Code of Conduct and Ethics

1. OBJECTIVE

This Code of Ethics aims to establish behavioral standards and determine issues related to (i) compliance with coexistence rules in the workplace, without distinction of hierarchy, areas, or functions; (ii) transparency of operations in general; (iii) the safety of the activities of the professionals involved; and (iv) the security and confidentiality of information that must be protected.

Furthermore, it provides ATHMADI collaborators with an understanding of the anti-corruption law and respective regulations. It also serves as an effective tool for adequacy and prevention, guiding collaborators, employees, and third parties interacting with the company to identify conflicts and infractions that may be considered illicit practices.

2. INTRODUCTION

ATHMADI is a company operating in the Information Technology segment, aware that the success and continuity of its business are directly related to the orientation of ethical standards and sustainable management, so that the impact of its actions results in a balance between social, economic, environmental, and corporate governance aspects with all its stakeholders.

Fundamental Principles:

• Dignity and Respect: Recognizing, accepting, and not discriminating against gender, social class, ethnicity, divergent opinions and beliefs, and always preserving physical, moral, and psychological integrity.
• Rejection of Harassment: Zero tolerance for any abuse or harassment, whether moral or sexual.
• Fair Work: Rejection of any labor exploitation action.
• Legality: Compliance with internal policies and all applicable legislation and regulation.

3. SCOPE

The Code of Ethics includes conduct guidelines based on ethical and moral standards that will serve as a reference for the behavior of all collaborators, internal and external, that is, members of the ATHMADI staff in the exercise of their functions, including service providers, suppliers, and business partners.

4. WORK ENVIRONMENT

The Institution fosters a work environment with respect and dignity, does not allow any type of discrimination among its Collaborators, and is committed to actions and policies to ensure fair job opportunities.

Cooperation and teamwork are great allies of our culture. Our work environment is pleasant and favors courteous relationships between people. Therefore, we respect individual freedom and treat every individual with dignity.

5. WHISTLEBLOWING CHANNEL

ATHMADI prohibits retaliation against anyone who reports, participates, or collaborates with any investigation. If you believe you are suffering retaliation, contact us immediately.

All reports received will be investigated and, if confirmed, will lead to corrective or punitive measures. All investigations are confidential.

6. ETHICAL PRINCIPLES

6.1 Abuse, Harassment, and Discrimination

Respect for others is a premise taken seriously. We do not tolerate moral or sexual harassment, discrimination based on color, race, creed, gender, sexual orientation, or age – or any other type of abuse.

6.2 Use of Alcohol, Drugs, Weapons, and Violence

We encourage physical, emotional, intellectual, and social balance. The possession or use of illegal drugs in our environments is prohibited, as well as the possession of weapons and violent acts.

6.3 Corruption Prevention

ATHMADI conducts its business with honesty and integrity, in compliance with anti-corruption laws. It is prohibited to offer, promise, give, or accept any undue advantage.

7. GENERAL CONDUCT RULES

• Preserve and cultivate the positive image of the Company;
• Treat people and their ideas with dignity and respect;
• Proceed with loyalty, justice, and frankness in work relationships;
• Preserve the well-being of the community and the privacy of each one;
• Use ATHMADI resources only for Company interests;
• Do not verify and/or present information that does not reflect reality;
• Prioritize and preserve ATHMADI interests with clients and partners;
• It is forbidden to exercise any type of discrimination;
• It is forbidden to use ATHMADI proprietary information for personal benefit;