Lean Sales

Lean Sales Code of Ethics and Conduct

To all our employees and customers...
Our conduct builds our history

Every day, our journey is shaped by committed individuals who act with passion, integrity, and dedication, driving both their own success and that of our clients. We believe that a company's sustainable growth is only possible when there is unity, mutual respect and action based on ethical principles and compliance with the law.

In order to strengthen this organizational culture based on ethics, transparency, respect and responsibility, this Code of Ethics and Conduct brings together clear guidelines that guide our behavior and decisions in all professional activities.

More than just rules, these guidelines reflect the values we practice every day and which underpin our reputation. We are convinced that the way we act is as relevant as the results we deliver.

The ethical principles established here are fundamental to the way we conduct our business and demonstrate our commitment to acting with integrity, respect, and responsibility.

We invite you to get to know, understand and apply this Code in your daily life, actively contributing to a fairer, more ethical and collaborative working environment.

Jorge Dalfovo - CEO Lean Sales

Our mission

We help IT companies develop business acceleration strategies, through strong partnerships, aimed at delivering the highest levels of value and results.

Our vision

To be a reference and authority in the IT market regarding commercial acceleration strategies and new business development.

Our values

Ethics | Simplicity | Innovation | Performance | Partnership | Humanism | Diversity

Purpose of the Code of Ethics and Conduct

The purpose of this Code is to consolidate the principles and standards of conduct that guide Lean Sales' activities, promoting an organizational culture based on ethics, responsibility, professionalism and mutual respect.

It guides the decision-making and behavior of everyone involved in the company’s operations, reinforcing Lean Sales' commitment to transparency, corporate responsibility, and excellence in internal and external relationships.

Although it does not cover all situations that may involve ethical dilemmas, this Code establishes guidelines that must be observed in any circumstance, acting as a reference for acting coherently and responsibly.

Who is it for?

The Standards of the Code of Ethics and Conduct apply to all directors, executives, employees, service providers, and other stakeholders who interact with Lean Sales, regardless of their hierarchical position or area of activity.

Read, understand, and comply
Speak up
Act with integrity
Make a commitment
Raise questions and express concerns
Help and cooperate

Making good decisions and acting ethically generate trust among ourselves and in the relationships with the people we interact with

However, not all the situations you encounter are simple, do you agree?

Although this Code does not tell you exactly what to do in every situation, it serves as a guideline to help you make good decisions and deal with complex situations in which the answer may not always be clear. 

Don't forget to stop, reflect and ask questions.

Lean Sales principles

Our professional and social conduct is based on a set of principles that strengthen the relationship between Lean Sales and its customers, suppliers, partners, employees and civil society.

Respect | Dignity | Inclusion

We treat everyone with respect and dignity, without discrimination of any kind.

We believe that a diverse and inclusive work environment is essential for success and innovation.

We value the contribution of each individual and seek to create an environment where everyone can thrive.

Don't tolerate. Don't participate. Report it.

Lean Sales prohibits all forms of discrimination, harassment, humiliation, threats of violence and abusive or offensive behavior. 

The terms "discrimination" and "harassment" include discrimination in any form and sexual, racial and ethnic, moral, gender, religious beliefs, age, sexual orientation, physical conditions, among others. 

These behaviors are considered serious acts of misconduct and may subject you to disciplinary or legal action.

Zero tolerance of harassment in all its forms

Lean Sales has a zero tolerance policy towards harassment, whether moral, sexual or of any other nature. Any behaviour that amounts to harassment will be investigated and treated with the utmost seriousness.

All employees have the right to work in an environment free from harassment and intimidation. It is everyone's responsibility to prevent, identify and report any form of harassment.

Our conduct matters

Based on ethical values, Lean Sales adopts an Integrated Management Policy, which depends on everyone’s commitment for its maintenance and continuous improvement.

Part of this relates to our conduct in the workplace and the way we manage our relationships within the organization.

At Lean Sales , all employees are invited to work with us and have the option of accepting or declining the job offer. All vacancies are advertised on channels where anyone interested can apply.

Lean Sales reserves the right to only hire employees with complete documentation submitted prior to the date of hiring, in accordance with local legislation, as well as those with legal status in the country in the case of foreigners.

Knowing our codes and policies brings us closer to the Lean Sales culture and makes it easier to understand the roles we must assume in the organization.

Dress code

Lean Sales values the professional image of its employees, understanding that the way we present ourselves in the workplace conveys respect, professionalism, and commitment.

Appropriate clothing is an important component of personal branding and contributes directly to building a reputation aligned with the company's values.

For this reason, it is recommended that everyone wear attire suitable for the corporate environment, always prioritizing good judgment and professionalism. Styles that are incompatible with the workplace context should be avoided, especially in situations involving clients, partners, or corporate events.

With the aim of harmonizing the dress code in the workplace, we recommend wearing the corporate T-shirt during working hours and at all representative company activities.

Each employee will be provided with two t-shirts, in accordance with the collective agreement. Additional items may be purchased upon request and payment of the corresponding amount.

You are responsible for the proper care and use of the parts supplied. This will reflect our commitment to the image and values we cultivate at Lean Sales.

Disciplinary measures

The company may impose disciplinary measures in the event of breaches of the rules. Before disciplinary action is taken, the employee will be instructed and, depending on the seriousness of the offense, the disciplinary measures applicable are:

  • Verbal warning evidenced;
  • Written warning;
  • Suspension;
  • Unjustified dismissal;
  • Dismissal for cause.

Alcohol and drug policy

Lean Sales is concerned about health and safety in the workplace. It is forbidden to attend or remain in the workplace, at events or in any activity related to Lean Sales while drunk or under the influence of illicit drugs. The consumption of alcoholic beverages is restricted to social events, as long as it is in moderation and does not influence any behavior. According to Federal Law 9.294/69, the use of cigarettes and similar tobacco-derived products is prohibited indoors. Lean Sales adopts the same measure, i.e. smoking is not allowed on company premises, including electronic cigarettes.

Statement of knowledge and commitment

I declare that I have received, read and fully understood the LEAN SALES Code of Ethics and Conduct. I undertake to observe and comply with all the rules and guidelines set out therein, acting ethically, responsibly and in accordance with the applicable legislation.

I am aware that failure to comply with these rules may result in disciplinary measures and legal liability.

I acknowledge the signature by electronic, digital and computerized means as valid and fully effective to legitimately manifest my will and confer legal validity to this contract, which consists of an extrajudicial executive title, for all legal purposes, even if the signature is made without the use of a digital certificate issued in the ICP-Brasil standard, under the terms of art. 10, §2º, of Provisional Measure nº 2.200-2.

Personal data protection and privacy

At Lean Sales, we respect and protect the personal data of all employees, customers and partners. We follow our privacy policy to ensure the security and proper handling of personal data.

Confidentiality

All Lean Sales employees must maintain strict confidentiality regarding any confidential information they may have access to as a result of their professional activities. 

This includes strategic, commercial, technical, financial, personal data, or any other type of non-public information related to the company, its clients, or partners.

The duty of confidentiality remains in effect even after the termination of the employment relationship and is essential for preserving trust, business integrity, and the reputation of Lean Sales.

Whistleblower Channel

Lean Sales values open and transparent communication of ethical concerns and reports of misconduct. 

Our aim is to ensure a fair working environment where everyone can communicate their concerns without fear.

Whistleblowing policy

Anyone can submit a complaint, report or concern, provided that they have reasonable grounds to believe that the report is true and that it is made without malice or personal benefit.

How do I submit a complaint?

The channel is available to employees, suppliers and customers, ensuring that all concerns can be reported safely and dealt with confidentially and impartially.

Complaints can be made via e-mail: conduta@leansales.com.br

Anti-corruption conduct

We are proud of our reputation and do not tolerate unethical practices of any kind, as well as any favors, bribes, payments of any amount of money and the distribution and/or receipt of gifts, products, presents or entertainment, in order to obtain advantages in decisions or use influence to maintain business.

Therefore, Lean Sales employees, suppliers and service providers must undertake to adopt measures to combat corruption in all its forms, including the payment or receipt of undue advantages of any kind (bribes) either in your name or on behalf of Lean Sales. If you are offered or ask for a bribe, you must immediately refuse and report it.

Protection against retaliation

Lean Sales guarantees that no whistleblower will suffer retaliation for reporting a concern in good faith. Retaliation can include dismissal, harassment, discrimination or any form of punishment. 

If anyone believes they have been retaliated against, they should report it immediately so that appropriate measures can be taken.

Intellectual property

Lean Sales values and protects its assets of intellectual and industrial property, including, but not limited to, trademarks, patents, copyrights, industrial designs, codes, methodologies, technical materials and any creations developed in the context of its activities.

All employees must respect these rights, ensuring that they are not reproduced, misused, disclosed or shared without proper authorization.

Likewise, it is essential to fully respect the intellectual and industrial property rights of our clients, partners and third parties, especially when confidential or protected information is accessed in the course of business relations.

It is forbidden to use, copy or distribute any material protected by intellectual or industrial property - whether from Lean Sales or third parties - without express authorization or without a specific contractual provision.

Work and its journey

Working hours at Lean Sales respect the limit of 44 hours per week, and Lean Sales decides how to structure them according to the sector within the company. The working hours of trainees and young apprentices respect the legal limit. 

Punctuality must be prioritized in relation to working hours, meal times, meetings and other commitments. Exceptions in special situations must be communicated to the immediate manager.

Remember to clock in, out, during lunch or dinner breaks and any early departures, which must be authorized by your immediate superior using a specific form.

According to current labor legislation, employees who are in management positions recognized by the company and characterized by greater autonomy, decision-making power and positions of trust, are exempt from time recording and overtime pay.

attention: the exemption from time control does not eliminate the commitment to the company's objectives and values. So carry out your activities with responsibility, balance and respect for Lean Sales' guidelines.

Time allowances and compensation

In order to comply with current labor legislation, Lean Sales adopts the legal tolerance of up to 10 (ten) minutes a day in the working day, distributing this time in up to 5 (five) minutes at the entrance and 5 (five) minutes at the exit, without this constituting lateness or overtime.

Important: This tolerance cannot be used as a way of offsetting hours within the same day, for example, coming in early and leaving early. Offsetting working hours requires another type of formal control.

Lean Sales does not use a bank of hours system.

Maintaining respect for these established schedules reflects the commitment of each one of us to discipline, organization and collective responsibility.

Overtime

Overtime is not permitted, unless the need is proven by express authorization on a specific form. 

The authorization must be signed by the immediate leader for the employee to stay outside of working hours. 

Employees are not allowed to stay at the company outside of their working hours without proper authorization. Work done outside of working hours without prior authorization is not considered overtime because it was not required by the company.

Absenteeism

Avoid being absent during working hours, except in urgent cases. If you need to leave during working hours, let us know.

Unjustified absences and delays may be deducted from the payroll. The possible justifications for absences are those authorized by law and duly proven, and no other reason or justification will be accepted.

Medical certificates and allowances

Original medical certificates must be delivered to the company within 2 days of the absence, or by the day of return to work for certificates longer than 2 days.

All certificates must contain identification stamp of the issuing professional, with full name and CRM number, as well as the corresponding legible signature.

Certificates that do not contain these items, that have been submitted after the deadline or that contain erasures may be invalidated. Exceptions may be made for exceptional and duly justified cases.

Deliveries should be made to:

Rio do Sul: must be delivered to the People and Management department or to the Finance department if the former is not present.

Itajaí: should be delivered to Ruan or John, and in their absence, to the Endomarketing department.

Benefits

Lean Sales ensures that all employees receive the benefits determined by current legislation and the rules of the collective bargaining agreement applicable to their category. 

Any additional benefits that go beyond what is provided for by law or collective bargaining agreement will be granted on a complementary basis and will be duly regulated in the respective internal policies.

Only benefits that are formally communicated by the company through official channels and in accordance with its policies will be considered valid. 

Employees should always consult the specific guidelines for each benefit to understand their eligibility criteria, how they can be used and any conditions for maintaining or canceling them.

Assets and resources

When using Lean Sales assets and resources, such as corporate cell phones, notebooks, desktops, printers, projectors and office supplies, employees must be aware of their responsibility to take care of them.

Use must be for strictly professional and non-personal purposes and always in accordance with the guidelines of this Code. 

It is forbidden to use the Internet, corporate e-mail, computers or other equipment for illegal, unethical or inappropriate purposes, such as playing games, accessing pornographic sites or disclosing unauthorized information.

All messages distributed via the e-mail system are the property of Lean Sales, so if the company deems it necessary, e-mails may be monitored without prior notification. 

All extensions used for negotiations or customer service, suppliers and service providers are recorded, and calls are stored for at least 5 (five) years, in accordance with legal requirements and best market practices.

As already mentioned, Lean Sales believes that employees should devote themselves exclusively to professional activities during working hours. 

It therefore communicates transparently that corporate data may be accessed for the sole purpose of analyzing, confirming or investigating issues related directly or indirectly to the company.

All IT resources made available by the company must be used rationally, with a view to maximum use and conservation.  

Every employee must keep copies of the work they produce in order to ensure the security of the information they use each month.

Computer desktops should display the standard operating system theme or company logo. Employees who have access to the internet should use this resource wisely.

Before sending e-mails to external parties about matters pertaining to the company's activities, employees must ensure that they are authorized to deal with the subject matter.

Networks and social media

The use of social networks during working hours is restricted to professional needs or institutional campaigns. 

We must always act responsibly when representing the company on social media. Do not disclose confidential information about Lean Sales or its stakeholders.

Avoid associating personal activities with the Lean Sales brand or compromising your image in online posts.

Any communication on behalf of the company must be authorized in advance. It is crucial that personal and professional boundaries are respected in all forms of digital communication.

Affective relationships

Lean Sales respects employees' freedom to maintain emotional relationships and family ties in the workplace. 

However, it is essential that these relationships do not generate conflicts of interest, as provided for in the company's internal policies.

It is expected that issues of a personal nature will not interfere with the professional routine. Public displays of affection and private discussions should be avoided in order to preserve a respectful, productive work environment that is aligned with the organization's values.

Conflict of interest

Conflicts of interest occur when an employee's personal interests interfere or appear to interfere with the interests of Lean Sales.

It is crucial that all business decisions are made objectively and in the best interests of the company, without undue influence from personal interests.

Identification of conflicts of interest

A conflict of interest can arise in the following situations:

  • Business relationships: if you or a member of your family has a significant financial interest in a competitor, customer or supplier of Lean Sales;
  • Personal interests: participation in external activities that may interfere with their responsibilities in the company or that compete with the interests of Lean Sales;
  • Affective relationships: Personal relationships with coworkers, especially if they involve direct or indirect subordination, should be reported to HR to avoid favoritism or harm to objectivity in the work environment.

Procedures for managing conflicts of interest

  • Communication: inform your immediate supervisor and the Compliance department of any potential conflict of interest situation;
  • Assessment: the Compliance department will assess the situation and determine the appropriate measures to mitigate or eliminate the conflict;
  • Documentation: all disclosures of conflicts of interest and the measures taken to resolve them must be formally documented.

Gifts and entertainment

In the corporate environment, it's natural to receive invitations to lunches, dinners or sporting events from people or companies that maintain or wish to maintain business relations with Lean Sales. 

Similarly, it may be necessary, on behalf of the company, to offer hospitality to clients, suppliers or other strategic partners.

To guarantee the integrity of business relationships and avoid any appearance of undue favoritism or conflict of interest, all Lean Sales employees must follow clear principles of ethical conduct when dealing with gifts and entertainment, whether in interactions with the public or private sector. Here are some guidelines to help you:

Accepting gifts and entertainment

No soliciting
Never solicit or demand gifts or entertainment of any kind. This includes any kind of advantage.

Conditional acceptance
Only accept unsolicited gifts or entertainment if they are a simple courtesy and a common and acceptable business practice.

Appropriate context
Gifts or entertainment should only be accepted in the normal course of business and must not be excessive or lavish.

Registration
Record all gifts and entertainment events received to ensure transparency and compliance.

Offering gifts and entertainment

Appropriate and ethical
Only offer gifts or entertainment when it is appropriate and does not create the impression of influencing the recipient's decision.

Reasonable value
Gifts should be of symbolic value, and entertainment should be modest. Extravagant or inappropriate items are prohibited.

Business context
Entertainment should take place in an environment where business discussions can take place before, during or after the event.

Approval
All offers of gifts and entertainment must be approved by the line manager.

Registration
Register all gifts and entertainment events offered to ensure transparency and compliance.

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