money laundering and terrorist financing in our operations by preventing 7COMm Group from engaging with companies that have received sanctions. As a result, we have established prevention, investigation and punishment guidelines consolidated in the group’s Anti-corruption Policy that should be used as parameters for the development of any business activities involving the group. In this way, we seek to contribute to a healthy, ethical and efficient financial system, in compliance with the law, as we consider these conditions essential for our economic and social development.

Integrity with Employees and Third Parties

7COMm Group has integrity rules for the relationship with collaborators and suppliers, such as business partners, sponsors, institutions and partner companies.

Conflict of Interests

7COMm Group establishes in its Code of Conduct and Corporate Ethics specific guidelines for prevention, identification and treatment of possible conflicts of interest existing in the company. In a preventive manner, it carries out a mapping of sensitive aspects in the personal and professional relationships of employees and administrators, and promotes orientation actions through activities such as workshops and online meetings, while also producing support material, such as videos and a booklet.

Communication and Training

With a view to internalizing and disseminating the commitments to ethics and integrity expressed in the policies and procedures of the Integrity Program, 7COMm Group promotes periodic communication and training activities for employees and other stakeholders.

The communication actions are intended to disseminate the integrity mechanisms implemented in the group’s companies and foster the culture of ethics and integrity, disseminating Compliance. They include the Code of Conduct and Corporate Ethics, the Anti-corruption Policy, the Good Practices Manual and guidance on topics such as fraud, corruption and conflict of interest, for the internal public and for third parties involved in the company’s activities. Among the ethics and integrity training actions carried out on a regular basis, we highlight the annual ethics and integrity training, done online, for all employees, which addresses the guidelines of the Integrity Program, and integrity training targeted at specific audiences, such as contract managers and inspectors, company managers, governance, risk and compliance teams.

Reporting Channel

7COMm Group has a Reporting Channel, where anyone can report violations or suspected violations of our Code of Corporate Ethical Conduct, our Compliance Program and anti-corruption legislation. We ensure the anonymity and confidentiality of the reports, as well as non-retaliation to the whistleblower. To access this, you can use the e-mail weare7@7comm.com.br or access the link https://bit.ly/3GxMOus.

Consultations and clarifications

Inquiries and clarifications of doubts about compliance actions must be forwarded by the e-mail weare7@7comm.com.br