Conflict of interests

Decisions or actions that benefit private or individual interests, to the detriment of the interests of the SPIC Brasil group, may characterize a conflict of interest. Corporate decisions must always be taken according to what is best for the Company and not according to what suits the individual interests of an employee, third party, individual or legal entity. It is important to always be aware of situations that are or appear to be potential conflicts of interest.

Example:
An employee has the power to decide on the contracting of a certain service, and he chooses, among the proposals participating in the competitive process, to contract the company of a family member.

In this case, the employee’s family member company would not be prevented from participating in the competition. However, it is necessary that some requirements are met. For this situation, it would be necessary that the employee does not participate in the management of the contract if the company of his family member wins the competition.

Such restrictions are designed with the purpose of not exposing the employee to a conflict of interest, so that their actions are not questioned as to the absence of impartiality in decision making, either by favoring the company of their relative in the competition, or by granting benefits or ignore the same company’s failures in measuring the services provided.

Some situations in which there may be potential conflicts of interest:

• Existence of relatives in the same hierarchical reporting line or managing one another’s contract.

• Existence of close relatives in decision-making positions in government companies.

• Employee with a second job, especially if it is in a competitor company.

• Hiring companies from former employees.

• Existence of close relatives who influence the decision-making process in a competitive process.

• Employees with corporate participation in competing companies or suppliers.

Our management intends that situations like this do not happen; therefore, it is necessary for the company to be aware of these cases, so that it can take precautions and protect its employees, through appropriate controls.