1. Improve NDD’s relationships and increase the company’s culture of trust;
2. Establish ethical principles and standards of conduct that should guide NDD’s internal and external relationships;
3. Offer a source of information and guidance for all actions involving the company and the people who are directly or indirectly part of it;
4. Contribute to strengthening the corporate culture, focused on the company’s sustainable development.

• Work honestly and transparently. Balance among environmental, social, economic, and financial resources.
• Act with ethics, honesty, and sincerity in any situation. Our way of acting must in no way be conditioned by personal gains and advantages.
• Take care of NDD’s and our own personal reputation, acting ethically and morally. Conduct our activities with transparency, clarity, and accuracy.
• Our relationships with coworkers, partners, suppliers, customers, regulatory bodies, and public agents must be guided by best market practices and in accordance with legislation.
• Be aware that our decisions and actions influence the sustainable development of the communities where we operate.
• Respect the principles of free competition and not be complicit with actions that may discredit the image of competitors.
• Reinforce the commitment we have with the effective performance of our activities, rethinking attitudes and actions that may conflict with NDD’s objectives.
• We must not engage in external activities, whether paid or not, that compete with NDD’s interests.
• Inform your direct manager of any participation in companies that conflict with the company’s commercial, financial, or economic interests.
• Do not hire relatives or any person with whom you maintain a personal relationship as a subordinate or service provider, without prior notice to your direct manager and requesting authorization from the People and Management department.
• Conduct commercial negotiations involving the acquisition of products and/or contracting of services with impartiality, always seeking the best agreements for the company.
• When there are commercial transactions and any acts under our responsibility that include companies where relatives or people with whom you have a strong personal relationship work, inform this situation immediately to your direct manager.
• Do not allow parallel negotiations in purchasing processes. In case of sponsorships from suppliers for improvements, events for the team or for your own benefit, request approval from the Board of Directors.
• Do not use the prestige of your position at NDD and access to privileged information for your own benefit or that of others.
• Ethics above any business code is a matter of character. Applying ethics in all areas of our lives is the best way to build a balanced society, focused on common well-being.
• Condemn corruption in all instances, as well as the offering of undue advantages of any kind;
• Do not abuse power to obtain a favor or an undue advantage;
• Do not obtain an undue advantage or benefit, fraudulently, based on modifications or extensions of contracts signed with the public administration, without authorization by law, in the public bidding notice or in the respective contractual instruments.

Multiple relationships. Only one conduct. Take care of people, maintain an environment with mutual respect. The NDD code must inspire and guide our conduct so that we can act ethically and equitably in all our relationships.  “[…] We are a company of people, and they are responsible for our expansion.”

Valmir Tortelli

Value diversity and reject any act of discrimination, whether related to race, color, religion, sex, gender, political conviction, nationality, physical condition, among other topics.

Do not admit any form of embarrassment and intimidation, such as verbal, physical, or psychological violence, as well as any form of workplace and sexual harassment.

We forbid:

• Possession and use of illegal drugs and weapons (cold or firearms) on company premises.
• Consumption of alcohol on company premises.
• Smoking on company premises, outside permitted areas.
• Watching videos and TV shows as well as streaming non-work-related music/podcasts intensively.
• Use of NDD assets, facilities, and other resources (including computer, tablet, cell phone and any resource for accessing information, email, and internet) for personal purposes.

We have our own suitable environment, called “Giga”, where we allow leisure activities, such as games and get-togethers.

Exclusively at this location, the consumption of drinks is allowed at specific times defined by NDD, as long as it does not coincide with the employee’s working hours and compliance with the rules of coexistence, especially respect and moderation.

• Build a relationship based on trust, partnership, and respect with our partners, customers, suppliers, and service providers. Through regulatory standards such as: ISO9001 and ISO27001.
• Offer our customers high-quality services and products, fair price, and added value.
• Treat our suppliers and service providers equally and impartially, respecting the principles of free competition and considering the standards required by NDD.
• Do not adopt forced or child labor and demand the same conduct from our suppliers and service providers. Understand customer needs and indicate solutions that meet their interests.
• Before conducting any business or action, analyze the risks involved and mitigate them. Be impartial in decision-making, without prejudice or individual preferences;
• Do not receive any kind of gift, hospitality, donations, or similar benefits from suppliers that have not been agreed with management or the board of directors;
• Do not commit fraud in public bidding or the contract resulting therefrom.

• Maintain a relationship of respect and transparency with the press, protecting NDD’s image.

• No one without authorization should grant interviews or pass on information about NDD. All requests must be forwarded to the Marketing area.

• Conducting lectures, seminars, or academic papers about the company or its services and products without prior authorization from the company are prohibited.

• If you identify improper publication of information or news that affect NDD’s image, immediately notify the Marketing area.

• Privacy. Confidentiality.
• Fully commit to the pillars of information security: confidentiality, integrity, and availability.
• Follow the personal data protection principles established by legislation, both Brazilian (Law No. 13,709/18), and from other countries and regions where NDD provides its solutions.
• Develop new products and evolve our solutions in order to preserve data privacy and protection.
• Participate in training related to Information Security and Personal Data Protection legislation and if there are any questions, contact the company’s IMC (Integrated Management Committee).
• Do not make photocopies of NDD’s confidential data or documents as well as from its partners and customers.
• Data protection regulations are essential to guarantee the privacy and personality rights of everyone who interacts with our solutions. We collaborate for this purpose!
• PREVENT LEAKAGE OF INFORMATION
• Do not give or share your personal password to access the company’s system, even to other NDD employees.
• Respect the confidentiality of strategic information about our customers, business partners, suppliers, and service providers.

• Truth and integrity in all relationships. Attitude.
• Provide to others the information necessary for the performance of their functions or activities and guarantee the integrity of such information.
• We only commit to what we can accomplish and deliver. Take responsibility for every word said, every attitude (however small).
• A transparent relationship builds a trustworthy environment and benefits everyone, making our business more sustainable;
• Do not manipulate goals and results to gain undue advantage.

• Compliance with the Code of Conduct and respect for the business, mission, vision, and values is everyone’s duty.
• If each one takes responsibility and cares for them as much as possible, we will promote a fairer environment, providing opportunities for personal and professional growth, and strengthening the company’s image.
• Failure to comply with the Code of Conduct may result in disciplinary measures, administrative and/or judicial, civil, and criminal sanctions.
• We must report any conduct that does not comply with our code. You can report the situation directly on our Ethics Channel.
• Don’t be complicit! The information will be conducted with absolute confidentiality and the identity of the whistleblower will be protected.
• No retaliation or reprisal against a person who, in good faith, reports violations or suspected violations of this Code will be tolerated by NDD.

If you are unsure whether you are doing the right thing, answer the following questions:

• Is what I’m thinking of doing legal?
• Is my attitude impartial and honest?
• Will this action be questionable after a while?
• What is the impact of this conduct on the company?
• How will I feel afterwards?
• How would this look on the front page of the newspapers?
• What would I advise my children to do?
• How would I feel if my family, friends, and neighbors knew about it?

Reflect on what was experienced and share what you learned.