Introduction
Along the path of good.
Dear employees, suppliers, consultants, and business partners of SER Renováveis,
The migration from a carbon economy to a green economy, in which solar energy plays a fundamental role, represents a benefit to humanity. SER Renováveis’ contribution to building this new industry stems from a concern for future generations and the well-being of planet Earth. But doing good is meaningless unless it is done along the path of good — along the narrow roads of integrity, dignity, and respect.
SER Renováveis’ concern and commitment — not only with the ends, but with the means used to achieve its goals — are reflected in this Compliance & Integrity Policy. The terms of this document are no more than a declaration of the principles of SER Renováveis’ shareholders, long held as a way of life — a commitment extended to all who engage with the activities of the company and its affiliates: senior management, employees, service providers, consultants, representatives, and business partners.
With this Policy, SER Renováveis wishes to publicly express its strict respect for national and international anti-corruption and anti-bribery laws, standards, and agreements; to reaffirm its commitment to honoring everything it agrees to; and to convey a spirit of collaboration and support for all movements toward transparency and justice. SER believes that building a fairer, more equal, honest, and free society depends on respecting the human person in the full breadth of their diversity, on valuing life, and on caring for the environment.
1 · Who it applies to
Scope
Observance and application of this Compliance & Integrity Policy is mandatory for all those who wish to establish professional and/or commercial relationships with SER Renováveis — including employees, affiliates, service providers, intermediary agents, representatives, consultants, and all those who supply goods or services to SER Sistemas de Energia Renovável Ltda.
1.1 · Conduct that adheres to standards
All actions at SER Renováveis must be guided by compliance, understood as strict adherence to the internal and external laws, standards, policies, and regulations applicable to the company’s business. Beyond complying with the law, transparency, honesty, loyalty, dignity, respect, courtesy, and collaboration are expected.
Adherence to and observance of ethical laws and standards, such as: the Federal Constitution, the Brazilian Penal Code, the Administrative Misconduct Act, the Anti-Corruption Act, Decree 8,420/15, the Public Procurement and Contracts Act, the FCPA (Foreign Corrupt Practices Act), the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and the Inter-American Convention against Corruption, among others.
2 · Applying the Code of Conduct
2.1 · Upholding integrity in our actions
Embedding and systematizing practices and procedures to control and mitigate the company’s financial, legal, operational, and reputational risks, in observance of and compliance with the SER Anti-Corruption Policy.
Every employee, board member, director, consultant, representative, or anyone acting on behalf of SER Renováveis must follow these requirements:
{{ rule }}
This SER Compliance & Integrity Policy is detailed further in the Ethical Conduct Procedures attached to the original document.
3 · Preventive actions and remediation of violations
Awareness and reporting channel
All those who wish to establish professional and/or commercial relationships with SER Renováveis must be aware of this document and, when acting on behalf of the company, may not claim ignorance of these requirements. In every engagement, evidence of awareness and acceptance of these terms must be produced.
When possible non-conformities or violations are identified, they must be shared with the company for improvement actions and lessons that prevent recurrence. SER Renováveis provides a secure communication channel that preserves anonymity, allowing employees and suppliers to report any violations of the terms of this document.
4 · Non-compliance
Penalties
Actions that contravene the terms of this document or other applicable standards and procedures — even through mere omission or an attempt to circumvent them — will be subject to the penalties set out in the applicable service agreement, independent of any civil or criminal proceedings, including but not limited to verbal or written warnings, suspension, and termination of the employment or service contract.
5 · General provisions
Review and training
This Policy will be reviewed periodically to ensure its effectiveness and alignment with legal and regulatory changes, as well as with the needs of SER Renováveis. All employees, suppliers, and business partners will be informed of any significant updates or changes.
SER Renováveis commits to providing ongoing training and the resources needed for everyone to understand and comply with this policy. In case of questions or a need for clarification, employees and business partners should contact the company’s compliance department.