Code of Ethics and Conduct

At Crossjoin we always act with cordiality, correctness, and professionalism, based on a relationship of trust.
Our communication with the client is correct, clear, rigorous, transparent and true, providing the client with the necessary information and ensuring the scrupulous fulfillment of the agreed conditions. Our posture with the client is one of respect and loyalty in accordance with all the ethical and deontological principles that we stand for.

We are professional, rigorous, and effective; we use all our skills, competencies, and resources to meet our customers' and partners' needs and expectations, always striving to elevate the quality of the service provided and in our relationships.

Efficiency: Our solutions are tailored to each project to ensure maximum effectiveness.

Dedication: We have teams dedicated to each of our projects, always on standby, to anticipate, act and solve in real-time.

We always act, according to the best practices, to ensure quality and safety in the delivery of our projects in accordance with our Quality and Information Security Policies.

Confidentiality and data security are at the top of our concerns. Our employees are subject to professional secrecy, as signed in the Confidentiality and Non-Disclosure Agreement and are governed by the utmost discretion. We comply with all legislation in force and invest in information systems and secure technology, always keeping abreast of best practices in the area of security for information, personal data protection (customers, partners and employees), facilities and equipment.
Company data is private and may not be shared with outside parties.
It is the responsibility of each and every one of us to ensure the protection and security of Crossjoin, Customers and Partners.

We protect our brand, ideas, software, patents, technological advances and distinctive services subject to all inherent proprietary rights as original and exclusive property of Crossjoin.
It is the responsibility of each one of us to ensure the proper management of our Intellectual Property Rights and prevent their unauthorized use.
We equally respect the Intellectual Property Rights of others, adding to our responsibility the implementation of legal frameworks, with Partners and Vendors that uphold these rights and allow us to secure and manage risks and benefits effectively.

Our corporate culture encourages and promotes a respectful organizational atmosphere that ensures dignity and fairness among all employees. We strive to create working conditions favorable to the involvement of all in an environment of trust and always with a spirit of mutual help, which we are all responsible for promoting.
A spirit of cooperation and sharing common goals are welcome and strengthen us.

Integrity and loyalty are expected of everyone and in all circumstances, respecting and promoting Crossjoin's good name.
We encourage you to maintain a posture of integrity and to establish relationships of trust with everyone with whom you work.

We are committed to respecting and enforcing fundamental rights, upholding the dignity of
people at all times and in all its dimensions and to safeguarding diversity and inclusion, which
we promote and aim for at Crossjoin.
As such, all hiring decisions are made on the basis of technical skills, merit, experience and personal suitability.
Regardless of the reason, we do not tolerate discrimination of any kind, be it race, ethnicity, gender, sexual orientation, nationality, age, political choice, religion, family situation, or any other.
All relationships with employees and among peers are based on respect for individuals and human rights, and no child labor is permitted.

We act with total transparency when evaluating the performance and recognizing the merit of our employees, so we design an Individual Development Plan (IDP) tailored to each employee and define quarterly expectations for each project (PES) the employee is part of, to guide and support our employees in their career development, in a system of equity and equality of opportunity.
We encourage and promote the necessary training for professional development and encourage the sharing of opinions to enhance the company.

We protect the health, safety, and well-being of our employees by investing in safe work environments that promote both physical and psychological wellness. We promote team building activities, socializing and recreational activities for all employees. We encourage and promote the adoption of healthy and environmentally sustainable lifestyle. We provide access to the gym to all our employees. All of our employees, and their household, are provided health insurance and psychological, nutritional, psychosocial and legal support.

We are, and strive to remain, a leading employer of choice. To this end, we continuously work towards achieving the best balance between professional activities and personal and family life, ensuring the work-life balance of each employee as an individual.
We recognize how crucial this balance is to fostering a healthy organizational climate, and we actively encourage and welcome ideas and proposals that help the company fully achieve this goal.

When we think about the impact we have on people’s lives we think about a merge between responsibility and curiosity, which is why we seek to add innovation to the new generation of talents, in order to generate constant evolution.
We have total confidence in our skills and in our work, added by continuous learning and receptivity to new knowledge, because we believe in the value of collective intelligence.

Any type of harassment or any action that may constitute intimidation, retaliation, reprisal, or threat within the relationship between employees is unacceptable. Our conduct must be characterized by its integrity, cordiality, and mutual respect. A hostile,
intimidating, or destabilizing work environment will not be tolerated. Our commitment is to a working environment free from discrimination, harassment and bullying free environment, thus we make all misconduct consequential. All situations that undermine someone's dignity, be that you own or that of a colleague, must be reported.
All reports must be submitted through Whistleblowing, the channel made available on our website for this purpose, with the guarantee that they will be treated in a confidential, diligent and serious manner and ensuring that the protected against any kind of reprisal and retaliation.

We use the resources, such as assets, equipment, and buildings, made available by the company in a manner which is appropriate and responsible, never forgetting that their use and derived enjoyment is shared by all employees, and that we must maintain, protect and preserve them.

Environmental sustainability is truly important to us, which is why we adopt more appropriate and efficient practices, optimizing our resources.
This concern is reflected in all our spaces, namely in the use of renewable materials, intelligent flushing systems, sustainable lighting, and others.
Our fleet is composed exclusively of electric vehicles. We work daily towards being more environmentally aware, cognizant of our role and responsibility, and all employees should feel that they are an active and relevant part of this concern. We want to reduce our environmental impact and influence those around us also make more sustainable choices.

All employees, regardless of their position, are expressly forbidden from acting in any way which may constitute corruption, bribery or any related offence, and other forms of undue influence or illicit conduct, in all of their internal and external relations, be that with private or public entities.
In particular, it is expressly forbidden to all employees, regardless of their position within the company:
- the use of the company or its name to obtain benefits for themselves or for third parties by them indicated.
- all situations or actions that may constitute conflicts of interest,, that is, whenever private interests or access to privileged information may compromise the impartiality of the decision or affect the company's interest.
- the acceptance of gifts or benefits from third parties that could create expectations of favoritism or be construed as corruption.
All employees will be provided with training on what constitutes Corruption and Related Infringements in compliance with the legal regulations of the RGPC (General Regime for the Prevention of Corruption).
Any knowledge of situations that could, in any way, constitute corruption, bribery, conflict of interest, money laundering or others that fall within the scope of the above, should be reported through Whistleblowing, the Internal Reporting Channel.
Crossjoin has a zero tolerance policy for any unethical or illegal practices.
The Corruption and Related Offences referred to in this Policy are punishable, depending on the legal framework, by fines and imprisonment for a maximum of 12 years.
The Regulatory Compliance Officer must draw up a report for each offence committed, in which are detailed the rules violated, the sanction applied and the measures adopted or to be adopted within the scope of its internal control system.
The RGPC is in the internal development and implementation process, as well as the ISO 37001 standard - Certification of the Anti-Corruption Management System.

We consider it part of a normal business relationship to offer and receive gifts or other offers, as long as they are reasonable and proportionate, given with transparency and using common sense, as long as it is made clear and guaranteed that we are never influenced, nor do we try to influence, by receiving or offering gifts, which is why we never receive commercial gifts or offers during any negotiation, before closing a new deal or contract. However, we do prohibit the giving or receiving of excessive or improper gifts or offers that could in any way amount to bribery or corruption.

Crossjoin provides Whistleblowing, Internal Reporting Channel in compliance with the legal directives provided by Law 93/2021, which establishes the general system of protection for whistleblowers.