Compliance and LGPD

For compliance efforts to be achieved effectively and genuinely, the Company requires Third Parties (suppliers, service providers, consultants, business partners) to share the same principles that guide its business.

Here at Grupo SIMPAR, we have established a commitment to ethical, transparent and honest behavior that respects the law. This is a document for you, our third party. In it you will find:

• A set of rules of conduct, principles and values that we share here;
• Guidelines for establishing a healthy, transparent and sustainable relationship between us;
• The right channels for you to contact us.

You, as a third party, must disclose the rules of this Code to your employees, managers and any subcontractors, and to your own supply chain, ensuring that they are disseminated and fully complied with.

Important: after signing the "Term of responsibility" mentioned above, remember to send it by e-mail to the compliance sector at [email protected]. Thank you for your cooperation.

The Compliance Program has policies that define guidelines appropriate to the risks identified: 

• SIMPAR's Anti-Corruption Policy encompasses a set of policies that we believe are essential for effectively combating corruption:
  • Interaction with the Public Power
  • Participation in Bidding
  • Donations and Sponsorships
  • Gifts, Entertainment and Hospitality
• Disciplinary Policy
• Conflict of interest

Simpar manages its risks in a manner appropriate to its business, observing the criteria defined by a specific policy validated by the Board of Directors. The Risk Management Policy describes the stages of the management process for (i) identifying risk events, (ii) the instruments used for risk management, (iii) the organizational structure for risk management and (iv) the responsibilities of each of those involved, establishing limits for responsibilities according to the levels of risk identified.

Following the risk identification methodology, the internal control process is developed to support decisions with a higher level of security, reliability, efficiency and effectiveness, based on the objectives defined by the company, as well as its risk appetite. They are operationalized through a set of interconnected activities, plans, routines, methods and procedures.

Respecting your privacy and the safety of your information, we have updated our Privacy Policy, granting even more clarity and transparency on how SIMPAR treats personal data.

This Privacy Policy complies with the requirements of the General Data Protection Law (LGPD) and reflects SIMPAR's position of compliance.

If you wish to exercise your rights or have any questions, please feel free to contact our Data Controller directly. by clicking here.

SIMPAR acts ethically, with integrity and transparency, in line with its values. Here are some of the company's information and publications:

• Our Way Manual;
• Integrated Reporting;
• Reference Form;
• Get to know our Governance Structure and who are the members of Board of Directors and Audit Committee.

We share the certification obtained by the company, as well as the commitments made in relation to the compliance of our business. SIMPAR is committed to high ethical standards, transparency and integrity, providing trust and security to our clients and other third parties.

• Signatory to the UN Global Compact
  Launched in 2000 by the then Secretary-General of the United Nations, Kofi Annan, the Global Compact is a call for companies to align their strategies and operations with Ten Universal Principles in the areas of Human Rights, Labor, Environment and Anti-Corruption, developing actions that contribute to tackling society's challenges. It is now the largest corporate sustainability initiative in the world, with over 21,000 members in more than 70 local networks covering 162 countries. Ref. https://www.pactoglobal.org.br/sobre-nos/

SIMPAR respects diversity and human rights and promotes a professional environment in which everyone is and feels respected with equal conditions and opportunities. The company does not tolerate any form of discrimination and has official policies and reporting channels to curb any acts related to this issue.

To encourage the development and entry of women into the workforce of the companies and the Group's holding company, various programs and professional support actions are carried out throughout the group, including structured mentoring for the development of women's participation, for example. These practices have proved to be effective and are reflected in the consolidated growth of more than 80% in hires and more than 50% in women's promotions between January and September this year compared to the same period in 2023.

With regard to the number of women currently working for the company, we have:

• 56,59% of the Company's jobs;
• 57,14% of leadership positions (management and above) - the Brazil average is 38.8%.

In compliance with the Equal Pay Law (14.611/2023), the Company discloses the Transparency and Equal Pay Reports ("Report") relating to its various CNPJs.

The report is drawn up by the Ministry of Labor and Employment and, in the company's opinion, its methodology can distort the reality of salaries practiced in the company.

It should be made clear that Report does not allow modification, clarification and/or correction by the Company of any misrepresentation. An example of possible distortion occurs when there is a direct comparison of (i) the remuneration of employees at different levels (for example, manager and director, or senior analyst and junior analyst) and (ii) variable remuneration.

The MTE consolidated information from the Company's employee base in public records in 2022 and made statistical calculations using the following criteria:

• Median general basic salary;
• Average general remuneration (amounts received taking into account not only basic salary, but also variable amounts and other entitlements, such as overtime pay, commissions, etc.); and
• Average and median of positions held according to the classification indicated in the Brazilian Code of Occupations (CBOs), segregated into 10 (ten) major analysis groups.

Although the Report is published to comply with a legal obligation, the way in which the data is presented may not reflect the reality practiced at the Company, which has always complied with the rules on equal pay, encouraged development and valued people regardless of their gender.