1. Introduction

The Code of Conduct of ASAE SERVIÇOS ELÉTRICOS LTDA reflects the values and principles that must guide the conduct of all its professionals, both in internal activities and in external relations in the exercise of their functions.
Considering the current scenario of demand for greater governance and transparency from public and private institutions, it becomes essential that our actions are based on high standards of ethics and integrity.
This Code plays the role of aligning the criteria adopted by the Company, strengthening professional ties, and promoting employee engagement, creating an environment based on mutual respect, organization, transparency, and harmonious coexistence.

2. Scope

This Code applies integrally to partners, employees, interns, trainees, and service providers (collectively referred to as “Members”) in all their interactions related to the Company.

3. Fundamental Ethical Principles

The actions of the Company and its Members must be guided by the following fundamental principles:
i. the preservation of the highest standards of suitability and integrity;
ii. equality before the law;
iii. the exercise of professional activity with courtesy and efficiency;
iv. conduct compatible with constitutional principles, with the precepts of current legislation, internal norms and regulatory acts, and provisions of this Code;
v. the protection of human rights and dignity;

In the performance of their functions, Members must respect the general precepts of morality, legality, ethics, transparency, and loyalty, maintaining such posture in relations with colleagues, clients, and authorities.

ASAE SERVIÇOS ELÉTRICOS LTDA and its Members do not condone any illegal or unfair practices carried out by its clients or third parties linked to them.

4. Specific Ethical Principles

In addition to the fundamental precepts, Members must respect the following specific ethical principles:

4.1 Absence of conflict of interest
Before starting any new project or commercial negotiation, Members must ensure the absence of conflict between their interests and those of the Company or its clients.

4.2 Corporate spirit and mutual collaboration
Members must pursue the collective objectives of the Company in the exercise of their functions, not prioritizing personal interests over institutional ones, in order to ensure the Company's general interest in the work performed.

4.3 Confidentiality
All information and documents accessed by Members due to their duties or provided by clients must be treated as confidential. Even if not expressly confidential, data and content that could cause embarrassment must not be disclosed. Client projects must not be discussed outside the professional context.

4.4 Transparency
The posture of Members must be guided by clarity, objectivity, and transparency, except in cases where legislation imposes restrictions or confidentiality.

4.5 Commitment to copyright
The Company values the scientific production and innovation of its members but demands strict observance of copyright and intellectual property in all its terms.

5. Relations with Government and Regulatory Bodies

Members, in interactions with agents representing public bodies or entities controlled by them, must act with total transparency and always observing the applicable legislation and the ethical principles established in this Code, without any form of promise or concession of advantages or privileges.

6. Relations with Partners, Suppliers, and Employees

ASAE SERVIÇOS ELÉTRICOS LTDA is committed to the quality of its contracts and partnerships, understanding that this relationship is based on the development of co-responsible and complementary actions to meet the needs of its Members.

Only the formalization of partnerships or contracting of suppliers and employees who operate with ethical standards compatible with those of the Company will be permitted.

7. Relations with Competitors

The Company understands that competition must be fair, based on ethical principles and in accordance with applicable norms and legislation. Members must always maintain respect for companies, liberal professionals, and companies that provide services similar to those provided by it.

8. Anti-corruption and Anti-Money Laundering Legislation

Compliance with this Code will be based on the following legislations:

• Law No. 12,846/2013 (Anti-Corruption Law);
• Law No. 8,429/1992 (Administrative Improbity Law);
• Law No. 7,492/1986 (Crimes against the Financial System);
• Law No. 14,133/2021 (Bidding and Contracts Law);
• Decree-Law No. 2,848/1940 (Penal Code),
  In addition to other national and international norms regarding the practice of acts against public administration, anti-corruption, and anti-money laundering.

The following conducts are expressly prohibited:
a) Offering or granting undue advantage, directly or indirectly, to a public agent or third parties, with the intention of obtaining benefit for oneself, for the Company or its clients;
b) Giving or offering facilitation to public agents aiming to accelerate, delay or favor procedures;
c) Intermediating payment of undue amounts or advantages to public agents or people related to them.

9. Implementation of the rules of this Code

All rules provided in this Code will be widely disseminated among Members and made available on the Company's official website, and can be consulted by clients, partners, suppliers, and interested parties in general. Any complaints and/or claims arising, from external or internal sources, related to non-compliance with the guidelines established in this Code, will be addressed to any of the Company's capital partners, who will be responsible for investigating the occurrence and, in conjunction with the other capital partners, applying the appropriate penalties.