1. CODE OF CONDUCT
DOMO Salute is health regulatory consulting firm assisting medical devices’ manufacturers through the Brazilian regulatory system, enabling their access to our growing market. We are committed to respecting work standards, human rights, environmental sustainability, and ethical conduct. In line with this commitment, we find it essential to outline the principles and guidelines embodied in our Code of Conduct. This Code of Conduct brings together the principles, rules, and values adopted by the company in conducting its business in an ethical and transparent manner. These guidelines govern the interactions and relationships between DOMO Salute and all stakeholders, including employees, suppliers, service providers, as well as customers, competitors, government entities, and the press.
It is important to note that these guidelines are not exhaustive, and exceptional situations may arise that are not covered in this document. In such cases, disciplinary actions may be taken in accordance with applicable laws and regulations.
How to identify whether an action or conduct is appropriate?
It is important to ask yourself a few questions:
- Does the action or conduct comply with the current legislation?
- Is the action or conduct consistent with this Code, with the internal policies and other rules of DOMO Salute?
- Is the action or conduct in line with DOMO Salute’s values?
If the answer to any of these questions is negative, the behavior, action, or conduct in question is deemed inappropriate by DOMO Salute. However, in cases of doubt, we recommend reaching out to the Compliance Committee for further clarification.
2. PRESENTATION
It is with great satisfaction that we present our company’s Code of Conduct. We believe that this framework is essential to reinforce our values and ensure that our actions and decisions are always in line with our ethical principles.
Our code of conduct reflects our high standards of integrity and accountability in all areas of business. Based on transparency and respect for people, it defines the expectations and obligations of each one of us, regardless of our position or role in the company.
The Code of Conduct is a guide that must be used in our daily lives to guide our actions and decisions. We hope that all our employees and partners read it carefully and adopt the practices and behaviors described.
We thank everyone who has contributed to developing this code, and we are confident that together we will continue to work ethically and responsibly to achieve our business goals.
With this code, we strengthen the organizational culture that we value, and that underlies DOMO Salute’s business strategy and management processes.
3. VISION, MISSION, AND VALUES
VISION
To be a global benchmark of excellence, providing regulatory services to the medical device market and causing a positive impact in people’s life – whether they are customers, associates, or government agents. We aim to act as a partner in the promotion of technological, commercial, and regulatory development.
MISSION
To enable the access of medical device technologies into the Brazilian market by providing excellent regulatory services and working in synergy with the regulatory bodies. To promote long-lasting, trust-based relationships with international and national partners, in order to achieve both client and associate’s satisfaction.
VALUES
We base our work on the following values: excellence and empathy.
4. RESPECT FOR PEOPLE
DOMO Salute constantly seeks to maintain and improve the relationship with people, always treating them with transparency and valuing ethical work and attitudes. Our partners and employees respect diversity, not allowing any type of discrimination based on ethnicity, beliefs, nationality, gender, age, citizenship, religion, regional origin, disabilities, marital status, among others.
It is not allowed to adopt abusive, improper, or offensive conducts in our work environment, whether verbal, physical, or gestural, against colleagues, partners, or visitors.
It is not allowed to engage in behaviors that constitute psychological or sexual harassment in the performance of your duties, both within and outside the company. Psychological harassment consists of exposing individuals to humiliating and embarrassing situations in the workplace, repeatedly and over an extended period, in the performance of their duties. It is a behavior that undermines the dignity and integrity of the individual, jeopardizing their health and harming the work environment. Sexual harassment is characterized by repeated actions, though depending on the case, it can even be constituted as a single act, in which the victim, of any gender, ends up being subjected to unwelcome sexual advances.
DOMO Salute aims to create a healthy environment based on trust and respect among individuals. The environment should provide physical, moral, and psychological safety to all employees. Therefore, working under the influence of alcohol or any intoxicating substance will not be allowed, as these conditions can jeopardize the safety of the employee, their colleagues, and third parties.
Considering that DOMO Salute is officially present on major social media platforms, it is important to emphasize that safeguarding the company’s good image is the responsibility of everyone. Therefore, employees must preserve their personal image when choosing to identify themselves as employees of the company, paying attention to their comments or other content mentioning the company, and respecting the terms described in this Code.
Professional matters should preferably be addressed by email. The application WhatsApp should be used with caution as it is a supplementary communication tool. Avoid sending messages about professional matters after business hours.
The work environment at DOMO Salute is based on respect for legal norms and the well-being of employees. All employees have access to safe and healthy working conditions through projects related to health and occupational safety. In order for this to continue, everyone must comply with general health and safety regulations and standards and participate in training and orientation activities.
Human working conditions: DOMO Salute does not tolerate inhumane and degrading working conditions, nor violations of fundamental rights. Therefore, the company will not tolerate the hiring of forced or compulsory labor, by the company or any entity with which DOMO Salute maintains a relationship, in accordance with the Brazilian legislation in force. Likewise, the hiring of child labor will not be tolerated, pursuant to the current Brazilian legislation.
5. INTIMATE RELATIONSHIPS
We understand that romantic relationships or kinship may occur between employees and/or employees and third parties. To avoid any conflicts arising from these relationships, any level of hierarchical subordination, influence on management decisions and processes must be avoided.
In cases where there is hierarchical subordination, the relationship should be disclosed to the managers, and the situation will be brought to the attention of the Compliance Committee, which will assess the case and provide its recommendations. In cases where there is no hierarchical subordination, but one party has influence over the other party’s career or activities, the employee should abstain from participating in decision-making and must not conceal the existence of an emotional bond with another employee under any circumstances.
6. CONFLICT OF INTEREST
A conflict of interest occurs when our judgment can be influenced or appear to be influenced by the possibility of obtaining personal benefits. Even if unintentional, the appearance of a conflict can be as detrimental as an actual conflict. The existence of a conflict of interest does not imply a violation of the Code of Conduct; however, the concealment of such a conflict should never occur.
Therefore, one should always:
- Inform their manager or partner of any situation involving a conflict of interest.
- Refrain from participating in any professional decision that involves a personal relationship. If abstaining is not possible, the decision must involve the participation of at least two business partners or managers.
The following situations also constitute a Conflict of Interest:
- An employee or member of the board engaging in other professional activities that may interfere with DOMO Salute’s business, even if conducted indirectly and/or outside of working hours.
- Improper use of privileged information obtained within the company.
- When kinship or friendship relationships between an employee and a supplier or service provider compromise the impartiality in business, meaning that personal interests take precedence over those of DOMO Salute.
- The use of confidential information obtained through meetings or activities within DOMO Salute for personal purposes or for a third-party company.
7. USE OF PHYSICAL RESOURCES
It is the responsibility of each employee to use DOMO Salute’s resources consciously and diligently, avoiding personal use and complying with applicable legislation.
The use of IT resources must strictly follow the guidelines of the Information Security Policy, available on the internal network (cloud). Illegal software copies and the use of unlicensed products are not allowed. Access to the Internet using company equipment for personal purposes, such as accessing social media platforms and conducting research, is permitted. However, personal use should be careful, in accordance with applicable law and internal rules and policies, and should not hinder work performance.
All messages distributed through the e-mail system are the property of DOMO Salute; therefore, if deemed necessary by the company, e-mails may be monitored without prior notice.
The employees are responsible for their passwords (telephony, electronic means, and systems) for accessing personal and non-transferable accounts. Additionally, a password manager is provided by the company for all employees to use. Do not share personal passwords with unauthorized third parties. By doing so, we ensure the security of information and confidentiality of company data.
8. CORRUPTION PREVENTION
At DOMO Salute, practices involving favoritism, promise, or direct or indirect granting of benefits of any kind, as well as any act of corruption or bribery with public agents or business partners, are unacceptable and impermissible.
By way of example, below are some behaviors that are inconsistent with the legislation, particularly the Anti-Corruption Law:
- Omitting, permitting, inducing, or facilitating any form of corruption or bribery, directly or indirectly, through another employee or representative of DOMO Salute.
- Manipulating accounting records with the intention of omitting transactions. All accounting records must be accurate and truthful. Every payment and/or receipts must be recorded.
- Offering, promising, or giving payment, gift, and/or providing any type of benefit (direct or indirect) to any person with the aim of inducing or rewarding inappropriate conduct, illegally influencing or attempting to influence the decision of a national or foreign public agent, or any other person, for personal or third-party benefit.
- Requesting, accepting, agreeing to receive a gift, payment, or undue advantage (directly or indirectly) from any person as a reward or incentive for inappropriate conduct or to influence or create the impression of influencing decisions for personal or third-party benefit.
Employees and third parties are expected to always act ethically and transparently, without engaging in any form of undue offering or permission with the intention of influencing or promoting DOMO Salute. There will be zero tolerance for illicit practices.
Any conduct indicative of corruption must be immediately reported to the company’s management and/or through the Whistleblowing Channel, even if it is just a suspicion. DOMO Salute has the necessary tools to investigate such reports.
9. PROTECTION OF PERSONAL DATA, PRIVACY, AND CONFIDENTIALITY
DOMO Salute complies with the General Data Protection Law (Law nº 13.709/2018), and demonstrates constant concern for the use of personal data within its possession, as well as personal data of third parties related to the Company.
Employees must not intentionally request or obtain personal information belonging to third parties unless it is necessary for carrying out activities of DOMO Salute and is done through the execution of a term or contract, is required by law, or is a legitimate right.
Any personal or sensitive personal data be used only for the purposes specified in the Record of Processing Activities (ROPA), in accordance with the Privacy and Data Protection Policy and the Information Security Policy. DOMO Salute does not share personal data unless required by law, contractual obligations, and legitimate rights.
Employees and third parties must treat confidential data and information of the company with confidentiality. The disclosure of confidential information can only be done with prior authorization from the responsible manager. Confidential information includes business strategy, financial results, strategic plans, personal information of employees and customers, internal policies, rules, and practices, as well as any information provided by the company’s clients under conditions of secrecy and confidentiality, among others.
10. RELATIONSHIP WITH REGULATORY AUTHORITIES
Medical devices, which fall within the scope of DOMO Salute’s activities, are regulated in the national territory by government agencies such as ANVISA, INMETRO, and ANATEL. Each employee, manufacturer, importer, and distributor involved in the supply chain of these products is responsible for complying with the requirements established by regulatory agencies, including manufacturing practices, quality controls, labeling, and other regulations and documents established by government agencies.
Each employee, manufacturer, importer, and distributor is responsible for reporting any problems that may be identified to the Quality department and Management of DOMO Salute.
DOMO Salute is committed to maintaining a transparent, constructive, professional, and ethical relationship with regulatory agencies regarding regulatory requirements and compliance with current legislation.
11. RELATIONSHIP WITH CUSTOMERS
DOMO Salute is committed to building and maintaining a strong and trustworthy relationship with its clients. In doing so, we strive to:
- Ensure excellence in providing regulatory services for the medical devices industry;
- Act transparently and in full compliance with current regulatory requirements, ensuring clarity in the information provided and addressing requests accordingly;
- Respect the clients’ freedom of choice;
- Adhere to competition regulations.
13. RELATIONSHIP WITH THIRD PARTIES
In relation to this item, we acknowledge: suppliers, distributors, importers, service providers, business partners, and consultants as third parties.
DOMO Salute maintains a transparent and ethical relationship with third parties, respecting free competition and free enterprise, including providing a communication and reporting channel accessible to everyone.
The hiring of third parties follows previously established internal rules and procedures, particularly through the submission of documents that qualify them according to the requirements of the company’s Quality Management System, when applicable.
Employees should avoid directly engaging in the hiring or management of third parties with whom they have any degree of kinship, as outlined in the Conflict of Interests section of this Code of Conduct.
- Hiring should be based on the internal rules and procedures defined by the company, taking into account the documents provided and reputational risk;
- The company will engage with third parties whose business activities are guided by ethical principles and adhere to anti-corruption laws, ensuring fair competition.
- Inhumane and degrading working conditions, violations of fundamental rights, non-compliance with current legislation, and environmental laws are considered unacceptable.
13. WHISTLEBLOWING CHANNEL
The Whistleblowing Channel is a tool available to receive reports or suspected cases of violations of laws, this Code, and/or Company Guidelines.
It is of utmost importance that any individual, whether internal or external to the company (client, supplier, third parties in general), who becomes aware of or suspects a violation of laws, this Code of Conduct, and/or the company procedures (whether it has occurred, is occurring, or may occur), feels comfortable reporting their concerns directly to the Whistleblowing Channel.
For employees, it is considered it a duty to report any violations of this Code they become aware of. DOMO Salute values the questions and concerns of all individuals with whom it interacts, and therefore, we strongly encourage clarifying any doubts regarding conduct.
The Whistleblowing Channel ensures the confidentiality and anonymity of the reporter. All reports are properly investigated, and the Whistleblower Channel is subject to and prepared for audits that ensure its proper functioning.
We emphasize that any actions of repression or retaliation related to the reports will not be tolerated.
Send your inquiries, concerns, or reports via email to compliance@domosalute.com.br.
14. DISCIPLINARY MEASURES
Violation of the Code of Conduct, DOMO Salute’s internal policies, or the current Brazilian legislation may result in sanctions, which, depending on their severity, can range from verbal warnings to termination of employment or contract termination.
DOMO Salute reserves the right to take the appropriate administrative and legal actions to seek compensation for any financial or reputational damages that may arise from such violations.
15. UPDATES
DOMO Salute strives for continuous improvement of its services and practices. For this reason, the Code of Conduct may undergo periodic updates. We recommend regularly consulting this Code. Any significant changes will be communicated and disclosed.