EN 
BR 
ES Letter from the Vice President
The contemporary world undergoes constant transformations daily, and with it, people, groups, and organizations. These transformations stem from events in human history responsible for paradigm shifts and technological advancements that present us with new challenges. Absolute truths are giving way to new possibilities, new models of interaction and management, and new experiences. It is clear that the transformations that drive the world are caused by people and for people. Innovation can be seen as a direct consequence of the innate desire to always serve the population well, whether through products or services.
That said, it's no secret to our more than 2,600 direct employees that the history of the Passenger Division companies has been built on values such as trust, ethics, safety, respect, innovation, and sustainability in the provision of its services. Seven decades later, we remain increasingly focused on the strategic pillars that have brought us this far and will continue to help us expand our market presence.
However, our purpose is not only to move our clients, but also to offer quality services. We seek to provide our clients with satisfaction and loyalty through what we offer. And all this is based on our commitment not only to ethics, safety, and respect, but also to transparency and integrity.
Therefore, in order to offer the best experiences to our audience, as well as in our relationships with regulatory bodies, state entities, suppliers, and society as a whole, we understand that it is fundamental to improve our corporate governance and integrity practices. In this sense, the Code of Ethical Conduct is a tool that will propel us forward, as it defines the principles and standards that need to be observed and put into practice in our professional routine.
To ensure compliance with this document and to carry out any necessary investigations, the Passenger Division of the Águia Branca Group has an Ethics and Integrity Committee, and we are committed to ensuring the confidentiality of communications received, as well as a thorough investigation of any suspected violation of this Code.
We are facing an important moment for our company, formalizing the guidelines and disseminating the ethical and integrity standards we desire. This is a challenge for all of us. We count on the commitment and responsibility of each member of our team.
We're counting on you!
Renan Chieppe
Vice President of the Passenger Division
The Passenger Division of the Águia Branca Group is composed of the following companies:
Viação Águia Branca SA
Águia Branca Transportes SA
Companhia Viação Sul Bahiano – SULBA
Lynx Vehicle Trading Ltd.
Recreational, Sports and Cultural Association Águia Branca
Squad Viagens e Turismo Ltda
Squad Tech Technology and Services LTDA
Agaxtur Travel and Tourism Agency SA
Flex Serviços Ltda
We Safety Technology and Services Ltd.
Agência Um Viagens, Turismo e Eventos Ltda
Purpose
Moving the world forward with excellence and respect for people.
Of the Principles
Honoring its commitment to providing the best road passenger transport services, or, within its portfolio, the best travel and tourism agency services, events, communication and related services, and always aiming for integrity and respect in its activities, all employees of the Passenger Division, including its Senior Management and other stakeholders, adhere to this Code of Ethical Conduct which, without prejudice to others, is based on the following principles:
Ethics:
Ethics guides actions and decisions through the ability to act with integrity and honesty in all personal and professional relationships.
Equality:
Equal and non-discriminatory treatment for all employees, customers, suppliers of goods and services, members of the Passenger Division Board of Directors, investors, and other business partners.
Responsibility:
To ensure the proper use and conservation of the assets of the companies that make up the Passenger Division, taking care of them and using them responsibly and exclusively for work purposes, while also being mindful of environmental care and basing their conduct on sustainability.
Legality:
To guide its actions in compliance with current legislation, always seeking the best practices with its internal and external clients, suppliers, as well as regulatory bodies and other state entities, paying attention to any legal norms that may apply to each situation.
Impersonality:
The conduct of Senior Management, employees of Passenger Division companies, and other stakeholders must comply with established goals and policies and ensure corporate ethics and integrity, including with regard to personal interests.
Advertising:
Committed to ensuring a Policy of Integrity and Transparency with its Board Members of the Passenger Division, Senior Management, Employees, Collaborators, Suppliers, Partners and other entities that may have relationships with the companies of the Passenger Division, this Code of Ethical Conduct will be made public on the companies' websites and other channels used, to all those who have a relationship with the companies, at any time requested or when necessary, so that its rules are followed and practiced in all areas.
From the Introduction to the Code of Ethical Conduct
The Code of Ethical Conduct brings together guidelines for conduct based on ethical and moral standards that will serve as a benchmark for the behavior of all employees, both internal and external. Its application is mandatory for all members of the workforce of the Passenger Division companies, in the performance of their duties and/or while representing or identifiable as employees of the Passenger Division companies, including service providers, suppliers, and business partners linked to the Companies.
The Code of Ethical Conduct presented in this document indicates duties and expected behaviors in the workplace, outside of it while representing or identifiable as employees of the Passenger Division companies and/or in institutional relations with the Public Authorities, in commercial relations carried out between the Passenger Division companies and third parties, facilitating the application of the commitments disseminated by the companies.
This Code of Ethical Conduct may be revised and/or supplemented at any time, in which case the changes made must be published through available means for the information of all those to whom this Code may apply.
Target Audience
The content of this Code of Ethical Conduct applies to:
To the members of the Board of Directors of the Passenger Division;
To Senior Management – Board Members, Presidents, Directors, including those of controlled companies if applicable;
To the employees of the Passenger Division companies, including their interns, apprentices, managers, and employees of contracted companies;
Those natural or legal persons who are acting or providing services on behalf of or for companies in the Passenger Division;
From the Norms of the Code of Ethical Conduct
a) Duties to Clients and the Community
To offer high-quality, safe, and reliable road passenger and freight transport services, and, where applicable to the respective company within the Passenger Division, to offer fair, well-defined, safe, and beneficial travel and tourism agency services to clients, attentive to the innovations of the digital age and respecting the legislation pertaining to each mode of transport, as well as to offer corporate event promotion and communication (live marketing) services, mindful of ethics, good practices, and anti-corruption policies;
To offer dignified, courteous, fair and equitable treatment, respecting the interests and rights of consumers;
To safeguard, in accordance with the law, the rights of its clients;
To provide clear, reliable, timely and efficient information to customers, always striving to serve them in a dignified and helpful manner, including addressing their complaints through the appropriate channels;
To encourage interaction between customers and companies, considering, as far as possible, their feedback and suggestions for developing improvements and new solutions, with a view to delighting the customer and driving the company towards excellence in its mission;
To ensure, as an institutional pillar of data protection, the confidentiality of information provided by customers through data acquired via applications, call centers, agencies, websites, HR departments, or any other means of interaction with companies, whether digital, telephone, or in person, respecting the provisions of the General Data Protection Law – LGPD (Law No. 13.709/2018).
To promote a cooperative, pleasant, and balanced relationship environment with the client in order to delight and encourage them to always choose the companies in the Passenger Division as their first options for road passenger and freight transport and/or travel and tourism agency services and/or corporate event promotion and communication (live marketing).
Respect the fulfillment of agreements and contracts.
To identify, propose and implement innovative and integrated solutions that contribute to the continued use of services provided by companies in the Passenger Division;
To establish fair and balanced relationships with the community through encouragement, promotion, support, and participation in social responsibility and citizenship initiatives.
To encourage, support, and participate in government actions aimed at social development and combating poverty, in accordance with current legislation.
To collaborate with the authorities, whether police or administrative, in requests made by such entities when done within the applicable legal norms, seeking a transparent, collaborative and peaceful relationship regarding the procedures initiated by them.
b) Duties of the Members of the Board of Directors of the Passengers and Investors Division
The Board Members of the Passenger and Investor Division will base the management of the companies on the principles listed in this Code of Ethical Conduct.
Members of the Board of Directors of the Passengers and Investors Division will be guaranteed the provision of transparent and timely information.
The Board Members of the Passenger Division must ensure that the financial statements are prepared in accordance with the law and with accounting principles and standards, in order to fairly represent the results of operations, cash flows, equity positions and finances of the companies.
The Members of the Board of Directors of the Passenger Division must ensure that the companies in the Passenger Division adopt internal procedures and controls aimed at ensuring, within applicable legal standards, the detail, accuracy, and transparency of the financial statements.
The Members of the Board of Directors of the Passengers and Investors Division will adopt best practices and conduct to ensure that business management is carried out in accordance with and in respect of this Code of Ethical Conduct.
The Members of the Board of Directors of the Passenger and Investor Division will repudiate, at all levels, at all times and in all forms, in a strong and unwavering manner, any illicit practices such as, but not limited to: bribery, extortion, corruption, kickbacks, money laundering, financing of terrorist or criminal acts, receiving stolen goods or goods not permitted in Brazilian territory, misappropriation of company funds for personal enrichment, use of private information for individual benefit, unauthorized sale of confidential information to third parties, facilitation of contracts to obtain illicit advantages and/or any other type of illegal/immoral/unethical activity or activity that goes against the principles followed by the companies.
c) Duties and obligations of Senior Management, Employees and Collaborators
To ensure the establishment of a dignified and healthy work environment, basing relationships between superiors, subordinates, peers, and colleagues on respect and cordiality.
It is the responsibility of Senior Management, Employees and Collaborators to provide a diverse work environment in which all those involved, regardless of their origin, color, gender, race, religion, age, physical disabilities, sexual orientation, nationality, political opinion, union affiliation, ethnic or social origin, are guided by mutual respect;
Conduct that may constitute moral or sexual harassment or discrimination of any other nature that constitutes any form of disrespect, including towards diversity, intimidation, threats or persecution in the relationship between employees, regardless of their hierarchical level, is not tolerated, nor is the use of derogatory and/or derogatory nicknames towards colleagues and partners.
We do not tolerate any form of forced labor, slavery, or child labor. We respect the legal criteria for young apprentices.
Respecting freedom of association and unionization, and seeking to reconcile the interests of the Passenger Division companies with the interests of employees and their representative bodies in a transparent manner, with negotiation as a continuous and priority practice.
To comply with the provisions contained in the collective bargaining agreements that govern the relationship between the company and its employees.
Comply with current legal regulations and those issued by national and international bodies (as applicable) and competent state entities regarding the provision of collective road passenger and freight transport services and travel agency services.
To ensure that employees receive information relevant to their privacy, as well as the confidentiality of this information, except in cases provided for by current legislation and where applicable.
The information, methodologies, and technologies owned by the companies in the Passenger Division are confidential and for exclusive internal use, and it is the responsibility of everyone to maintain due confidentiality. The disclosure of any restricted information, methodologies, technologies, and/or data is prohibited, except with prior and express authorization from the Director responsible for the data.
Do not discuss or work with internal information, especially confidential and/or strategic information, in public areas, taking the utmost care to ensure that this information is not exposed in any way on portable electronic devices such as cell phones/tablets or similar objects that could allow viewing/knowledge by third parties. Do not disclose, without authorization from the companies, by any means, promotional campaigns or any other type of campaign, calls, recruitment announcements, advertisements, projects, etc., before the scheduled deadline.
The Passenger Division guarantees the right to freedom of expression to the recipients of this Code of Ethical Conduct, as guaranteed by the Federal Constitution, and does not support any form of restriction on this right, noting that the exercise of such freedom is accompanied by the responsibility of each individual regarding their form of expression and conduct in internal and external work environments.
Those who are subject to this Code of Ethical Conduct must base their behavior on social media or other forms of electronic communication, as well as their daily conduct inside and outside the business environment, in a dignified, honorable, and respectful manner towards everyone, observing the ethical and integrity principles adopted by the companies, aiming to preserve and respect their image, assets, and interests.
Internet use is permitted only for authorized individuals, and only on websites that do not compromise the integrity of the system and network. Access to any page containing offensive, illegal content, or content unrelated to work, such as pornography, illegal goods sales, gambling, or similar sites, is prohibited. The use of the internet and technological tools must follow the guidelines of the Technology Department of the Águia Branca Group.
The dissemination of strategic professional information on the internet is expressly prohibited.
The creation and maintenance of social media networks (Facebook, LinkedIn, Instagram, etc.) and pages on behalf of the companies in the Passenger Division are the exclusive responsibility of the Internal and External Communications and Sales areas.
Follow all company guidelines regarding the use of equipment and work tools that may be available to Senior Management, Employees and other collaborators, acting diligently and cautiously in order to preserve the assets under their care and the internal and external image of the companies.
To present oneself appropriately for the performance of one's duties and activities within the company, in accordance with current company guidelines;
The use of uniforms and badges is intended for identification and access to company premises. Uniform use may be waived on days and/or occasions previously defined by the companies. Directors, Superintendents, Managers, Lawyers, and Coordinators are exempt from mandatory uniform use. Badge use is mandatory in companies that use them or are required to do so by law, and is more flexible depending on the specific nature of a given company.
Regarding the use of uniforms, the employee is responsible for:
Use properly, only for its intended purpose;
Avoid wearing your company badge and/or uniform outside of work hours in external environments that could negatively associate the company's image and brand with you;
To be responsible for the safekeeping and preservation of the uniform, and not to alter or modify its form, shape, or nature;
Avoid wearing your ID badge (when used) and/or corporate uniform outside of work hours in external environments that negatively associate the company's image and brand;
In the event of termination of any employee's contract with the companies, the uniform and respective ID badge must be returned to the employing company at the time of signing the Termination of Employment Contract;
Depending on the nature of a given company's activity within the Passenger Division, it may adopt a specific uniform/dress policy, provided it is appropriate to the corporate segment to which it belongs and that good customs, ethics, and morals regarding dress code are maintained within its market scope, in order to preserve the company's image and reputation.
When required for the position and in accordance with current legislation, the Employer will also provide PPE (Personal Protective Equipment), the use of which is also mandatory, and the precautions described above apply to it.
Employees, service providers, or others who provide services in direct customer service are required to wear the uniform of their respective company. For employees in purely administrative roles, uniforms may be waived, but smart casual or casual attire is recommended, such as dress pants, jeans, skirts, dress shirts or polo shirts, and dresses, along with dress shoes or casual shoes. Inappropriate clothing that may suggest or have sexual connotations, cause embarrassment to others, or provoke unnecessary discussions related to politics, religion, or sports is prohibited.
Employees are prohibited from attending company premises or events scheduled by the company if they show signs of intoxication or are under the influence of any psychotropic substance that causes chemical dependency.
It is unacceptable for an employee to be caught driving a vehicle while showing signs of intoxication or under the influence of any psychotropic substance that causes chemical dependency, even during vacation or time off, given the incompatibility of such conduct with the core business of companies and with current legislation.
The consumption of alcoholic beverages or psychotropic substances that cause chemical dependency is prohibited on company premises or, even in external environments, while identifiable as a company employee, except, with regard to alcoholic beverages, at events where the company management permits it, the consumption of alcohol in a moderate manner may occur, always in accordance with current legislation, with the exception of employees who, during or after the celebration, will still be performing professional activities.
At events aimed at professional drivers hired by the company, the offering and consumption of alcohol is prohibited.
The resources of companies within the Passenger Division may only be used for purposes that are in the interest of those companies.
When traveling for business, during activities in which the employee is representing the company, they must behave appropriately, both inside and outside the workplace, in order to reinforce the company's positive image.
It is the duty of every person, driver and/or pedestrian, on company premises, to respect the speed limit and all other traffic signs, as well as safety guidelines and/or internal circulation rules. Likewise, all persons must park and drop off/drop off passengers from their vehicles only in permitted areas and use only one parking space. Visitor parking, when available, should not be used by employees.
Companies will seek to encourage and stimulate the self-development of employees with a view to excellence in fulfilling the missions, values and visions of the companies, through internal and/or external training/courses suitable for the performance of their activities in the organization.
Companies will encourage the sharing of knowledge and experiences, through all means that prove to be appropriate and legitimate, seeking to improve technical skills, methods and processes, in order to achieve better overall results for the companies;
Companies will promote the recognition and appreciation of the intellectual capital of their employees and encourage the emergence of new leaders;
Companies will value and encourage ethical conduct, both individually and collectively.
All recipients of this Code of Ethical Conduct must respect the diversity of all people, clients, internal or external, who interact with companies daily, guided by the principles of tolerance, courtesy, dialogue, and legal norms as indispensable values in their dealings with each other, with clients, suppliers, government entities, and any other third parties.
All recipients of this Code of Ethical Conduct must repudiate, at all levels, at all times and in all forms, in a forceful and unwavering manner, any illicit practices such as, but not limited to: bribery, extortion, corruption, kickbacks, money laundering, financing of terrorist or criminal acts, receiving stolen goods or goods not permitted in Brazilian territory, transportation of unauthorized persons or goods, misappropriation of company funds for personal enrichment or that of third parties, use of private information for individual benefit, unauthorized sale of confidential information, facilitation of contracts to obtain illicit advantages and/or any other type of illegal/immoral/unethical activity that goes against the principles followed by the companies.
It is the responsibility of any person, upon becoming aware of any conduct condemned by this Code of Ethical Conduct, to report it through the appropriate channel provided by the companies, with the anonymity of the whistleblower guaranteed.
Never claim personal benefits or advantages for yourself or for third parties as a result of a commercial or financial relationship established on behalf of any of the companies in the Passenger Division, whether with clients, government agencies, financial institutions, suppliers, entities or other companies.
Receiving commissions or benefits of any kind from clients or any third party that maintains a commercial relationship with companies in the Passenger Division is prohibited.
Outsourcing work for competitors in any segment of the Passenger Division and/or work that involves the transfer of knowledge, technology, documents, and methodologies from the companies to third parties is not permitted, unless covered by specific contracts.
Not to be complicit or negligent regarding errors and violations of this Code of Ethical Conduct and current legal and regulatory provisions, and to report them appropriately through the available channels.
Do not allow and/or encourage the harassment of employees, suppliers, or any individuals related to the companies, whether vertically or not, regarding any matter.
There is no impediment to the admission/promotion/internal transfer of relatives or individuals who have an affective relationship with an employee of the Passenger Division; however, the candidate should avoid occupying a position that reflects hierarchical subordination to the employee with whom they maintain an affective relationship or family bond.
Influence on the recruitment and selection process area for the admission of individuals with whom one has kinship or an affective relationship will not be permitted without full compliance with the selection process and other rules of the Passenger Division.
Candidates who have a family relationship or romantic connection with an employee of the Passenger Division will be evaluated without any preference and under the same conditions as other internal and external candidates.
The existence of a family relationship and/or romantic relationship between employees must be immediately reported to the manager responsible for the area.
It is the employee's duty to inform their immediate supervisor of any professional, kinship, or romantic relationship with suppliers, service providers, public officials, clients, or competitors of the company.
It is the employee's duty to inform their immediate supervisor of their shareholding, regardless of the degree or purpose (including affiliates), in any company, especially those contracted to supply products or provide services to the Passenger Division.
Notwithstanding the fact that Senior Management, Employees, Collaborators, Suppliers, and others related to the companies in the Passenger Division are free to hold their personal political and partisan positions, no political or partisan activity will be permitted within the company premises.
If any employee engages in political party activity, it must always be conducted outside of company premises, in a personal capacity, and in a way that does not interfere with their professional responsibilities or link such opinions to company activities.
Political party or candidate advertising of any kind should be avoided on vehicles circulating on the premises of Passenger Division Companies, so as not to link one's preferences to the company's image.
It is forbidden to attach or hang stickers, buttons, brooches, or any other type of accessory or adornment belonging to candidates on their uniform and/or badge.
It is the responsibility of senior management to consider the socio-environmental impacts when planning activities, business operations, and management practices.
It is the responsibility of senior management in companies to encourage the socio-cultural and sporting initiatives of their employees;
It is the responsibility of senior management in companies to encourage the contracting of product and service providers that have integrity/governance policies.
The use of influence by any employees in decisions of the Passenger Division companies that result or may result in personal gain or gain for third parties and/or in direct or indirect losses is prohibited.
For companies to which this applies, all employees must follow and respect the policy for controlling international commercial relations and economic sanctions, as well as all laws in force in the country. This includes laws and regulations relating to trade embargoes and economic sanctions, export controls, anti-boycott laws, cargo security, import classification and evaluation, product/country of origin marking, and free trade agreements.
When an employee identifies any circumstance, transaction, or relationship that directly or indirectly involves them and that could bring them an advantage, they must immediately disclose their conflict of interest to their supervisor, who must, in turn, inform the company's Compliance/Integrity Department.
d) Companies' Duties in Contracting with Suppliers
To adopt selection, contracting, and evaluation criteria, in an impartial and transparent manner, that allow for plurality and competition among suppliers, aiming for contracts with the best economic-financial balance and cost/benefit ratio, within the framework of free competition, unless otherwise established by law.
To uphold legality, impartiality, morality, and efficiency in all actions taken in interactions with suppliers and potential suppliers, whether public or private, national or international, upholding the principles of integrity and corporate ethics.
To ensure the maintenance of a relationship based on mutual respect, best practices, preservation, and confidentiality of information relevant to the companies and their clients.
To seek, while ensuring compliance with free competition criteria and any existing legal limits, relationships with suppliers and partners whose practices are in harmony with the ethical standards adopted by the companies in the Passenger Division and with social morality.
It is a necessary and mandatory requirement in the relationship with Suppliers, subject to the legal limitations that these:
Comply with labor, social security, tax, and LGPD (Brazilian General Data Protection Law) legislation, as well as any international laws that may apply to a given service;
Comply with the legal standards established for the respective Supplier's sector of activity, as well as comply with regulations relating to the prevention and combating of corruption;
Do not use child or slave labor;
Adopt good environmental preservation practices;
Do not engage in corrupt practices against governments or public administrations, whether Brazilian or foreign, at any level.
Allow companies to inspect, at any time, any and all matters pertaining to the service provided or product sold, providing, as long as it is subject to legal confidentiality, the information requested by any of the companies; Do not exercise any form of physical or moral coercion that violates human rights. Service or product providers, while providing their services to any of the companies in the Passenger Division, will be instructed regarding the Guidelines of this Code of Ethical Conduct, undertaking to comply with its rules while providing their services.
Reject any contractual provisions with any suppliers, of any nature, that offend or minimize the dignity, quality of life, and social well-being of outsourced employees.
Suppliers, to whom this Code of Ethical Conduct also applies, will not permit or encourage the harassment of employees, suppliers, or any persons providing services to or on behalf of Passenger Division companies, and will take the necessary measures to prevent such conduct within their respective companies.
Do not authorize any improper business dealings on behalf of any of the companies in the Passenger Division that constitute criminal or illicit acts, such as corruption, money laundering, financing of criminal activities, fraud, or other illegal/immoral and/or unethical activities.
The contact information for the Whistleblowing Channel related to this Integrity Program for companies in the Passenger Division of the Águia Branca Group must be communicated to Suppliers, ensuring their right to anonymous complaints in case of investigation of unethical conduct.
(e) Relationship with Competing Companies
To adopt ethics, integrity, and civility as commitments in relationships with competing companies in the same line of business as the companies in the Passenger Division.
When appropriate and necessary, promote the exchange of information with competing companies in a lawful, transparent, and reliable manner, preserving ethical and honest conduct and the interests of the companies in the Passenger Division.
To encourage or partner with companies in the sector, when applicable, in the pursuit of best safety practices in interstate or intercity collective road transport and/or freight transport and/or travel and tourism agency services, aiming for social well-being and continuous improvements in the collective road transport of passengers and/or freight and/or the travel and tourism agency sector.
Do not engage in unfair or predatory competitive practices against other companies operating in the same line of business as the companies in the Passenger Division, and repudiate those who do so, seeking to take appropriate measures to bring to the attention of the relevant regulatory bodies any illegal or improper practices that come to your attention.
Refrain from disparaging or making value judgments about services offered by competitors, particularly on social media or other public platforms.
f) Relations with the Government at all levels
To act as a partner to the public sector in the implementation of socioeconomic policies, projects and programs aimed at the sustainable development of Brazil, continuing its mission to move customers in a safe, comfortable, reliable and excellent manner.
Maintain a respectful relationship with state entities (national and/or international) regardless of the ideological convictions of their leaders.
To act in accordance with the legal dictates governing the road transport of passengers, parcels, and travel and tourism agencies, whether interstate, intercity, and/or international, as applicable, as well as to observe all other applicable regulations, whether fiscal, labor, social security, or other applicable laws.
To recognize the role of regulatory and supervisory bodies and to commit to supporting them as required by law, providing them with relevant and reliable information in a timely manner.
To repudiate any acts of corruption committed against governments or public administration, whether Brazilian or not, at any level, such as: Guaranteeing, promising, offering, or giving, directly or indirectly, any undue advantage or advantage not provided for by law to a public official or a third party related to them; Financing, paying for, sponsoring, or in any way permitting or facilitating the commission of any illegal act;
To induce someone to engage in or refrain from engaging in any conduct that clearly violates their legal obligation;
To obtain, maintain, or direct business in an improper manner;
To affect or influence any act or decision of a public entity;
Using an intermediary, whether a natural person or a legal entity, for the purpose of concealing the interest or identity of beneficiaries of actions taken;
To frustrate, defraud, obtain undue advantage or benefit, impede, disrupt or manipulate the competitive nature of a bidding procedure;
To hinder investigative or supervisory activities or to interfere with their actions. Not to finance political parties or candidates for public office at any level in Brazil.
g) Regarding Donations, Gifts and Contributions:
Members of the Board of Directors of the Passenger Division, Investors, Senior Management, Employees, and Collaborators of the companies in the Passenger Division must refrain from soliciting or accepting, under any circumstances: Monetary value, except as defined by law;
Gifts with values exceeding R$100.00 (one hundred reais) are prohibited, except when there is prior knowledge and approval from the Board of Directors, with the option of consulting the Compliance/Integrity Committee;
Gifts with values less than R$ 100.00 (one hundred reais) must be reported to the immediate supervisor.
The aforementioned individuals must also refuse gifts or presents, even those within the permitted value, when their characteristics or circumstances indicate an intention to influence the impartiality of any selection/decision-making process.
If any gift or promotional item exceeding the permitted value has been forcibly received due to the impossibility of immediate or later return, said gift will be donated to an institution to be defined by the Integrity Committee.
Any and all donations made and/or received by any member of the Passenger Division companies and on their behalf require prior authorization from the Board of Directors and must be reported to the Compliance Committee.
Receiving prizes and/or donations above the established limit will only be permitted when it is an internal award or recognition event promoted by one of the companies in the Passenger Division and the Águia Branca Group.
It is prohibited for any member of the Board of Directors of the Passenger Division, investor, senior management, employee, collaborator, or any of the companies in the Passenger Division, or by a third party acting on their behalf, to offer gifts of any value, as well as entertainment, hospitality, and meals to public officials with the aim of obtaining any personal advantage or benefit, or who have the power to influence decisions of interest to the companies in the Passenger Division.
Requests from public authorities for the transportation of passengers in the form of tourist charters for specific events may be authorized by the Board of Directors, after consultation with the Compliance/Integrity Committee, provided that the request is made expressly and formally and does not in any way constitute obtaining any advantage or benefit for the companies.
Requests from public authorities for individual passenger transport in the regular and/or parcel delivery mode may be authorized by the Superintendencies via the Free Service Center – SAG –, and the request may be made expressly and formally, provided that it does not in any way constitute obtaining any advantage or benefit for the companies.
Companies within the Passenger Division, their Board Members, Administrators, Employees and Collaborators, as well as third parties interacting on their behalf or through them, may, with the prior and express authorization of the Board of Directors, offer corporate gifts, participation in events and meals to private institutions or agents, provided that this does not constitute obtaining an illicit advantage or benefit for the companies.
h) Questions and Complaints:
If you have any questions regarding the application of this Code of Ethical Conduct or any of its rules, you should contact the Integrity Committee for clarification through the available channels.
If any misconduct or irregularity is detected among members of the Passenger Division Board of Directors, senior management, employees, collaborators, suppliers, or others, such behavior must be reported to the Integrity Committee through the whistleblowing channels, with anonymity guaranteed.
The complaint must, without exception, identify the perpetrator of the irregularity, provide a truthful description of the facts, and indicate any evidence or witnesses, in order to enable the initiation of an investigation procedure.
Once a complaint has been filed as described above, a confidential procedure will be carried out, which, upon verifying the validity of the complaint, will produce a complete and detailed report that will be submitted to the designated Integrity Leader, with appropriate suggestions, for disciplinary decisions, in accordance with the Complaint Investigation Code.
If the investigation does not reveal any misconduct or irregularity, a report with the relevant conclusions will also be prepared and filed with the Integrity Department of the Passenger Division, ensuring the anonymity of the whistleblower in relation to other company members.
If the complaint involves a member of the Integrity Department of the companies in the Passenger Division, the accused may not participate in the investigation procedure, except to exercise their right to a fair hearing and full defense.
The contact information for the Internal Ombudsman and the Whistleblower Channel is:
Email: canaldedenuncias@aguiabranca.com.br
Telephone: 0800-810-8575
Letter – to the Compliance/Integrity sector – Av. Mario Gurgel, 5030, Vila Capixaba, Cariacica-ES, CEP: 29145-901;
Website: https://www.contatoseguro.com.br/aguiabrancapassageiros
Android APP: https://play.google.com/store/apps/detailsid=br.com.contatoseguro.appoficial&hl=pt_BR&gl=US&pli=1
iOs APP: https://apps.apple.com/br/app/contato-seguro/id945536717
A verbal complaint can be made in person directly to the Integrity Department.
There will be no retaliation against whistleblowers or witnesses involved in investigations of infractions by the Passenger Division Companies of the Águia Branca Group that participate in this Code of Ethical Conduct.
i) Media relations
The Passenger Division recognizes that the media plays an important role in the country, as it disseminates news, information, and expresses opinions to the public, and acknowledges the importance of this work in all formats. However, the companies in the Passenger Division prioritize protecting their image, which is why they must always verify the accuracy of information before publishing it, assisting media outlets in light of their responsibility in reporting facts and information about those involved.
Regarding the release of information by the Passenger Division, it is committed to acting with consistency and accuracy. Therefore, only certain employees are authorized by the Board of Directors to speak on behalf of the Company and give testimony to any form of media.
The Passenger Division is not responsible for content published by third parties on social media. Any misleading, inaccurate, or untrue disclosures will entitle the Company to the right of reply, allowing for the correction and removal of the content, as well as the possibility of adopting other applicable legal and/or contractual measures.
j) Occupational Health and Safety
Regarding occupational health and safety, the companies in the Passenger Division proceed as follows:
They continuously manage risks and comply with applicable legislation;
It develops health and preventive medicine programs aimed at its employees, with the goal of improving their quality of life;
It identifies risk factors in the health field, carrying out systematic awareness, education and intervention actions.
k) Final provisions:
This Code of Ethical Conduct reflects the values and culture of the companies in the Passenger Division, and its compliance demonstrates a commitment to professionalism and transparency in all actions and work of the companies.
Any disregard for the Code of Ethical Conduct will subject all those to whom it applies to disciplinary action, which may even result in dismissal for cause and legal proceedings.
Third parties who fail to comply with the applicable rules contained in this Code of Ethical Conduct may have their business relationship with the Passenger Division terminated, without prejudice to the payment of damages in legal action, if applicable.
Everyone who interacts directly or indirectly with the companies in the Passenger Division must be aware of and uphold this Code, sharing the same ethical commitments, regardless of their position.
Failure to observe any of the practices and/or procedures described herein may affect the credibility of the institutional image of the Passenger Division companies with customers, the market, regulatory and supervisory bodies, the government, and society as a whole.
Everyone is subject to facing one or more ethical and controversial dilemmas during their career in the Passenger Division companies. Whenever this occurs, ask yourself the following questions:
"I have permission to do this."
The fact or decision is in accordance with the law, internal policies and rules, and my personal values.
I would be proud if this action and/or decision became public, if it appeared in the media.
I would be proud to share my actions and/or decisions with my family and friends.
This action and/or decision puts other people's lives at risk.
The answers to the questions above serve as a guide in case of gaps in this Code of Ethical Conduct.
This Code shall enter into force on the date of its publication.
February 6, 2020
Rev.1.2 – May 21, 2025