Código de ética - GTKS – Medical Products Distributor

GTKS Medical Code of Ethics and Discipline

I. INTRODUCTION

I.1 OBJECTIVE

This Code of Ethics and Conduct aims to highlight and reinforce the ethical values of GTKS Medical, as well as the principles that guide the conduct of its activities.

Given its vocation for national and international business, the provisions covered in this Code are closely linked to the company’s commitment to offering the best service and product to all healthcare institutions in Brazil and abroad.

The Code aligns with the purpose, mission, values and vision that define the identity of GTKS Medical and together reinforce its business status in the medical field, committed to innovation and excellence, without, however, creating any relationships between parties other than those they already have.

All other commitments expressed by GTKS Medical through standards, regulations, regulations and policies are also aligned with and inspired by this set of values.

I.2 RECIPIENTS

This Code must be observed by the board of directors, leaders such as Supervisors and Managers, Salespeople, Commercial Representatives, Employees and Interns who act on behalf of GTKS Medical, commercial partners and suppliers.

All these recipients must use the provisions set out in this Code as an ethical and conduct reference to be observed in their relationship with GTKS Medical and in the conduct of their activities in any location where GTKS Medical operates.

I.3 PURPOSE

Our purpose is to Win Customers who Win Customers!

I.4 MISSION

We offer our customers a relationship of trust and efficiency that guarantees a long-term sustainable partnership.

I.5 VISION

We are a reference in the medical field with disposable, surgical products and equipment. We supply imported items and distribute nationally manufactured items that serve various specialties, with a focus on neurosurgery.

I.6 VALUES

We guide our attitudes on 6 values:

Honesty and Trust

Recipients of this Code must consider that GTKS Medical’s excellence generates trust that is naturally established in relations with the various audiences with which the company interacts and in whose relations it is necessary to weigh not only what is legal and illegal, what is fair and unfair, what is convenient and inconvenient, what is opportune and inopportune, but mainly what is honest and what is dishonest.

Therefore, it is essential that ethics be the background of conduct, since not all laws, norms and policies exhaust ethical reflections and, therefore, everyone must:

Be honest in our partnership relationships;
Act with respect for human rights and the environment;
Act ethically;
Repudiate any form of harassment;
Repudiate any fraudulent or corrupt practice (bribery, influence peddling, money laundering, concealment of assets, undue advantages and others) or illicit or criminal acts of any kind;
Condemn illegal conduct such as document forgery, tax evasion, tax evasion, among others.

Respect and Equality

Recipients of this Code must take into account that GTKS Medical respects the individual choices of those who maintain links with it, but shares moral and ethical attitudes that are fundamental. Therefore, it is essential:

Respect diversity;
Promote the right to freedom through the exchange of thoughts, ideas and opinions, without prejudice or discrimination;
Condemn aggressive or embarrassing attitudes;
Avoid prejudiced or discriminatory behavior in relation to race, color, origin, gender, personal aesthetics, physical conditions, nationality, sex, age, marital status, sexual orientation, social position, religion and other acts that harm the dignity of people people;
Respect people and our partners;
We practice coherence by acting in line with what we say.

Realization

Recipients of this Code must seek superior standards of quality and constant innovation from an environment in which enthusiasm, the desire to learn and teach, commitment and professional attitude are exemplary and contagious. Therefore, it is essential:

Perform the duties of your role with a high sense of commitment, responsibility and proactivity;
Innovation, results and partnership are what motivate us;

Perform duties with precision and within the required deadlines;
Perform your activities always seeking to overcome challenges;
Seek innovative proposals and continuous improvement of processes;
Focus on objectives;
Recognize mistakes made, correct them and use them to identify ways to avoid them;

Trust people in our relationships, thus ensuring that each person is part of a whole.

Coherence

Recipients of this Code must base their conduct on impartiality. There are situations in which norms become abstract to assist decision-making in which it is necessary to balance antagonistic interests – conflicts of interest – it is necessary to use one’s own concept of what is right or wrong. Therefore, it is essential:

Carry out activities in an impartial manner, not using the position to obtain benefits or advantages for oneself or third parties;
Resist any type of pressure or harassment;
Communicate other professional activities performed;
Avoid embarrassment from colleagues and maintain a friendly atmosphere;
Refrain from using the name, brand and corporate symbols of GTKS Medical without prior authorization;
Renounce participation in decisions involving the selection, hiring, promotion or termination of contracts of family members or people with whom they have relationships that compromise impartial judgment;
Respect all stages of the hiring process for professionals who may have any connection with GTKS Medical so that there is no need for any type of favoritism, regardless of the professional level of the employee who made the appointment;
Refrain from disseminating content on social media that is not in line with GTKS Medical’s values.

Commitment to Laws and Standards

Recipients of this Code must consider that attitudes and behaviors are based on a strong commitment to doing the best, but with full adherence to GTKS Medical’s values, current laws and internal standards. Therefore, it is essential:

Act in accordance with applicable laws and regulations, internal or external;
Respect all rules established by GTKS Medical when choosing to use the institutional email address to handle personal matters, being aware that, due to control obligations, such messages are subject to internal monitoring;
Maintain neutrality on GTKS Medical’s official channels on social media, on matters of a controversial nature involving politics, religion and social and cultural issues;
Ensure the image of GTKS Medical on social media;
Ensure that confidential documents are not reproduced, whether by scans, photos, photocopies or any other means;
Record accurately, within the required deadlines and with the appropriate degree of detail, information relating to income and expenses in order to generate complete accounting reports and in accordance with the standards required by current legislation;

Know and follow the rules for preventing corruption provided for in Brazilian legislation, among them, the Administrative Improbity Law (Law no. 8,429/1992) and Law no. 12,846/2013 and its regulations in which they undertake to comply with them faithfully, by itself and by its partners, administrators and collaborators, as well as demanding compliance by the third parties hired by them;
Do not give, offer or promise any good of value or advantage of any nature to public agents or people related to them or any other people, companies and/or private entities, with the aim of obtaining undue advantage, influencing an act or decision or conduct business illicitly;
Adopt the best practices for monitoring and verifying compliance with anti-corruption laws, with the aim of preventing acts of corruption, fraud, illicit practices or money laundering by partners, administrators, employees and/or third parties hired by them. The proven violation of any of the obligations set out in this clause is grounds for the application of current legal standards as well as foreseen internal sanctions.

II. Pillars

II.1 OUR PILLARS

Our pillars are:

Our values
Sustainable partnership with our customers and suppliers
Range of high quality medical products
Profitable business
Meet regulatory and statutory requirements

III. CRITERIA FOR CONDUCT IN RELATIONSHIPS

III.1 WITH GTKS Medical ITSELF:

The following are common conduct criteria for all GTKS Medical employees and interns, which must be observed:

Take care of the internal assets and material resources made available, using them correctly, legally and primarily for the performance of tasks that serve GTKS Medical, protecting them from damage, inappropriate handling, loss or misplacement;
Use resources such as water, energy, paper and other office and consumer materials with citizenship and without waste;
Show up for any work commitment at the established time, prepared to meet expectations and dressed appropriately;
Obtain prior authorization to be absent from work, whether to deal with personal matters or to carry out some type of activity, paid or unpaid.

III.2 AMONG THE INTERNAL AUDIENCE:

1.1 The following are common conduct criteria for all recipients in leadership positions:

Act with the responsibility that the position gives you;
Know and disseminate, including through one’s own attitudes, the values and principles contained in this Code;
Speak in an impartial and well-founded manner regarding professional attitudes considered inappropriate in light of the principles contained in this Code.

1.2 The following are common conduct criteria for all recipients as members of work teams:

Welcome divergent and constructive opinions and act to resolve conflicts, thus enhancing a broadly cooperative environment;

Maintain the work environment free from embarrassment arising from the formulation of criticism or reproduction of rumors that affect the reputation of GTKS Medical professionals and those who have ties with it;
Be willing, when working together, to share your knowledge and information with professionals from other teams, within the required needs and established agreements.

III.3 WITH BUSINESS PARTNERS AND SUPPLIERS

The following are common conduct criteria for all employees in relation to business partners who act on behalf of GTKS Medical and suppliers:

Relinquish participation in the process of hiring business partners and suppliers, indicated or not, who are related to you (relative up to the 3rd degree), submitting any other situation, in which you feel conflicted, to the competent channels of GTKS Medical;
Require confidentiality from commercial partners and suppliers and confidentiality in the handling of data and information to which they may have access at any time, including the phases before and after contracting services;
Clarify and adjust adherence to the same with commercial partners and suppliers GTKS Medical’s ethical conduct and management guided by dignified and honest attitudes represented by compliance with legal, labor, environmental, health and safety requirements;
Select commercial partners and suppliers using transparent, fair and objectives that consider technical compliance, performance, quality, guarantee conditions, among others, so as not to characterize favoritism of any kind, casting doubt on the integrity of relationships;
Objectively reject commercial partners and suppliers that show any signs of the use of slave, child or forced labor and illicit practices such as fraud, bribery and corruption and, if any irregularity is detected, direct it to the competent authority;
Require that When carrying out activities on behalf of GTKS Medical, commercial partners respect its identity, its values and its operational standards, not misappropriating the resources made available to them;
Inform leadership of any link or relationship unofficial situation that occurs, or that may occur with business partners and suppliers.

III.4 WITH CUSTOMERS:

The following are common conduct criteria for all employees and business partners towards GTKS Medical customers:

Act in a transparent and ethical manner;
Safeguard the information used and the results obtained in the business, protecting them from undue leaks and treating them with the required confidentiality standards plus those established during the negotiation;
Reject the idea of obtaining results at any cost and always seek to put your attitudes in the foreground in line with the company’s values and interests;
Inform leadership of any unofficial ties or relationships that occur, or may occur, with clients or future clients of GTKS Medical.

III.5 WITH PUBLIC AGENTS:

The following are common conduct criteria for all employees and business partners in relation to public agents:

Strictly respect anti-corruption and anti-bribery laws that govern relations with national and international public agents from all spheres of power, including employees and licensees of public services, as well as members of political parties and candidates for political office;</li >
Base any relationship on total transparency and legality, detailing, at any time, the object and objective of the relationships and the resources involved, so as not to question the purpose and destination of these resources;
Avoid any situation in which there may be doubts regarding the integrity of the relationships and in which there is the possibility of the existence of some type of undue advantage;
Condemn the offer of any resource, monetary or otherwise, with a view to fulfilling the legal obligations of public agents or rushing routines, as any act may constitute facilitation or bribery and, therefore, bribery and corruption.

III.6 WITH THE PRESS:

The following are common conduct criteria for all employees who are authorized to deal with the press on behalf of GTKS Medical:

Maintain relationships guided by the veracity and transparency of information, as well as the opinions and opinions issued, basing them on previous and well-founded studies so as not to tarnish GTKS Medical’s reputation as an upright institution committed to socioeconomic development of the country.

IV. CRITERIA FOR CONDUCT OF BUSINESS PARTNERS AND SUPPLIERS

The following are the conduct criteria of all commercial partners and suppliers contracted by GTKS Medical, to be observed in all their relationships:

Maintain standards and procedures that guarantee processes free from unethical and illegal practices, mainly, making payments for legitimate commercial purposes authorized by law arising from genuine commercial reasons;
Ensure that the object of the contract is not likely to be used for illicit practices;
Reject and not offer any payment or undue advantage (kickback or bribery), for any reason, aimed at the celebration, maintenance or guarantee of a commercial relationship with or for GTKS Medical;
Act with the same ethical conduct as GTKS Medical and management guided by dignified and honest attitudes represented by compliance with legal, labor, environmental, health and occupational safety requirements;
Abhor misleading, unfair and fraudulent commercial practices;
Act in full compliance with the laws, rules and regulations applicable to the conduct of activities with GTKS Medical;
Comply with the accounting and tax rules established in applicable laws and regulations;
Comply with GTKS Medical’s internal standards;
Know and apply the principles, values and rules of conduct established in this Code;
Avoid any interaction with GTKS Medical, or on its behalf, that is characterized by a conflict of interest;
Comply with the clauses of the contracts signed between the parties;
Promptly present accounts when requested by GTKS Medical;
Reject the use of child labor, slave labor and the like that could be considered a violation of human rights;
Respect the confidentiality and secrecy of information shared arising from activities carried out with GTKS Medical;
Execute, if requested by GTKS Medical, a confidentiality agreement in the event of the exchange of confidential information;
Never make confidential GTKS Medical information available for any purpose;
Ensure the security of data and confidential information about GTKS Medical, in physical or digital form, adopting the necessary precautions to keep it confidential;
Ensure working conditions that comply with legislation, free from harassment and discrimination;
Facilitate the inspection and investigation activities of public bodies, entities or agents and notify GTKS Medical immediately if they are subject to any type of investigation.

V. REPORTING QUESTIONS OR COMPLAINTS

Any recipient of the Code who has doubts or considers it necessary to report a concern or violation of the principles and criteria of conduct established therein must do so using the reporting channel via email administrativo@gtks.com.br;
Any complaint will be investigated and those that have a substantiated basis will be handled and the appropriate measures will be applied;
Regardless of the outcome of the investigation, GTKS Medical will make every effort to ensure that no form of retaliation occurs against the whistleblower;
All complaints will be handled under the strict confidentiality required;
When the violation of this Code of Ethics and Conduct concomitantly violates matters of another nature, in the criminal, civil, labor or disciplinary fields, the channel receiving the complaint will take the situation to the competent authorities within the scope of GTKS Medical.

SAW. FINAL DISPOSITIONS

VI.1 TERM AND APPLICATION

This Code is valid for an indefinite period of time, from its publication and applicable to GTKS Medical in all locations where it operates.

VI.2 DUTY TO DISSEMINATE

1.1 All recipients have the duty to disseminate this Code, adequately reporting any violations of it.

VI.3 COMMITMENT TO THE CODE

1.1 From the implementation of this Code, and in all its revisions, all its recipients are obliged to sign a declaration attesting that they have read each version of the Code of Ethics and Conduct:

For those who maintain employment relationships, regardless of hierarchical level, type of relationship and duties whenever there is a review or at the time of hiring;
For other recipients who maintain contractual ties (individual or legal entity), at the time of contracting.

1. 2 Failure to sign the declaration or absence from training does not represent release from compliance by recipients of this Code; 1.3 All recipients have the duty to follow and report any violations of the provisions of the Code; 1.4 All contracts concluded by GTKS Medical with third parties must contain a clause referring to the awareness and commitment to adhere to the principles and criteria of conduct contained in this Code.

VI.4 QUESTIONS AND OMISSIONS

1.1. The principles and criteria of conduct considered in the Code provide for all situations that may arise in the daily life of each relationship;

1.2. Anyone who has doubts and uncertainties about the provisions of this Code should contact their immediate manager or, if this is not possible, when necessary, use the reporting channel via e-mail administrativo@gtks.com.br.