Code of Conduct and Ethics

This Code is intended to present a compilation of our Compliance policies and the values of Desk Manager, with these guidelines being applied to all employees, suppliers, partners, and clients.


1. Objective

This Code of Conduct and Ethics (“Code”) embodies the essence, pillars, rules, and norms of conduct that underpin the activities of DESK MANAGER SOFTWARE LTDA. (“Desk Manager”).

Through these norms and pillars, Desk Manager aims for cohesive management and operations, focused on the constant pursuit of high standards of ethical governance and corporate sustainability, valuing sustainability, diversity, social inclusion, the promotion of safety in its workplaces, as well as the fulfillment of its employees.

Thus, the Code explains the standards that must be followed in conducting activities and living out our pillars and applicable legislation.

2. Scope

This Code is intended for all Desk Manager employees, regardless of hierarchical level, and the relationship groups referenced in this document, such as consultants, contractors, representatives, distributors, suppliers, and service providers (the “third parties”), or any other business partners acting on behalf of Desk Manager.

In this sense, its full compliance is the responsibility of each one, it should be an integral part of work tasks, the routines of all leaders, and serve as a performance measure of our organization.

3. Values

Desk Manager has four basic pillars, based on Partnership, Trust, Transparency, and Continuous Improvement, which guide the behavior of all connected to the organization, based on its values and culture.

Partnership: We value respect and welcoming everyone. It doesn’t matter the sexual orientation, ethnicity, religion, or political orientation. We encourage each person to find their own alchemy of essence: what makes them unique, their main skills and attributes;

Trust: We are all integrated and move collectively because we understand the importance and impact of everything we are and do;

Transparency: To achieve the results we expect, communication must be transparent and accessible;

Continuous Improvement: Building our journey is a collective task. We learn and make mistakes together. We help each other find new ways to solve challenges. After all, for Desk Manager, there is no challenge without a solution.

Based on these values, the Desk Manager Code provides guidelines to guide your conduct, actions, and decisions so that the company’s credibility is always preserved. Thus, much more than a simple document, this Code should guide all relationships that are part of a professional relationship and be a reflection of the conduct of these.

4. Guidelines and Best Practices

I – Professional and Personal Integrity
Desk Manager values the professional and personal integrity of all its employees. Therefore, it is everyone’s responsibility:

a) Take responsibility for the acts performed in the exercise of activities, especially for maintaining all information, records, and other documents intact, accurate, and complete;

b) The use of information obtained and/or handled within Desk Manager for all purposes, during or after the end of your relationship with Desk Manager, is prohibited;

c) Cooperate with public authorities in conducting investigations, audits, and inspections, without interfering or unduly influencing their realization;

d) Use all equipment provided by Desk Manager appropriately, as well as corporate email and other applications, in a manner compatible with the exercise of their professional activities and in accordance with the interests of Desk Manager;

e) Be aware that Desk Manager may, at any time, monitor its employees’ computers, including files, folders, email content, identification, and verification of content of the pages consulted on the internet in the exercise of their activities, corporate applications, among others;

f) Maintain good relationships with all Desk Manager employees to maintain adequate synergy and collaborate for the effective execution of all activities;

g) Never make or participate in political propaganda, own or third parties, written or spoken, including through t-shirts, buttons, stickers, flags, email, using Desk Manager assets or acting on its behalf;

h) Immediately report to the hierarchical superior any activity or situation that may affect their professional responsibilities or that may cause real or potential conflicts of interest for Desk Manager;

i) Not have financial interests, personal or ties of any kind with a company that does business with Desk Manager or, if they have, communicate such interest and/or link and also abstain from participating in hiring the third party in question or managing their contract to avoid suspicion of favoritism.

j) Inform the Conduct and Ethics channel about any processes that may affect them, whether as alleged responsible, witnesses, or any other title, that have been promoted by regulatory authorities, when participating in such processes arises from their professional activities.

II – Information Security

Desk Manager protects and values information, which must be treated with responsibility and confidentiality. Therefore, it is the responsibility of all employees:

a) Protect information to ensure its integrity, confidentiality, and availability, making use of it to the extent necessary for the performance of their professional activities;

b) Safeguard the confidentiality of information relating to relevant acts or facts to which they have privileged access due to the position or function they hold;

c) Protect professional information, maintaining confidentiality about technologies, methodologies, know-how, projects, processes, strategies, and any other relevant information owned by Desk Manager;

d) Refrain from conversations and comments about Desk Manager and its clients in public places;

e) Protect and keep confidential their user passwords and access to Desk Manager systems, avoiding compromising security systems and information;

f) Never omit relevant information or of interest to Desk Manager obtained in the performance of the position or function; and

g) Follow Desk Manager’s Privacy Policy, which covers a set of measures regarding the correct use of information, ensuring its confidentiality, integrity, and proper disclosure.

III – Various Relationships

Desk Manager relates through its employees, suppliers, and partners with various sectors of society. All these relationships must comply with the values and guidelines described here. Since each sector has its peculiarities, we relate them below.

Desk Manager does not condone and, therefore, rejects the practice of any illegal acts, and its commitment is to respect Brazilian legislation, its employees, clients, suppliers, and the entire chain involved.

A) Workplace Relationships

Desk Manager ensures harmony and organization in the workplace. Therefore, it is essential to maintain motivated teams in a continuous process of professional improvement. Managers, responsible for people and processes, play a fundamental role in propagating and applying the Code of Conduct and Ethics and must maintain an environment that encourages respect and personal and professional development. Therefore, it is the duty of all employees:

a) Encourage teamwork, respecting individuality and seeking consensus among people;

b) Ensure the establishment of a dignified and harmonious work environment;

c) Repudiate behaviors that may constitute harassment or discrimination of any kind, as well as situations of disrespect for the human being and their personal, political, religious, gender, or social convictions;

d) Encourage the self-development of employees, providing training for the performance of their activities within the Institution; and

e) Express suggestions and/or criticisms that may contribute to the development, evolution, and rationalization of processes and procedures adopted by Desk Manager via the Ethics Channel.

Desk Manager follows and values compliance with legislation and ethics, to ensure equal opportunities and fair treatment for all and, therefore, will not accept any type of offensive or embarrassing manifestation. Desk Manager rejects any form of discrimination against anyone.

B) Customer Relationships

Desk Manager’s main characteristics are differentiated and personalized service for all its clients, and it is committed to fair, ethical treatment in accordance with applicable legislation.

All employees must serve Clients with professionalism, competence, readiness, and empathy, providing clear, correct, transparent, and timely information. Adopting easily understandable contracts, making clear the rights and duties of the parties, providing service channels prepared to listen to them attentively and able to quickly resolve requests, complaints, and suggestions, treating the information provided by clients with confidentiality.

It will also be the responsibility of Desk Manager employees to pay attention to warning signs, such as requests for cash payments or other unusual payment methods that may lead to non-compliance with anti-money laundering or illegal financing laws by accessing reporting channels for case evaluation.

C) Relationships with Suppliers/Service Providers

Desk Manager’s relationship with its suppliers and service providers is based on ethics and always established under market conditions. Thus, it is essential that their actions are aligned with Desk Manager’s pillars, values, internal policies, and current legislation.

Desk Manager hires suppliers and service providers impartially, considering technical-financial criteria, that is, quality, price, delivery time, and service, using a clear and objective bidding process. Demanding from them the duty of confidentiality of the information they had access to before or after selection and hiring, as well as compliance with this Code, internal standards, and current legislation.

Desk Manager does not maintain relationships with suppliers and service providers whose reputation and actions contradict any principle or provision of this Code and those who use child labor or labor in conditions analogous to slavery, as well as those who disrespect the environmental, cultural, and social heritage of the community in which they operate.

D) Relationships with Competitors and the Market

Desk Manager rejects any practice that may restrict trade or free competition. It rejects the practice of forming cartels, bidding fraud, power abuses, or any form of market restriction.

Thus, employees must base their actions on the Principle of Fair Competition, according to Law No. 12.529/2011, Art. 36, and other related legislation, avoiding actions that could be interpreted as anti-competitive, monopolistic, or in any way contrary to international or national laws that control competitive market practices, not tarnishing the image of competitors and/or companies through rumors and/or disseminating negative information, even if true. It will also not use practices such as insider information, omission of relevant facts, manipulation of good faith, espionage, or obtaining competitors’ plans and actions through illicit methods.

E) Relationships with the Public Sector and Official Bodies

Desk Manager maintains good relationships with all municipal, state, and national public entities. Therefore, it is necessary that all employees:

a) Know, respect, and comply with internal standards related to relationships with the public sector;

b) Do not express, in the exercise of their function, opinions about acts or declarations of public agents nor make any comments of a political nature;

c) Do not make offers, payments, promises of payment, or authorization for payment of any amount of money, gifts, or objects of value to any authority or public official;

d) Do not attempt to influence any act or decision of authority or public official; and

e) Do not induce authority or public official to commit any act in violation of their legal duties.

Desk Manager rejects any form of corruption and conducts continuous training for its teams regarding the norms brought by the Brazilian Anti-Corruption Law and the Anti-Money Laundering Law.

F) Relationships with the Media and Social Media

Employees should pay special attention to social networks and other media and applications, including WhatsApp, and should not disclose messages or images that are not public or have not been published on Desk Manager’s official channels.

Any statement that may generate misinterpretation, involving discrimination, harassment, and insult on social networks or instant messaging applications, even if not related to Desk Manager, can affect our brand and reputation and goes against the principles defended in this Code.

In addition, special care must be taken with sensitive data of other employees, clients, suppliers, and partners, protecting their privacy, and not making verbal or written statements that may affect their image or contribute to the dissemination of rumors.

G) Policy of Relationships between employees or with suppliers, service providers, public agents, clients, or competitors of the company

All relationships between company employees or with suppliers, service providers, public agents, clients, or competitors of the company must be carried out and maintained with special diligence and care, always based on transparency and strict adherence to Desk Manager’s established systems.

Desk Manager employees must avoid, among themselves and with all suppliers, service providers, public agents, clients, or competitors of the company, establishing a relationship, whether in the personal or commercial sphere, that could characterize situations of conflict of interest or affect the impartial or objective judgment of these eventual situations.

V – Gifts, Presents, Favors, and Entertainment

It is very common for some suppliers to offer gifts, presents, or entertainment to us, or for us to offer them to our clients. There is nothing wrong with offering or receiving gifts from partners, as long as it does not create a real or apparent conflict of interest and does not result in influencing a business decision or compromise an independent judgment of the situation. For this, some rules follow:

a) We can receive and give gifts up to the value of half a minimum wage, as long as it is not in money or money equivalent;

b) Gifts that exceed this value must be returned or delivered to the Human Resources team, which will receive it on behalf of the company and promote its collective destination or disposal;

c) We can receive and give gifts to and from suppliers, partners, and clients who already have a relationship with Desk Manager, never those who are in negotiation.

d) The gifts received or sent must be lawful;

e) Offering and accepting promotional, public, non-exclusive, and non-commercial gifts by our employees and third parties acting on our behalf is permitted;

f) Gifts and presents must be purchased directly by Desk Manager, never by the employee;

g) We do not offer or receive gifts from/to public bodies and agents; and

h) Gifts and presents are occasional and cannot constitute remuneration or advantages, so it is worth paying attention to the frequency of receipt or sending.

VI – Diversity Practices

Desk Manager values diversity and is always looking to bring people with different points of view, backgrounds, genders, races, talents, and experiences into the company. The company understands that diversity is a competitive advantage.

In addition, Desk Manager understands its role in society and strives to create an inclusive work environment, free of prejudice, that allows the development and assistance of individual and collective needs, through human resources management policies with equal criteria for all employees, regardless of race, color, creed, origin, age, function, sex, sexual orientation, political orientation, marital status, or physical limitation.

VII. Práticas de conformidade com as Leis Anticorrupção

As leis anticorrupção existem para assegurar a qualidade da gestão pública, missão que a Desk Manager também assume. Assim, não oferecemos, prometemos ou aceitamos pagar dinheiro ou qualquer coisa de valor a agentes públicos de qualquer país, seus familiares ou qualquer pessoa a eles ligadas, com a intenção de fazer ou reter negócios. Isto é, não permitimos subornos, propinas, pagamentos “facilitadores” a qualquer funcionário do governo em nome da Desk Manager ou em seu interesse e não praticamos atos que visem fraudar, frustrar, impedir ou perturbar licitações ou atos licitatórios.

O Programa de Compliance da Desk Manager é a demonstração do nosso compromisso com a conformidade e conduta ética.

5. Reporting

Reporting a concern about a potential violation of this Code is everyone’s responsibility. Likewise, reporting any suspicion of misconduct can help prevent or limit damage to Desk Manager and its reputation. If you have concerns about unethical conduct or suspect a possible violation of this Code, any policy, Desk Manager procedure, or law, you should report it immediately.

Reporting is not always easy, so to ensure anonymity and greater comfort, we have our Ethics Channel. However, for us to investigate, it is often important to know who is reporting a concern. And, in this case, the confidentiality of this information is absolutely assured, restricted exclusively to the Ethics Channel group. After the investigation, the Ethics Channel will also be responsible for providing feedback on the corrective measures taken and/or the outcome achieved, to the extent possible.


Desk Manager also prohibits any form of retaliation against anyone who makes a good faith report or participates in an investigation. On the other hand, making a report in bad faith or knowing it to be false is also considered misconduct, subject to the disciplinary measures provided herein.

6. Disciplinary Measures

Non-compliance with the Code of Conduct and Ethics, known to the entire Desk Manager community, is not allowed and is subject to punishments such as:
a) Written warning;

b) Suspension;

c) Dismissal;

d) Motivated termination of the relationship with Desk Manager’s supplier or service provider; and

d) Filing of applicable lawsuits