![]() | Code of Conduct and Ethics - ![]() | ||||
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Message from the President | |||||||||||
To all, | |||||||||||
This is the Code of Conduct and Ethics of Inter. To be part of Inter is to do something new, simplify and resolve. Therefore, we have become an ecosystem of solutions that go beyond finance, offering facilities for the most diverse moments of life. We believe in people, we propose to help them evolve, to be partners and respect each one's freedom of choice. If at any time you believe that our employees, partners or even Inter are not acting in accordance with the guidelines contained herein, or with the rules and laws in force, let us know through the Inter Ethics Channel. Your report will be confidential and, if you wish, may be anonymous. | For us, some values are non-negotiable on this journey, and acting in a way that honors them is what allows us to move forward with legality, efficiency, transparency, integrity and ethics. Phone: 0800 887 0077 or via link https://canaldedenuncia.bancointer.com.br We are counting on you. This Code of Conduct exists so that management members, employees, customers, suppliers, authorities and other stakeholders with whom we interact may understand the principles and standards that must always guide our behavior and relationships. João Vitor Menin CEO of Inter | ||||||||||
Our Identity | |||||
Our purpose | |||||
Our pillars | |||||
Social, environmental and climate liabilty | |||||
Our code | |||||
Objective | |||||
To whom it applies? | |||||
Work environment | |||||
Attention to personal relationships | |||||
Attention to our assets and resources | |||||
Attention to confidentiality of information | |||||
Conduct in business relations | |||||
Attention to conflicts of interest | |||||
Attention to preventing money laundering and combating terrorism financing | |||||
Attention to preventing fraud, bribery and corruption | |||||
Attention to gifts and facilities | |||||
Attention to relationship with suppliers and partners | |||||
Attention to relationship with competitors and the market |
Conduct in Relation to External Audiences | |||||
Attention to customer relationships | |||||
Attention to relationship with the government and official bodies | |||||
Attention to relationship with the community | |||||
Attention to relationship with shareholders | |||||
Attention to relationship with unions | |||||
Attention to donations and sponsorships | |||||
Attention to our image and the media | |||||
Management of the Code of Conduct | |||||
How to act? | |||||
Duty of collaboration | |||||
Ethics Channel | |||||
Ethics Committee | |||||
Integrity Program | |||||
Consequences of violation |
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Our purpose | |||||
Create what simplifies people's lives |
EXPERIENCE | SEGURITY | PARTNERSHIP | INNOVATION | TRANSPARENCY | ||||||||||||||||||||||||||||||||||||||||
We value humanized, respectful and quality interactions between all audiences and channels. | We safeguard all interactions and data exchanges involving customers, employees, partners and other institutions. | We safeguard all interactions and data exchanges involving customers, employees, partners and other institutions. | We are born to do diferent. We are open to ideas that aim to improve people's lives and generate value to our company. | We must maintain and transmit clear, impartial and understandable information, always ensuring the truth. | ||||||||||||||||||||||||||||||||||||||||
OUR IDENTITY | ![]() | ||||
Social, environmental, and climate responsibility | |||||
Social, environmental and climate responsibility is at the core of Inter. We are constantly concerned about creating value for our main audiences, meeting their expectations, our materiality and the best practices expected from business models similar to ours. We are also careful to promote social, environmental and climate responsibility in our value chain. Therefore, we verify that our partners comply with specific social, environmental and climate guidelines, and we have a growing presence in the community through private social investment and the corporate volunteering. |
![]() | Purpose | ||||
The Code of Conduct and Ethics of Inter was based on our purpose and pillars, and aims to ensure increasingly ethical management and performance. Here you will find the set of guidelines that we elaborated with the aim of ensuring the credibility and security of the institution's relationships. Although rich and detailed, our Code of Conduct and Ethics may always improve. Therefore, in case of doubts about an action or behavior, consult your manager or contact Compliance team by the email compliance@bancointer.com.br. |
OUR CODE | ![]() | ||||
Who is it for? | |||||
The standards and rules of this Code of Conduct and Ethics must be applied in any action or business that involves the interests of Inter by all: _ Employees _ Shareholders _ Members of the board of directors _ Suppliers _ Business partners _ Service providers |
ABUSE OF POWER | SEXUAL HARASSMENT | MORAL HARASSMENT | ||||||||||||||||||
When someone uses their position or influence to force the other to carry out activities in violation of law or our internal regulations. | Undesired expressions of sexual nature that causes embarrassment or threats, for the purpose of having a sexual relationship with a co-worker. | Abusive, intimidating or offensive conduct that creates a toxic environment, affecting the integrity an employee. | ||||||||||||||||||
Attention to our assets and resources | OUR ASSETS _ Use them only for their intended purposes, respecting the corporate interests. _ Keep your work desk always clean and tidy. _ Be careful with liquids near electronic equipment and computers. _ Treat our equipment with the same care used to your own assets! OUR STRATEGY _ Always keep Inter's business and operations confidential so that, together, we can grow even more. _ Protect what makes us unique: our ideas! OUR WORKING ENVIRONMENT _ Visitors are always welcome, but they should only circulate in our facilities accompanied by our “Blood Orange” (Sangues Laranjas). _ Access must be restricted to the meeting rooms. _ Other work environments should only be visited in case of need. | |||||||
We make available facilities, equipment, materials and systems for using in the work-related activities. It is important that you be aware of the expected conducts related to them: |
REMEMBER! | ||||||||||||||
Inter may, at any time, monitor the computers of its employees, including files, folders, contents in emails and contents in sites accessed at the internet. | 14 | |||||||||||||
Attention to confidentiality of information | CONDUCT Always act diligently and use all information security mechanisms provided by Inter. PASSWORDS Your passwords are personal and non-transferable. Therefore, do not share your system accesses, not even with another Blood Orange. INFORMATION Do you have access to insider information? So uphold the trust we place on you! The use of such information for personal interest and/or market abuse is unacceptable. DATA Personal data of our customers, partners and employees are extremely confidential, following the guidelines of our regulations, internal policies and Law 13.709/2018. | |||||||||||||
Due to the nature of our business, we handle a lot of confidential and sensitive information. Therefore, we must treat it with great responsibility, following some guidelines. They are: | ||||||||||||||
We know that Inter is an unavoidable topic for all of us, but we need to be aware of discussions and comments about our platform and our customers in public places. After all, we do not want other people to have access to our information. |
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BUT AFTER ALL, WHAT CONFLICT OF INTERESTS MEANS? These are situations in which your personal interests or those of people close to you can influence your decisions at work. There is no need for actual damage, but just the possibility - even if alleged - of affecting your decision. Perception makes a difference: Not only do avoid the actual conflict of interests, but also situations where an external person might assume the existence of a conflict of interest, even if it is not their intention. | ||||||||
WHAT MONEY LAUNDERING MEANS? It is a practice used to cover up the origin of illegal money. It consists of a scheme to make it appear that resources obtained through illegal activities came from legal activities. | ||||||||
FRAUD | CORRUPTION | BRIBERY | ||||||||||||||||||||||||||||||
Intentional act of deceiving someone or using dishonest or false methods in order to illegally and misleadingly gain benefits. | Act of improperly using a position of influence to obtain advantages, or even perform any action considered illegal under the laws in force. | Offering anything of value for the purpose of obtaining improper advantages or information (illicitly, unfairly or fraudulently). A means of rewarding someone for doing something forbidden. | ||||||||||||||||||||||||||||||
REMEMBER! | ||||||||
It is everyone's duty to report any practice of fraud, bribery, corruption or any other unlawful practice. | ||||||||
REMEMBER! If in doubt whether or not to accept a gift, entertainment or any other kind of courtesy, consult Compliance: compliance@inter.co | 22 | ||||||||||
![]() | Attention to relationship with competitors and the market | ||||
Competition is essential for customers and users to exercise their freedom of choice. However, we must fight three types of practices: _ Unfair competition (obtaining a competitive advantage by using unethical or illegal means) _ The formation of cartels, which submit the market to a game of marked cards, directly harming buyers of goods or services. _ Unilateral practices that undermine the competitive dynamics in markets in which we have a relevant share. To do this, act in accordance with the principles of free competition, and respect the reputations and opinions of our competitors. |
REMEMBER! | ||||||||
Immediately report to the Ethics Channel the knowledge of any conduct that does not respect these guidelines. | ||||||||
CONDUCT WITH EXTERNAL AUDIENCE | ![]() | ||||
Attention to relationship with the community | |||||
Inter is committed to being a responsible company in the community where it operates, encouraging the development of conscientious citizens. For the effectiveness of such project, we count on your involvement! _ We promote advertising campaigns that are not misleading and are committed to good customs and free competition. _ We maintain open channels that encourage the free expression of opinions and concerns of all stakeholders with whom we interact. _ We carry out and encourage the volunteer work by our employees to the entire community. |
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Attention to relationship with shareholders | |||||
We treat our shareholders equally, based on the principles of good governance, being accountable and maintaining transparent communication, providing clear, accurate, accessible and complete information. | |||||
We recognize union entities as legal representatives of employees, and we strive to seek, through respectful and responsible negotiation, the best agreement for the interests of both parties. _ Treat the representatives of unions and professional entities in a respectful and cordial manner. _ Report to your manager or Compliance team (on an identified or anonymously basis) any unethical conduct or that is harmful to the rights of employees. |
Attention to donations and sponsorships | ||||||||||||||
Donations and sponsorships may and should be made, but always guided by transparency, integrity and legal compliance. _ Donations and sponsorships may take place in different modalities, whether through financial contributions, solidarity programs, volunteer work, sports, leisure, among others. _ Donation or sponsorship to organizations that have a potential conflict of interests is prohibited, in accordance with the rules provided for in this code. _ Agreements signed with beneficiary institutions shall contain anti-corruption clauses. | _ We do not authorize to conditioning any contributions (sponsorships, donations, etc.) on the achievement undue benefits for Inter, for yourself or for third parties. _ The beneficiary institutions shall comply with the rules contained in this Code, and shall act ethically in all their relationships, in return for the donation or sponsorship received. | |||||||||||||
REMEMBER! | ||||||||||||||
Each donation must undergo an integrity due diligence, ensuring that there is no history of involvement with corruption or fraud, as described in the respective Internal Policy. | ||||||||||||||
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REMEMBER! | ||||||||
The information confidentiality guidelines apply to social media as well. | ||||||||
BE ALERT! | |||||
If you still have any doubts, please consult your manager or our Compliance team via email compliance@inter.co or the Ethics Channel. | 34 | ||||
Duty of collaboration | ||||||||
Whenever you have any doubts, witness or suspect any violation of the Code of Conduct and/or current legislation, it is your duty to report the fact via the Ethics Channel. _ Inter's reputation for integrity affects everyone, and only a single person can harm it. _ When you do not speak up, unethical behavior continues, which may negatively affect our work environment and employee morale. _ Report any suspicious immediately may prevent a problem from escalating and casing damage to Inter and your co-workers. | _ How can our customers and the public may trust us if we allow any behavior contrary to the Code of Conduct and ethical standards? |
BE ALERT! | ||||||||
Inter will never accept any attempt to identify who made an anonymous report, and we shall not tolerance retaliation of any nature against a good faith whistleblower and anyone who provides information, documents or collaborates in the investigation process of an incident. Play your part. Help create the company we want. | 35 | |||||||
Ethics Channel | ||||||||
One of the mechanisms we make available to all our employees and third parties so that we can have an environment that ensures an ethical conduct is the Ethics Channel. _ It is managed by a third-party and independent company. _ Your report may be identified or anonymous, at your discretion. If you choose make an anonymous report, you can be sure that this decision will be respected. | _ Do not worry. We fully guarantee that no retaliation shall be made against a person due to any report made. _ Provide as much detail as possible about the subject matter of the report, so that the investigation is viable. _ To file a report, you do not need to be sure about the existence of a conduct that violates our pillars, integrity or our Code of Conduct and Ethics. Suspicion and good faith are enough. |
INTERNET | PHONE | ||||||||||
http://canaldeetica.com.br/ bancointer/ | 0800 887 0077 -available 24 hours a day, 365 days a year. | 36 | |||||||||
PREVENTION | DETECTION | RESPONSE | ||||||||||||||||||
–Code of Conduct and Ethics –Internal regulatory system, which manages the work policies, standards and instructions; –Training and awareness; –Compliance risk management; –Regulatory compliance with regulators; Know Your Customer and Know Your Partner procedures. | –Audits (internal, external, regulatory and internal controls); Transaction monitoring; Know Your Employee Procedure; –Report Hotline; –Systematic monitoring of audit points. | –Reports to senior management; –Integrity Committee; –External Reports (COAF – Financial Transactions Control Board) | ||||||||||||||||||
Sanctions | ||||||||||||||
Whenever there is a violation of the principles and guidelines contained in this code by employees or third parties, Compliance and the Ethics Committee shall be responsible for dealing appropriately with each case. Indications and evidence of the violation will be taken into account for the application of the following sanctions to employees, third parties and suppliers: _ Disciplinary measures _ Suspension _ Agreement Termination (interns and suppliers) _ Dismissal | ||||||||||||||
BE ALERT! | ||||||||||||||
It is the responsibility of every employee or third party to report behavior that is incompatible with this Code or the law. Omission after being aware of possible violations is considered an unethical conduct, and is also subject to the application of prescribed disciplinary measures. | ||||||||||||||
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Integrity, consistency and seriousness summarize our conduct. We are very proud of our history, and we need you, Blood Orange, to keep those values alive in our present and future. Let's go on this mission together! | |||||