Version 5 – June, 2015
Valid Soluções e Serviços de Segurança
em Meios de Pagamento e Identificação S.A.
CNPJ nº 33.113.309/0001-47
Companhia Aberta
Rua Peter Lund, 146 . São Cristovão
CEP 20.930-390 . Rio de Janeiro . RJ
INDEX
INTRODUCTION
02
VISION, MISSION AND VALUES
03 RELATIONS
04
Employees
04
Suppliers
06
Customers
06
Competitors
07
Shareholders
07
Community
07
Press and Disclosure Information
07
Government
08
Environment
08
ETHICS AND CONDUCT COMMITTEE
09
INFRACTION OF CODE, POLICIES AND PROCEDURES
09
AGREEMENT AND COMMITMENT TERM
10
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INTRODUCTION
Dear colleagues,
Respect for our clients, colleagues, shareholders, suppliers, society and everyone who deals with Valid is,
without a doubt, one of the characteristics that make this brand so well-recognized on the market.
In the code you have in your hands, we have assembled a series of principles, policies, procedures,
instructions and practices that should serve to guide our daily decisions. You should be a champion for
values such as honesty, integrity, commitment and respect for people throughout all of the company’s
areas. In addition to fulfilling our legal obligations, we must exemplify a conduct consistent with the trust
that has been placed in us.
I am certain that you are able to conduct yourself in line with the principles contained in this code, and,
because of this, I ask for your full attention when you read it. You can be sure that our quality management
system team and your direct leader are always available to chat, exchange ideas and clear up any doubts.
Valid also has an active Ethics and Conduct Committee. Its representatives are available to you, especially
for guidance in any situation where there has been a violation of this code or of the guidelines contained
in our corporate documentation. You, as an employee of Valid, have a duty to report anything that goes
against business conduct, making use of the available channels of communication.
To conclude, my wish is that Valid will continue to grow in a sustainable manner for many decades to come.
And this is made possible when we transform words printed in documents such as this one into behaviors.
Happy reading, and keep up the good work!
Carlos Affonso S. d’Albuquerque
CEO Global
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VISION
MISSION
VALUES
Vision
To be the best partner of security services in methods of payment, telecommunication, digital certification and identification
procedures in the countries where operates.
Mission
To be present daily with our customers offering the best local call, bringing technological solutions in a certain manner and
creating relationships of trust.
Values
Results and excellence
The purpose of the people’s work is to increase the company’s efficiency, which is measured by the profit it generates in its
operations. The search for excellence must be continuous and permanent.
Integrity and trust
Since we work with confidential data and security products, we maintain a high standard of ethical integrity. The trust of our
customers is our main asset.
Quality in service provision
We work so that our customers never have to seek another supplier and to always offer the best service.
Simplicity and creativity
Our manner to do things is simple and informal, aiming to reach quickly the substance of issues. We always seek creativity and
original manners to achieve goals.
We value our team
We believe that success is proportional to the quality of our employees, and we aim to have the best talent who believe in our
values with us. We intend to treat everyone with respect and dignity, and fairly and appropriately remunerate them.
Merits and rewards
People are valued for their contribution and ethical standard. Therefore, we reward all employees, at all levels, by this criterion.
We believe that work should be an important source of individual achievement.
3
RELATIONS
Employees
The business strategy of Valid is guided by issues related to sustainable development. The most important is the ethical
treatment aimed at working relationships with employees; with which we are committed, prioritizing dialogue in the workplace
as a critical component.
Valid believes that social responsibility begins at home and, thus, keeps the encouragement and development policies for those
who are responsible for the company’s credibility.
We legitimize and respect the rights of employees and their relationship with the organization, based on trust and loyalty,
essential to keep our purposes. We make efforts to offer a safe and healthy workplace, with freedom of expression related to
integrity and people’s privacy, and do not tolerate any kind of threat, harassment or intimidation.
All employees are responsible to know and respect laws and national/international standards, as well as internal procedures of
the company.
A. Child Labor
Valid does not engage or support the use of child labor. We may adopt a minor apprentice in our framework for work according
to the law, pointing out that we should not expose ourselves to situations in or outside the workplace that may be hazardous,
unsafe or unhealthy.
Valid undertakes to promote repair actions if it finds this fact by providing financial support and/or other actions as may be
necessary; as well as the requirement for a remedial action plan, if this will be seen at its suppliers, which will be subject to
cancellation of approval, if the action plan with appropriate repair measures is not submitted.
B. Forced or Compulsory Work
Valid does not engage or support the use of forced or compulsory labor and does not engage human trafficking.
We do not require from our employees any kind of ‘deposit’ or retain identification documents to keep them in the company. We can
not commit employees to work periods as reimbursement of training courses that they were subsidized by the company.
C. Health and Safety
Valid provides a safe and healthy workplace and take appropriate measures to prevent accidents and health injury, encouraging
its employees to take a responsible attitude regarding to labor health and safety.
D. Freedom of Association and Right to Collective Negotiation
Valid respects the right of all employees to form and join trade unions of their own choice and to negotiate collectively.
E. Discrimination
Valid does not engage or support discrimination in hiring, compensation, access to training, promotion, termination of contract
or retirement based on race, social class, nationality, religion, disability, sex, sexual orientation, family responsibilities, marital
status, union membership, political affiliation, age or any other condition; being part of the company policy to hire people with
special needs.
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F. Disciplinary Practices
Valid does not engage or support the use of corporal punishment, mental or physical coercion, psychological or verbal
abuse, committing to exercise authority in an ethical manner, ensuring mutual respect between employees, not allowing any
threatening, abusive, sexually, coercive or exploitative behavior in the workplace.
G. Working Hours
Valid complies with applicable laws on working hours and should not normally exceed 44 hours per week allowed. Employees shall
have, at least, one day off in every seven-day period, and all extra work shall be paid at a premium rate in accordance with the current
legislation and/or Collective Labor Agreement.
H. Compensation and Development
Valid ensures that wages paid for a standard working month meets the minimum standards of the class, also ensuring that the
benefits are paid in full compliance with applicable law and in a convenient manner for its employees.
Valid also stimulates the self-development offering to all equal opportunity for development and professional growth, based on
effort, performance and personal skills.
I. Information
Valid is committed to communicate and disseminate the company policy to all employees, aiming to ensure that its activities
are conducted ethically, consistently and with quality.
J. Representatives
Valid has several representatives who have committed themselves to honor the principles of the company in an ethical, honest
and responsible manner, not disclosing information without the prior consent of the company, promoting the image, reputation
and interests of the company, in addition to facilitate the communication between the high management and employees without
suffering any retaliation or discrimination.
K. Receipt of Gifts and Participation in Events
Employees of Valid shall not offer or accept gifts, favors or economic benefits of any kind that may be correlated with any type
of negotiation; except promotional and small commercial value gifts.
L. Financial Loans
Employees of Valid shall not require or lend to people working in or for the company. The company has policy of lending through
financial institutions, in accordance with current legislation.
M. Relationship of Parentage
Hiring relatives of employees may be considered, provided they are evaluated and compete for jobs in similar conditions to
those of another candidate without this set any kind of advantage. In case of no parentage between employees within the
company, it shall not be allowed to act in the same work area, nor be permitted relation of subordination between them.
N. Company Heritage/Intellectual Property IFacilities, equipment, machines, materials, files and information created, received or
stored in electronic systems are property of Valid and should be used by employees in a responsible manner for work purposes only.
The intellectual property rights are respected, the transfer of technology and know-how is carried out to protect the intellectual
property rights of Valid and stakeholders (customers, partners, suppliers and employees).
O. Information Electronic Systems
Valid provides computing resources for the performance of functional tasks. Its use for personal matters is permitted provided it does
not conflict with the internal rules, or harm the progress of the work. Exchanges, disclosure, access, storage or use of any obscene,
pornographic, violent, discriminatory, racist, libelous, defamatory material, or that infringes any organization or individual content are
prohibited.
P. Other Activities
Valid does not allow that political, religious or professional activities not related to your employment, are carried out within
the working environment, so as not to interfere with professional responsibilities and, much less, with involvement of material
resources, personal or equipment of the company in these activities.
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Suppliers
The selection and hiring of suppliers should be based on technical, professional and ethical criteria through use of unbiased and
fair processes, without privilege or discrimination of any kind.
Suppliers are encouraged to improve their relationship with society and their own employees, as well as to seek continuous
improvement in productivity and processes in order to promote and ensure competitiveness and longevity of the business
partnership.
Audits in the suppliers should be adopted as a way to verify the compliance with terms of this code as applicable to it.
A. Child Labor and Forced or Compulsory Labor
Valid does not engage or support the use of child or forced/compulsory labor and reserves the right of not hiring services or
maintain business relationships with companies that adopt this practice.
B. Confidentiality
Confidential information acquired from employment or business relationship existing with Valid should be treated responsibly
and ethically, and the use has to be exclusive to the development of activities and services provided to the company.
C. Conflict of Interest
Valid does not allow the provision of goods or services by company(ies) which professional(s), partner(s) or representative(s)
have family bonds with administrator(s) or officer(s) of Valid, acting in a user or contractor area, or in a position that can directly
or indirectly influence the decisions’ making.
D. Product and Service Quality
Valid undertakes to provide necessary information and criteria to guide suppliers and contribute to the qualification of the
products and services’ supply within the quality standards established by the company.
E. Copyright
Products and systems developed by the company or suppliers to the company are owned by Valid, being prohibited its sale or
transfer to third parties without permission.
Customers
Customer satisfaction is the reason for the success of our company. Efforts must be made to identify what is perceived as “value”
by Customers, establishing any and all actions that may transform these values into mutual profitable realities, supported in
long-term relationships.
The promptness and responsiveness to Customers are fundamental to the company’s image, and are the employees’
responsibility to respond all Customer questions and clarify the company policies with transparency and respect.
The rules of fair business, goodwill, publicity and competition must be observed.
A. Dialogue
Valid provides communication channels for Customers to express their opinion and undertakes to respond within preestablished deadlines under a satisfactory standard.
B. Product and Services Quality
Valid undertakes to seek continuously the improvement of the products and services quality offered through constant
technological innovation, fulfilling legal requirements, specifications and demands of Customers for production of it.
C. Confidentiality
Valid guarantees the confidentiality of secret information passed to it by its customers and partners.
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Competitors
The relationship with the competitor must be respectful. Competition should be seen as healthy and reference source for new
challenges, promoting the improvement and continuous innovation.
Comments that could affect the image of competitors or contribute to the dissemination of rumors about them should not be
made.
It is not allowed to deal with people related to competition on issues of any nature that may affect the interests of Valid out of
association environments.
Shareholders
The perpetuation of the company and the search for results should be made within an ethical attitude in business, and Valid
undertakes to protect the assets and the company’s image, through continuous assessment and risk management of the
business.
The relationship with the shareholders must be based on accurate, transparent, clear and timely information to enable them to
monitor activities and performance of the company through the councils and assemblies - statutory arrangements constituted
for both.
Unofficial information related to financial results or participation and equity movement should be ignored and neutralized in
order to avoid influence in the staff, general market and/or shareholders.
A. Confidentiality
Valid guarantees the confidentiality of registration and movement of shares information under its responsibility, unless in need
of obedience to legal provision.
B. Conflict of Interest
Employees are not allowed to advise purchase or sale of shares, or use information that is not public domain to influence
the share price on the market, or benefit themselves, directly or indirectly, from information received in the course of their
functions.
Community
Valid values and encourages its employees, either personally or representing the company by performing volunteer labor for
the benefit of the community.
Community practices that shall benefit the personal interests of directors or officers of Valid over institutional interests should
not be adopted.
Press Relations and Information Disclosure
Only the president or persons authorized by him/her are able to give interviews, make statements, answer corporate researches,
etc. to the press in general and other organs on behalf of the company.
The relationship with the constituted powers should be based on mutual and unconditional respect for the current law; besides
being offered for public inspection bodies with all facilities and conditions to fulfill their functions.
7
Government
Valid respects laws and authorities of all levels of government. Providing information to all levels of government should always
be made by written protocol and with proper guidance from the legal department.
A. Corruption
Valid prohibits the performance of any payment, gratuity or offer of benefit to public officials for any advantage, speed up routine
services or administrative actions that result in harm to any constitutional principle that guides the actions of government.
Valid does not authorize or approve any request, demand, charge for itself or others, of an undue advantage, or promise of
undue advantage in exchange for influencing an act carried out by private and/or public agents expressing, also, that no fee,
money or any other object of value may be paid, offered, given, or promised by any of its agents or employees, directly or
indirectly, especially but not limited to, any:
(i) political or official party, or any candidate for political office;
(ii) representative to act for or on behalf of any state or parastatal entity;
(iii) person with an engaged position, job or function in any public or private body, even if temporarily or with no payment, in
order to:
(a) exercise undue influence over any public authority, in an official, corporate or commercial capacity;
(b) induce any public authority to perform or fail to perform any act against its statutory duties;
(c) induce any public authority to use its potential influence before the public, direct or indirect administration, to affect or
influence any act or decision of their responsibility;
(d) obtain any improper advantage or to be contrary to the public interest or business ethics.
B. Communication
Valid reserves the right to speak publicly about policies and government decisions that may affect the progress of business and
relationships with employees, customers or shareholders.
Environment
Attitudes regarding the environment have the respect for nature, legislation care, prevention and reduction of environmental
impacts as a priority.
Programs and projects should be developed in order to obtain the commitment of people, improvement of processes and
application of appropriate technologies aimed to sustainable development.
The international standard ISO14001 shall be adopted as a reference in the environmental management.
Valid values the rational use of natural resources, and the FSC® certification strengthens this commitment.
8
ETICHS AND
CONDUCT
COMMITTEE
The Ethics and Conduct Committee is as follows:
• HR Superintendent
• HR Manager
• Legal Manager
• An HR representative of each unit
The Ethics and Conduct Committee has the responsibility to:
• Develop, review and monitor compliance with this Code;
• Guidance regarding the implementation of this Code;
• Promote its disclosure;
• Disseminate appropriate conduct standards for the company;
• Propose penalties to the presidency when verified infraction of principles established;
• Collect and gather infringement allegations of the Code of Ethics and Conduct;
• Propose and organize meetings of the Ethics and Conduct Committee;
• Prepare meeting agendas, distributing it to the members of the committee;
• Present detailed analysis of such transgressions;
• Propose punishment under Brazilian labor legislation;
• Prepare and promote resolutions of the Ethics and Conduct Committee in the channels of communications of the company.
INFRACTION
CODE,
POLICES AND
PROCEDURES
Violations to the provisions described in this code, as well as non-compliance with policies, procedures and instructions
approved and in force constitute an infraction of ethics.
The results of internal audits, certifying body audits, public agencies’ audits, process monitoring and other control mechanisms
may suggest the breach of ethics at the criterion of the Ethics and Conduct Committee.
Violation of the code, policies, procedures and instructions of the company is subject to disciplinary penalties, regardless of
hierarchical level, with no loss to the applicable legal penalties.
When the situation requires, the employee shall notify the Ethics and Conduct Committee or directly to any of its members; and
may also communicate it by letter (Av. Presidente Wilson, 231 - 16º andar – Centro – Rio de Janeiro – CEP 20030-905) – for the
attention of the Ethics and Conduct Committee - and also by email (comite.eticaeconduta@valid.com.br).
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AGREEMENT
AND
COMMITMENT
TERM
CODE OF ETHICS AND CONDUCT, Valid S.A.
I, ____________________________________________________________________________________,
enrollment:_______________________, employee of the group of companies VALID SOLUÇÕES E SERVIÇOS
DE SEGURANÇA EM MEIOS DE PAGAMENTO E IDENTIFICAÇÃO S.A., declare that I:
• Received hereby a copy of the “Ethics and Conduct Code”;
• Know the full content of the Code and I am in full accordance with its rules, which read and understood, and
undertake myself to fulfill faithfully for the entire duration of my employment;
• Know that I must report any violation of this Code to the Ethics and Conduct Committee knowledge;
• Know that the Ethics and Conduct Committee shall examine infractions of this Code, suggesting penalties
to the competent bodies;
• Know that penalties suffered may even result in my termination as staff of the organization, notwithstanding any civil or criminal liability.
_________________________ of ____________
______________________________________
Employee Signature
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