Code of Ethical Conduct

Version 01/2022

Approving Body: Executive and Operational Board

Approval date: 19/04/2022

Release Date: 22/04/2022

DEFINITIONS

For the purposes of this Code of Ethics, words with capital letters, whether in the feminine or masculine version, whether in the singular or plural form, will present the definition established herein in the present context, unless, for the purposes of correct interpretation, a different meaning has to be attributed.

• INNOVEA HUB MARKETPLACE LTDA. referred to only as "INNOVEA HUB” or “Organization”;
• “Code” means the Code of Ethical Conduct;
• “Employees” refer to partners, directors, managers, employees, interns, outsourced workers, apprentices, service providers and suppliers;
• “Partners” refer to business partners and third parties linked to business activities, such as financial management platforms and other types of partnerships;
• “Customers” refer to individuals or legal entities that purchase/contract the services of INNOVEA HUB, and they are divided into the categories of Business Customers and Remote Professional Customers.
• “CEO” refers to the Chief Executive Officer or, in Portuguese, to the Executive Director of Innovea hub.
• “CAO” refers to the Chief Administrative Officer or, in Portuguese, Administrative Director of Innovea hub.
• "Conflict of Interest" refers to situations that generate a conflict of interest between the private interests of Employees, Suppliers and Partners, towards the interests of INNOVEA HUB and/or its Clients/Investors.
• “Platform” refers to the website https://innovea.com.br/ and its subdomains (such as https://app.innovea.com.br/ or any others), place where the services of INNOVEA HUB are offered.

1. Our Principles, Values ​​and Beliefs Business Management and Practices.

for us from INNOVEA HUB integrity is not optional. It is the non-negotiable basis for the actions of each individual Employee, as well as our Partners and Customers.

The fundamental nature of our work is to democratize opportunity. Our mission is to offer a solution for Talent as a Service so that the best talent in the market can connect with the best companies, regardless of where they are located.

Therefore, the Code must be observed by all Employees, Partners and Customers when they are: (i) exercising their professional capacity, or (ii) representing INNOVEA HUB  before third parties (iii) using the intermediation services of the Platform. Without prejudice to other hypotheses, this Code will be applied whenever Collaborators and Partners are interacting with each other, with clients or with counterparties.

The values ​​that guide this Code of Ethical Conduct are:

• Innovation
• Operational
• CONTROL
• Reliability
• Diversity
• Sustainability
• Social responsibility

A INNOVEA HUB was born with a mission: to facilitate and intermediate hiring between remote professionals and companies. But this mission is much more than that: in addition to our platform and technology, it is to humanize these processes and help companies and professionals in their evolution.

Our own culture is based on these values ​​and that's why we take this solution to the market, so that more companies and professionals can enjoy processes where the human being is the main part.

Our vision is to serve people: by people, by people, for people. Our goal is to deliver an incredible experience to our customers, reducing costs, deadlines and contracting bureaucracy, as well as turnover and losses.

And how do we do it? Transforming the autonomy of professionals into productivity and results for companies, as well as seeking the evolution, satisfaction and safety of these professionals.

To achieve these goals, it is important that integrity and ethics guide all our actions. Understand that brokering relationships is a commitment we make with pride, but it brings responsibilities beyond the simplification of the word. It is necessary to be attentive to the needs of society, to the complexity of legislation, always acting impartially, correctly and lawfully. In other words, it is a grandiose and complex responsibility in all its senses.

That's why it's important that you read, understand and commit to complying with this Code of Ethical Conduct, so that our goal, our values ​​and our mission are fully fulfilled and you can have security in your contractual relationship with us.

Finally, we hope that our relationship will be very successful for all of us.

 Thiago Freitas – CAO (Chief Administrative Officer)

2. Conduct of Senior Management members, Employees, Partners and Customers.

All members from Senior Management to Employees and Partners of INNOVEA HUB must act in a reputable manner, in order to comply with the provisions of this code, including:

1. Carry out its activities with good faith, transparency, diligence and loyalty in relation to Customers.
2. Act in a way that we achieve our mission and vision and in accordance with our values.
3. Not to practice acts that facilitate or configure tax evasion, money laundering, financing of corruption, either through own resources or through resources from the Innovea hub.
4. Do not use materials or goods protected by industrial property rights that are the property of others, with copyright, without the explicit authorization of the owner, as established by the Intellectual Property Law. Likewise, they may not use the materials or goods owned by INNOVEA HUB without your authorization.
5. Not adopting a data saving platform or tools other than those adopted by the company, as well as not performing Backups of data and documents INNOVEA HUB for their own interest or that of third parties.
6. Do not reverse engineer encrypted information, regardless of purpose.
7. Communicate any conflicts of interest that may arise to the immediate superior.
8. Refrain from participating in decisions, negotiations or intermediaries that have personal interests that conflict with those of the Innovea hub.
9. Do not carry out external activities that conflict with the interests of the company or present any type of competition.
10. Not acting in a way that links political and social interests to the interests of the Innovea hub.
11. The choice and contracting of suppliers must always be based on technical, professional, ethical and transparent criteria.
12. Refrain from contacting or providing service with customers and/or partners who carry out demonstrably illegal activities.
13. Respect the work environment with respect to safety standards and people. No type of harassment is accepted, regardless of the hierarchical level or any other condition, be it: moral, sexual, economic or even the practice of threats between Collaborators, Partners and Customers.
14. Do not make or disclose any criticism that offends the honor or slander that negatively affects the reputation of the company. INNOVEA HUB, Employees, Partners, Customers and Third Parties.
15. Do not practice, under any circumstances, conduct that characterizes prejudice, discrimination, embarrassment, coercion, disrespect to people or their positions and harassment of any nature.
16. Do not make value judgments or make any derogatory comment about competitors' products and services and/or about the competitors themselves.
17. To the Collaborators, not to act with clients and partners in order to impose business execution and/or conditions to which those involved do not express consent.
18. A INNOVEA HUB guarantees total freedom of expression on the part of its Collaborators in their personal social networks. However, they must always act with integrity and respect for the image of the INNOVEA HUB , Customers and Partners.

3. Relationship with Government Agencies and Institutions.

A INNOVEA HUB is always willing to seek an ethical and responsible relationship with governmental bodies and formal institutions, complying with the relevant legislation and collaborating to the maximum with the development of the nation.

4. Conflicts of Interest.

The Collaborators of INNOVEA HUB shall act with ethics, honesty, transparency, as well as guide their actions for the common good of the Organization and the Client, and shall also refrain from influencing others involved, carrying out activities incompatible with their function, negotiating with third parties interested in agent decisions public. In addition, it is the duty of all members of the Organization to inform the CEO or CAO of any other activities performed, so that the latter can assess the existence of potential conflicts or risks, including image risks.

5. Social and Corporate Responsibility.

A INNOVEA HUB has an ongoing commitment that its business is guided by ethical behavior that contributes to economic, social and environmental development, minimizing negative impacts on the current and future quality of life of everyone who may be affected by the company's operations. The company should, therefore, manage its routine by cooperating to improve environmental conditions and for the growth of communities and society.

Thinking about it, the INNOVEA HUB undertakes not to perform management and intermediation services on its platforms for companies that form the list of Employers' Registry that have subjected workers to conditions analogous to slavery (Slavery Dirty List), made available by the official portal of the Federal Government (https://www.gov.br/trabalho-e-previdencia/pt-br/composicao/orgaos-especificos/secretaria-de-trabalho/inspecao/areas-de-atuacao/combate-ao-trabalho-escravo-e-analogo-ao-de-escravo).

6. Use and Recording of Information.

Our information can be classified as:

• Confidential: valuable information that can give the company a competitive advantage;
• Internal: information used and available to support the conduct of the company's business;
• Public: Information that does not fit the previous classifications and is created specifically for consumption and distribution to the public and/or customers.

Confidential information is considered to be all information to which Employees may have access as a result of performing their duties at INNOVEA HUB and that are not demonstrably in the public domain.

Collaborators must keep confidential any information of a confidential and internal nature.

The obligation to preserve confidential and internal information continues even after the end of the relationship between the employee and the INNOVEA HUB.

Employees may not use confidential and internal information for personal gain. Nor may they provide it to third parties, including family members, relatives and friends, or even to other Employees who do not need such information to perform their tasks.

Providing confidential information to outside parties will be subject to the approval of the CEO and/or CAO.

7. Complaints.

If any Employee, Partner or Client feels affected or suffers any type of harassment or discrimination, as well as witnessing any of these attitudes carried out by any person linked to the INNOVEA HUB, whether at its headquarters or at another place where services are provided, must immediately communicate this fact to the Human Resources department, so that an investigation can be opened and punitive measures are applied, such communication does not remove the right of the Collaborator, Partner or Client injured in report such act to the competent authority.

A INNOVEA HUB undertakes to maintain the confidentiality of the identity of those who report and/or participate in the investigation into the violation of the code. In situations of doubt regarding the policies and practices of this code, the employee must contact his/her immediate superior, identification being optional.  

The Senior Management of INNOVEA HUB is fully committed to impartiality in its actions, always basing its decisions on technical and fair criteria, without embarrassing or coercing its subordinates in any situation. In addition to ensuring that your team knows and applies the precepts of the Code, it must also be an example of conduct to be followed by other employees.

8. Violation of the Code.

It is the responsibility of each Employee, Partners and Customers to be aware of the policies and practices expressed in the Code of Ethical Conduct of INNOVEA HUB. Any violation of any of its rules and/or guidelines will result in appropriate disciplinary action, up to and including termination or termination of the business relationship.

9. Commitment and Adherence.

Employees, Partners and Customers will have at their disposal a copy of this Manual in digital media, so that they can consult it at any time. Available at the link: https://innovea.com.br/codigo-de-conduta-etica

Updating this Code of Ethical Conduct of INNOVEA HUB will occur whenever relevant legislative or normative changes are identified by the responsible team, being the responsibility of the INNOVEA HUB alert all Employees of updates and keep up to date to avoid weakening this Code.

April 19, 2022.