The company MEGALASER INDÚSTRIA METALÚRGICA LTDA was founded in January 2006, with the objective of providing services in Laser Cutting, Bending, Boilermaking and Painting. Over the years, several technologies and new developments have been incorporated, also working with the assembly of components and equipment designed by our customers.

To achieve its goals, the Vision and Mission of the company MEGALASER can be summarized as:

• Maintain a solid and effective management system.
• Excellence in products and services.
• Guarantee reliability, honesty and suitability.
• Ensure technological development capacity.
• Lead and always seek participation in the metallurgical markets.
• Always attribute lessons learned.
• Support and provide feedback to the administrative and operational management system.
• Stimulate social, professional and technological development.
• Always react to adverse situations within the management system.

This Business Integrity Program is the corporate instrument that identifies the rules, policies, procedures and conduct that seek to ensure compliance with the standards, values ​​and principles that underpin personal and professional conduct among the company's directors, direct and indirect employees and between them and society, suppliers and customers.

The actions of directors, employees and all those who perform activities on behalf of Megalaser Indústria Metalúrgica Ltda. must be guided by the principles of legality, impartiality, morality, publicity, efficiency and by this Business Integrity Program.

It is the obligation of those responsible for hiring employees, interns, service providers, suppliers, third parties and agents in general to include in their respective contracts full compliance with the provisions herein.

Definitions:

Ethics: part of philosophy responsible for investigating the principles that motivate, distort, discipline or guide human behavior, reflecting especially on the essence of the norms, values, prescriptions and exhortations present in any social reality. A set of rules and precepts of a value-based and moral order of an individual, a social group or a society.

Integrity: state or characteristic of that which is whole, which has not suffered any decrease; fullness, entirety. Characteristic or state of that which is unharmed, intact, which has not been hit or attacked.

Compliance: comes from the English “to comply” and means to be in compliance with laws, ethical standards, internal and external regulations. Its function is to minimize risks and guide the behavior of companies in the market in which they operate.

Ethics and Integrity form the solid basis of Compliance at Megalaser, on which the Directors and direct and indirect Employees base their actions in strict accordance with the principles of legality, impartiality, morality, publicity, efficiency, in internal relationships, with suppliers and with the various sectors of society, ensuring:

To Customers

• Professionalism, trust and transparency.
• The availability of solutions that add value to our clients' businesses, permanently investing in the search for appropriate technologies and in the improvement of business strategies.
• The appreciation of and respect for the fulfillment of agreements and contracts, as well as the rights of our clients.
• The appreciation of business opportunities and partnerships built with our clients, aiming at results that benefit society.

To Government Agencies

• The company's relations with government officials and public authorities are strictly based on transparency.
• The company maintains a neutral and impartial relationship with political candidates, groups or parties.
• The use of resources, programs and services or the association of the Megalaser brand with activities of a political-partisan nature is not permitted.
• The company repudiates any and all forms of corruption, favoritism, extortion, bribery and kickbacks at all levels.

To Employees

• Maintaining a work environment where relationships are based on professionalism, trust, cooperation, integration, and respect for individual differences.
• Sharing knowledge and experiences, seeking to improve technical skills, methods, and processes, in order to achieve better overall results for the Company.
• Valuing people, contributing to their personal, technical, and professional development.
• Continuously striving for the appropriate and economical use of the company's material, technical, and financial resources.
• Preservation of and respect for the company's image, assets, and interests.
• Recognizing and valuing the company's intellectual capital and encouraging the emergence of new leaders.
• Valuing and encouraging individual and collective ethical conduct.
• Continuously striving for the appropriate and economical use of the company's material, technical, and financial resources.
• Preservation of and respect for the company's image, assets, and interests.
• Recognizing and valuing the company's intellectual capital and encouraging the emergence of new leaders.
• Valuing and encouraging individual and collective ethical conduct.

To Suppliers and Service Outsourcing Companies

• Legality, impartiality, morality, publicity and efficiency in all acts performed.
• Maintaining a relationship based on mutual respect, preservation and confidentiality of information relevant to the Company and its customers.
• Relationship with suppliers and partners who have practices in harmony with the ethical standard adopted by Megalaser and social morals.
• Rejection of contractual provisions that affront or minimize the dignity, quality of life and social well-being of its employees.
• Repudiation of any and all forms of bribery, kickbacks, corruption, favoritism and extortion at all levels and in all situations.
• The company maintains mechanisms to monitor its subcontractors, with regard to ensuring decent working conditions for their workers.
• The company maintains an updated database of its subcontractors, as well as maintaining a traceability control of the parts sent to them.
• The company prioritizes recycling and returning waste from the production process to the supplier.

Gifts and Hospitality

The general policy of Megalaser is not to receive or offer gifts and hospitality from/to clients, suppliers, or public officials.

Except for the above situation are gifts of small value, such as pens, notebooks, diaries, etc.

Reporting channel

Among the initiatives that reveal Megalaser's concern with transparency and its commitment to Ethics and Integrity is the reporting channel for recording and addressing cases of misconduct.

Reports and complaints can be made via email at denuncia@megalaser.com.bror via our website www.megalaser.com.br in the menu contact / Complaining and reporting channel.

Anonymity and a commitment to non-retaliation in the handling of shared information are fully guaranteed.

The company Megalaser develops practices, commitments and management aspects regarding Child Labor, Forced or Slave-Like Labor, Irregular Foreign Labor, Freedom of Association, Non-Discrimination in its most diverse aspects, Moral Harassment, Sexual Harassment and Retaliation, Human Trafficking.

Child Labor

• The company does not engage in or support the use of child labor, under the age of 16, except as an Apprentice.
• If minors between the ages of 16 and 18 are employed, the provisions of the CLT must be respected.
• It will not hire child labor.
• The company supports policies and programs that provide a transitional basis for children found working, which provide conditions for them to attend and remain in quality education until they reach adulthood.
• Young people under the age of 18 will not be employed for night work or in risky conditions.

Forced or Slave-Like Labor

• The company is involved in and does not support the use of forced or slave-like labor, which is characterized as degrading work.
• The company does not consider an exhaustive work day that extends beyond what is permitted by law and is continuous, leading to worker fatigue.
• The company repudiates precarious hygiene and safety conditions that threaten the health and safety of workers.
• Every worker must have a signed work card when starting their contract.
• The company repudiates situations of deprivation of liberty, whether due to debt, retention of documents or personal objects of the worker, or the presence of overt surveillance of the workplace in order to keep the worker in the workplace.
• Workers will not leave deposits or identity documents in the custody of the company and will be free to leave their jobs after legal notice.
• Physical or disciplinary abuse, threats of physical, sexual or other types of harassment, and verbal abuse or other forms of intimidation are prohibited.

Irregular Foreign Labor

The company does not engage in or support the use of labor or services performed by workers whose residence and employment status in Brazil is not regularized with the appropriate agencies.

Discrimination

The company does not engage in or support discrimination in hiring, remuneration, access to training, promotion, termination of contract or retirement, based on race, social class, nationality, religion, disability, gender, sexual orientation, age, pregnancy, union membership or political party affiliation.

Moral Harassment, Retaliation and Sexual Harassment

• Physical or disciplinary abuse, threats of physical or sexual abuse or other types of harassment, verbal abuse and other forms of intimidation are prohibited.
• Sexual harassment is characterized by unwanted sexual advances or inappropriate insistence by someone in a privileged position who uses this advantage to obtain sexual favors from subordinates or dependents, and is completely prohibited within the Megalaser company. Sexual harassment is a crime, according to art. 216-A of the Penal Code.
• Moral harassment is any and all abusive conduct (gesture, word, writing, behavior, attitude, etc.) that intentionally and frequently harms the dignity and physical or psychological integrity of a person, threatening their employment or degrading the work environment. The most common conduct, among others, is: giving confusing and imprecise instructions to the worker; making work difficult; attributing imaginary errors to the worker; unnecessarily demanding urgent work; overloading tasks; ignoring the presence of the worker, or not greeting him/her or even not speaking to him/her in front of others, deliberately; criticizing or making bad jokes about the worker in public; imposing unjustified working hours; unjustifiably taking away his/her work tools; physical or verbal aggression, when the harasser and the victim are alone; humiliating searches; restriction on the use of restrooms; threats; insults; isolation, and such practices are completely repudiated within the company Megalaser, and offenders will be punished according to the law in force in Brazil, after the facts have been investigated.
• Retaliation against the worker refers to reprisals for situations in which the worker witnessed and in some way affected the company, by his/her colleagues and/or superiors. The Company prohibits retaliation against anyone who, in good faith, reports or participates in the investigation of a violation or suspected violation of the Integrity Program, investigating any allegation of retaliation, and employees found to have engaged in retaliatory conduct will be subject to disciplinary action, up to and including termination of employment. Megalaser has a zero tolerance policy for retaliation.

Human Trafficking

• Megalaser supports and defends Decree No. 5,948 of 10/26/2006, which deals with the National Policy to Combat Human Trafficking, repudiating the recruitment, transportation, transfer, harboring or reception of people, resorting to the threat or use of force or other forms of coercion, kidnapping, fraud, deception, abuse of authority or vulnerability or the delivery or acceptance of payments or benefits to obtain the consent of a person who has authority over another for the purposes of exploitation, forced labor or services, slavery or practices similar to slavery, servitude or the removal of organs.
• All contracts with Megalaser to carry out the company's activities are based on Brazilian legislation, aware of its role in society and respecting the human person.

Megalaser has an Information and Communication Security Policy, which is a formal declaration by the organization about its commitment to protecting information/data owned by it and/or under its care, and must be complied with by all employees.

The company has technological protection measures in place to access information, through anti-malware, antivirus, firewall and backup mechanisms.

The company has measures in place to protect the personal data of all employees with their express consent, and the designation of a DPO (Data Protection Officer).

Megalaser has a structured program for the prevention of Occupational Health, Safety and Hygiene for all its direct and indirect employees, which must be respected and accepted by all members of the company.

Accident prevention must be considered a priority objective in all areas of the company;

• Preventive activity must be integrated with productivity at all hierarchical levels, which implies that all those involved are obliged to assume the prevention of accident risks as an inherent element of their responsibilities;
• The unrestricted support of management in the execution of its actions is essential, demonstrating leadership in establishing these objectives;
• It is essential that each employee understands and assumes responsibility for their own role in the prevention of industrial accidents, aiming at continuous improvements in working conditions;
• The daily requirement of collaboration from each employee at all levels becomes a commitment; provide unconditional support for the implementation of occupational health, safety and hygiene guidelines to integrate them into the company's safety culture, through their attention, knowledge and cautious action in accepting responsibility for their own safety and the safety of others;
• Willful violation of safety requirements constitutes a serious administrative offense. grave.

Responsibility towards employees requires the best accident prevention measures, and applies to the technical planning of workplaces, equipment and processes, and the work environment must comply with the requirements of a health-oriented design.

Megalaser develops and establishes actions to promote the appreciation and well-being of its employees, promoting integration and quality of life through:

Recruitment, Working Hours and Salaries

• There are no recruitment fees or other fees related to hiring employees.
• All employees work in accordance with the provisions of labor legislation and are registered in the Employment and Social Security Card (CTPS).
• Salaries and hours worked are paid as defined in the collective agreement.
• The hours worked, including overtime, are performed and paid as defined in the collective agreement.
• Before starting work, all employees receive written and understandable information about the working conditions and salaries and benefits.
• There are no deductions from wages due to disciplinary measures without the express authorization of the employee.

Benefits

• Additional benefits are provided to employees, in addition to those described in the collective agreement, such as meals at the workplace, breakfast, and health insurance, providing a better quality of life.

Freedom of Association

• Employees have the right to join forces and negotiate collectively with their union. sindicato de sua categoria.
• Worker representatives in the union will not suffer discrimination and may exercise their representative functions in the workplace.
• The company adopts an open attitude towards union activities as well as towards its organizational activities.
• When the law restricts the right to freedom of association and collective bargaining, the company will facilitate, and not hinder, the development of parallel alternatives for free and independent association and negotiation.

Apprentice

• Megalaser employs minors under 18 years of age as apprentices in accordance with Federal Law No. 10,097/2000, providing methodical technical-professional training compatible with their physical, moral and psychological development.

PCD – People with Special Needs

• Megalaser has people with special needs on its staff, in compliance with the regulations of art. 93 of Law No. 8,213/91.. 

The coexistence of people considered different makes the work environment more productive and humane, as it allows the exchange of experiences, enabling professional and personal growth.

Communication and Training

In order to promote the understanding and dissemination of the ethical and integrity commitments expressed in the Integrity Program policies and procedures, Megalaer promotes periodic communication and training actions, covering employees and other stakeholders.

The communication actions aim to publicize the integrity mechanisms implemented in the company and foster a culture of ethics and integrity, disseminating the Integrity Program (Compliance) regulations and guidelines on issues of fraud, corruption and conflict of interest, to the internal public and also to third parties involved in the company's activities.

Among the actions, training on: ethical conduct and integrity, diversity and harassment at work are carried out periodically for all employees, addressing the Integrity Program guidelines.

Megalaser bases its actions on the search for a healthy internal and external environment, minimizing any environmental impact caused by any form of matter or energy resulting from human activities that directly or indirectly affect:

• the health, safety and well-being of the population;
• social and economic activities;
• biota;
• the aesthetic and sanitary conditions of the environment;
• the quality of environmental resources.

The company considers the identification of aspects and the assessment of environmental, social and economic impacts when adopting strategies related to product development and the selection and use of raw materials and inputs, including in the value chain, meeting the following requirements:

a) acquisition of raw materials and inputs that avoid and reduce the generation of waste, effluents and emissions.

b) acquisition and use of raw materials and inputs that avoid and reduce negative social impacts and enhancepositive social impacts.

c) use of renewable raw materials.

d) use of recycled materials.

e) reuse of inputs.

f) minimization of waste in all of the organization's activities.

g) reduction of consumption of natural resources, such as electricity and water, are priorities.

h) use of waste, aiming at reducing the consumption of raw materials.

j) optimization of the use of raw materials and inputs.

k) proper disposal of effluents and solid waste.

I) prioritizes the disposal of waste from the production process for recycling. 

The company Megalaser, aware that its role in society is much more than employing people, has supported and developed social campaigns in the society in which it operates, the city of Capivari, being an active participant in Social Associations, participating in projects such as “Elderly Friendly Company” among others.

Suspicious/Unsafe Behaviors

Megalaser has an internal policy to detect suspicious and/or unsafe behaviors, whether by its internal/external employees or by people outside the company's premises, in cases where they are loitering around the company's physical perimeter.

The company records all people who visit and/or deliver/pick up goods on a daily basis. It also has external cameras to detect strangers wandering around the outside of the unit.

Employees are instructed not to give information about the company to people outside the company's contact circle and to report any strange facts/persons to the person responsible for Asset Security.

The commitment of the company's senior management is evidenced by the visible and unequivocal support for the Integrity Program, disseminating the culture of integrity through emails, social networks, posters, among others, informing employees and outsourced/subcontracted companies about the importance and need for integrity measures, promoting awareness that corruption, child labor, forced labor, lack of health and safety for workers, excessive working hours, lack of regular payment of wages and benefits, lack of freedom of association, damage to the environment, are everyone's responsibility and must be combated, through the guidelines below:

• The company makes the Integrity Program known to all direct and indirect employees, suppliers, customers, and service providers through electronic messages.
• Training is one of the most important points for the effective functioning of integrity measures. Management and employees will participate in training on topics related to integrity measures, the values ​​that guide the ethical culture, and the main risks related to the company's activities.
• Senior management must also maintain rigorous accounting records of all sales, purchases, loans, income and losses.
• Senior management must prevent fraud and illicit activities in any interaction with the public sector, even if mediated by third parties, such as paying taxes, being subject to inspections, or obtaining authorizations, licenses, permits and certificates, by hiring reputable individuals/companies
• Investigate inappropriate situations or behavior.
• Cut irregularities as soon as they are detected.
• Senior management will actively promote the broad distribution of the Integrity Program Guidelines, as well as ensure their implementation.
• Compliance with the law and the Integrity Program Guidelines will be regularly monitored at all levels of the company.

Definitions:

Bribery: is the intentional offer, suggestion, payment or authorization of payment to someone for personal gain, with the intention of motivating active or passive deviation from functional duty or to guarantee the performance of a function.

Corruption: refers to the state or situation resulting from making available, requesting, authorizing, offering or receiving a bribe.

Money Laundering: consists of a set of commercial or financial operations that aim to incorporate, into the economy, assets, rights or values ​​originated directly or indirectly from any criminal offense.

Terrorism Financing: consists of the allocation of resources to terrorists, terrorist organizations or terrorist acts. The resources may be originated legally or illegally.

The conduct described below is completely repudiated and prohibited in the performance of the activities of the company Megalaser Indústria Metalúrgica Ltda.

• Participating in situations involving money laundering;
• Participating in situations involving financing terrorism;
• Offering or authorizing the offering or suggestion of bribery or kickbacks;
• Accepting, paying or receiving bribes;
• Receiving any undue benefit, fraudulently, from any supplier, favoring the same in internal purchases of the company's materials.
• Requesting or accepting bribes to influence a decision, regarding purchase, sale or contracts, whether in the public or private administration.
• Obtaining unauthorized access to confidential information and passing it on to third parties.
• Committing or failing to act, regardless of whether the result could have been the same if the bribery had not occurred;
• Provenly using an intermediary individual or legal entity to hide or disguise their real interests or the identity of the beneficiaries of the acts performed;
• Using suppliers who are demonstrably involved in situations of corruption, bribery, money laundering, or financing of terrorism;
• Any act that is harmful to the public administration, whether national or foreign, that violates the principles of public administration or the international commitments undertaken by Brazil.
• Promising, offering, or giving, directly or indirectly, an undue advantage to a public agent or a third party related to him/her.
• Provably financing, paying for, sponsoring, or in any way subsidizing the practice of illegal acts provided for in Law 12,843/2013.
• Any act that is harmful to the public administration, whether national or foreign, that violates public assets, the principles of public administration, or the international commitments undertaken by Brazil.

Penalties:

Megalaser Indústria Metalúrgica Ltda, based on the guiding principles of its management, will impose the penalties described below on all direct or indirect employees, as well as on all outsourced/subcontracted companies that violate any item of this Integrity Program, through the establishment of an internal process to investigate the violation, which will be immediately considered serious.

a) Dismissal for Just Cause of the direct employee.

b) Automatic termination of any contractual relationship.

c) Seek full compensation for the damage caused, through applicable legal means.

d) Official communication to the injured authority for the legal measures applicable to the offender, directly or indirectly.

• Occupational Health, Safety and Hygiene and Environment Manual
  
  • Disposal Policy
  • Occupational Health and Safety Policy
  • Company Occupational Health and Safety Policy – ​​OUTSOURCED
• Internal Asset Security Policy
• Information and Communication Security Policy
• User Acceptance Policy
• Procedure: Competence, Awareness and Training
  
  • Company Internal Regulations and Rules.
  • LGPD Consent Form