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CODE OF CONDUCT
CODE OF CONDUCT
CODE OF CONDUCT

1. OBJECTIVES

The Code of Conduct of CARAVELA-COMPANHIA DE SEGUROS, S.A., hereinafter referred to as CARAVELA, is an integral part of the Corporate Governance System.

It is configured as a repository of fundamental values and principles, rules and procedures, which should inspire and guide CARAVELA's activity, both from its employees, from a moral and ethical point of view, both in its internal relationship and in interaction with the abroad, namely at the level of the distribution network, policyholders, claimants, reinsurers, and other external entities, to consolidate an institutional image of honesty, transparency, responsibility and sociability.

This code also seeks to contribute to the proper application of the General Data Protection Regime, following its Article 40 and the internal rules prepared by CARAVELA on this topic.

The amendment to Art. 127 of the Labor Code, contained in Law no. 73/2017 of 26 August, concerning the prevention and fight against harassment at work is included.

2. SCOPE

The Code of Conduct applies to all CARAVELA employees.

3. CONTENT

3.1 VALUES

As an Insurance Company, CARAVELA's core activity consists of the safety of people, translated into the guarantee of income or levels of enjoyment through quality solutions compatible with sustainable development.

A framework of values was built, to achieve the social purpose on which CARAVELA's employees should operate, without prejudice to strict compliance with the current legal and normative framework, which can be systematized according to the following chapters:

a) Innovation
The constant search for a response to new market needs and the consequent creation of new products is encouraged, with a view to Marketing Oriented to satisfy customers fully.

b) Credibility
CARAVELA's acceptance is necessarily based on the trust that its stakeholders and public opinion in general place in its performance and integrity. This trust will depend on the personal conduct and the ability of its employees to jointly transmit to their interlocutors an idea of honesty and morality regarding the decisions made and the attitudes taken.

c) Professionalism
CARAVELA's employees must act, both internally and externally, in a professional manner, analyzing each situation in detail, to find ways of shared solution that without hurting the contractual obligations in presence may deserve the consensus of all interested parties.

d) Valorization of Human Resources
Being that people are a critical success factor of a company, this implies that CARAVELA establishes Human Resources policies adjusted to each reality, contemplating, among other components, the continued professional valuation of its employees, providing each one with knowledge and behavioural acquisitions, which increase their technical capacity and ethical sensitivity.

e) Team spirit
Teamwork is an essential requirement for the pursuit and achievement of the objectives defined by the organization. Achieving this goal is only possible if a strong spirit of solidarity is established among the elements that make up the company's human capital, tending to a robust Corporate Culture record.

The following guidelines compete decisively for the Company's Culture:

➢ Matters should be shared across the board, encouraging everyone to participate in their approach and discussion, sharing the merit of the solution found by the stakeholders in the process;

➢ Unequivocal understanding that individual merit or demerit has a positive or negative impact on achieving the objectives defined for each Department, with obvious repercussions on CARAVELA's overall performance.

➢ The manifestation of total availability to hear or respond to any requests for help and clarification;

➢ Valuation and dissemination of records, emphasizing good practices.

3.2. RELATIONSHIP WITH CUSTOMERS

The Client is the core element of the insurance activity, and the person is embodied in the quality of the client. Like this,

a) The client/person must be treated in a fair, correct, transparent and urban manner through clear language without prejudice to technical rigour;

b) Clients' difficulties, doubts, concerns or suggestions should be carefully assessed to evaluate whether the questions presented are thorough and responsive, granting the benefit of the doubt to the interlocutor and seeking to correct any maladjusted procedures;

c) CARAVELA must carefully analyze the complaints that may be presented to it as a way to diagnose any blockages or insufficiencies in the organization to overcome them;

d) CARAVELA must provide secure means of sending and receiving complaints, namely providing accessible lines in terms of Information Technologies.

3.3 RELATIONSHIP WITH AGENTS AND BROKERS

As the Distribution Network is the privileged vehicle for placing CARAVELA's products, appropriate conditions are created to achieve this objective, with permanent maintenance of spaces for constructive dialogue with the Networks, namely:

a) Partnership relationships must be judiciously cultivated to establish enduring bonds of intimate collaboration, feelings of belonging and sharing of results.

b) When sharing results, not only the quantitative aspects of the portfolios in question should be considered, but also qualitative elements correlated with productivity and profitability.

3.4 RELATIONSHIP WITH SUPPLIERS

CARAVELA must privilege the relationship with external providers that, in addition to providing them with quality products/services and competitive economic and financial conditions, move by criteria of professionalism, suitability and transparency. In this context, it is up to you:

a) Select your suppliers based on transparent and impartial criteria, punctually fulfilling the commitments made to them, requiring reciprocal treatment from you;
b) Choose those whose operating principles are in line with their own, namely those that concern the confidentiality of the information and good practices in terms of competitive commercial actions.

3.5 GENERIC GUIDELINES

CARAVELA recognizes the freedom of expression and opinion of its Employees, in compliance with the rules provided for in this Code of Conduct.
Employees enjoy the right of reservation and confidentiality of the content of messages of a personal nature and access to information of a non-professional nature that they send, receive or consult, namely by email, without prejudice to the rules for the use of these means, defined by CARAVELA.

In this context, all Employees are obliged to:

a) Comply with the rules and regulations applicable to the insurance activity;

b) Comply with the internal rules of CARAVELA, namely its Policy of Treatment of policyholders, insured persons, beneficiaries and injured third parties and in particular, those concerning the exercise of the function that each competes with;

c) To develop its functional activity within the strict limits of the autonomies that have been granted to it;

d) To base its performance on criteria of high moral posture without prejudice to quality and technical rigour;

e) Refrain from engaging in activities that are socially objectionable or that may conflict with the performance of your duties at CARAVELA, namely:

➢ Subscription of contracts contrary to the accepted rules in force at CARAVELA;


➢ Economic/financial involvement with Clients and intermediaries that determine or have determined, among others, movements in the insurance portfolio;

➢ Acceptance of commissions, donations, or any other material advantages that are not merely symbolic;


f) Observance of the duty of confidentiality that inhibits the use of available information due to the functions performed, outside the scope and for purposes that are not exclusively professional.

g) Use the available CARAVELA equipment and services (computers, telephones, internet, etc.) only to serve the functional assignments inherent to the functions performed.

OBSERVATIONS:

1) It is prohibited to use said equipment and services effectively or potentially if harmful to CARAVELA.

2) It is forbidden to remove or place any types of software and data in CARAVELA's computer equipment, without prior express authorization.

h) To guarantee during the work period the full functioning of the organic unit to which they are assigned, even during their absences or impediments, even if momentary, using the mechanisms provided for their replacement;

i) Report superiorly - when they go beyond the scope of their autonomies - situations or episodes that prevent an efficient response to circumstances arising from standard functional actions;

j) Not to engage in activities that may mislead business partners, or the market itself, through the dissemination of false or misleading information, as well as by carrying out fictitious operations;

k) Availability to make statements in court, as a witness, concerning facts considered relevant, for the defence of CARAVELA's interests and of which they are aware, due to the functions they exercise;

l) Non-intervention in the appraisal and decision of operations in which they are directly or indirectly interested in their relations or persons.

m) Identify and report to your hierarchical superior any situation of exercising external business activities, which may cause conflicts of interest;

n) Report alleged cases of harassment at work, which, if confirmed, will be subject to disciplinary proceedings by CARAVELA.

o) Provide the existence of adequate conditions for the establishment of a pleasant working climate, encouraging the participation and involvement of all in the approach, discussion and resolution of social and professional matters, enhancing the creation of a real team spirit and feeding the Culture of Company.

3.6. SPECIFIC GUIDELINES ON PERSONAL DATA SECURITY

Following the measures recommended in the General Data Protection Regime, CARAVELA undertakes to adopt security measures and protection of data privacy in the scope of:

a) The process of collecting personal data;

b) Internal procedures to mitigate or eliminate undue exposure of personal data;

c) Information that can be provided to the public and the Holders of personal data;

d) The exercise of the rights of the data subjects;

e) The information provided related to the protection of children;

f) The processing of personal data, in a secure, transparent and fair manner;

g) CARAVELA's responsibilities, as an information controller, to protect its legitimate interests and to be able to demonstrate that the information processor complies with this General Protection Regime;

h) Notification of possible breaches of personal data that justify, due to their level of risk, their communication to both official entities and their respective owners;

i) The procedures for resolving any disputes with data subjects, concerning the processing of information not following this General Regime.

3.7. SPECIFIC GUIDELINES ON CORPORATE DATA SECURITY

The set of corporate data includes the personal data of employees who are resident in Caravela's computer equipment.

Given the risks inherent in the improper disclosure or loss of these corporate data and especially those that are more critical, employees are subject to specific duties, such as:

a) Professional secrecy regarding all information, including that made available electronically, of personal and professional elements and data to which they have access in the function they perform and in the quality of users assigned to them;

b) That of not addressing the information by telephone or cell phone, whenever unauthorized persons are present to obtain that information;

c) Take extra care in the transportation of corporate data, by any means, including paper or mobile devices (CMP, Mobile Phone, Pen,…) and report CARAVELA's loss in a timely manner;

d) The employee must be aware that, whenever he uses the information resources provided by CARAVELA (electronic mail, internet, telephone, mobile phone, etc.), it must be conducted on an ethical and professional basis.

CARAVELA reserves the right to issue specific regulations on the privacy of corporate data, defining access to corporate information, its disclosure, sharing, transport and storage, as well as the control procedures to be followed by employees and the right they have to access your data held by CARAVELA.

4. FINAL PROVISIONS

CARAVELA will ensure the necessary disclosure of the rules contained in this Code of Conduct, so that its content is fully assumed by its recipients, as a set of rules that binds everyone, and any violation of what is available may be subject to disciplinary appraisal under current legislation.

5. REVOCATIONS

On this date, Service Communication No. 06/2016, version 1.0, of 06/21/2016 is revoked.

Approved on: 2017/11/24
PLT - Policy 01 - 00/2017