The sustainable success of Modena Saúde in an ethical, honest and integrity manner depends on the conduct of each one of us, and management must be guided by example, always ethically, with integrity and transparency, in an environment with diversity and respect.

Please read the Code carefully and make sure you understand all of your obligations. If you have any questions after reading the Code or in the course of your daily life, please contact one of the resources identified in this Code of Conduct.

We thank you for your continued commitment to compliance with this Code of Conduct and your dedication to your work. Your support is critical to the continued success of our Company

Our commitment to ethics and transparency depends on the commitment and engagement of all of us.

We count on you.

ACT ETHICALLY WITH HONESTY AND TRANSPARENCY

is to build the common good in our midst.

THE POSITIVE IMAGE OF MODENA SAÚDE

It is an asset of its partners, managers and employees.

INTRODUCTION

The principles presented in this Code of Conduct direct and support the fulfillment of our Mission and Vision, respect for our company’s Corporate Values ​​and seek to guarantee the image and reputation of Modena Saúde, as a Brazilian company recognized for the quality of its processes and for its ability to generate financial, social and environmental value.  We value professional and personal relationships.

The Code of Conduct aims to guide daily activities, interactions and decisions based on the Principles and Conduct described, being a fundamental pillar of Compliance at Modena Saúde. The way in which we achieve our results is important for the sustainability of our business growth.

All employees and third parties who have relationships with our company must be committed to our principles, being responsible for disseminating and practicing these values.

Therefore, compliance with this Code is mandatory, and it is each person’s responsibility to read it completely and carefully, always keeping it close by for consultation. The text may not contain definitive answers for all situations. Therefore, always reflect and question. Questions related to the application of day-to-day conduct or the interpretation of this Code can be clarified with managers or through the Questions Channel compliance@modenasaude.com

REASON FOR BEING

MISSION

To be recognized as an innovative company with excellence, striving for balanced relationships, contributing to the appreciation of life, results and satisfaction for everyone.

VISION

Be different in the market, acting with ethical and coherent positions, promoting the sustainability of business relationships, valuing the commitments made, and organizational improvement.

VALUES

• Commitment
• Ethics
• Transparency
• Integrity
• Quality services
• Valuing the human being
• Social and environmental responsibility.
• Integrity

PRINCIPLES OF BEHAVIOR

Our attitudes must always be in tune with our culture of values. Integrity, transparency, respect for people and the environment, dignity, loyalty and trust are universal concepts that should serve as a guide for our behavior at work and in life in society.

Integrity and Transparency

A person of integrity always acts transparently, is honest with themselves and others and their behavior is straight and unassailable. Integrity does not admit that our private interests are in conflict with the interests of the company.

Below, see examples where conflicts of interest occur and what is the correct behavior to adopt:

Internal Standards and Processes

It is the duty of all Modena Saúde professionals to comply with current internal standards, which involve guidelines and approval levels, as well as any other regulations, standards, processes and procedures and the need for signatures from legal representatives. We do not tolerate conduct that influences others to fail to comply.

No activity or project should be started without first checking whether there is an applicable internal standard or current process and procedure.

Questions regarding compliance with any law or regulation should be directed to managers for clarification or forwarding to the responsible areas.

Questions about the application of internal rules and other Modena Saúde documents must be clarified with the managers or areas that authored the documents.

Side activities during work hours

Activities that are not those relevant to your role in the Company or those that affect your performance and impact your productivity are prohibited as they are not linked to Modena Saúde.

The use of internet Code of Conduct tools, such as social networks, for the dissemination and marketing of products and services, during working hours, is also not permitted.

The sale of products, raffles, among others, on company premises is expressly prohibited.

It is also not permitted to use Modena Saúde infrastructure for private purposes (equipment, technology, meeting rooms, among others).

Political or Religious Activities

It is prohibited to carry out any political or religious activity during the working day, using Modena Saúde resources or on company premises, even in the form of an individual demonstration.

Participation in political or religious activity must not have any connection with Modena Saúde or any of its companies.

If you decide to be a candidate for political office, the Modena Saúde professional must withdraw from their professional activities, requesting unpaid leave.

Shareholding in companies

If you have direct or indirect ownership interest in companies – regardless of the segment of activity –, whether or not related to the Modena Saúde business, you must inform the Corporate Risk Management Area in writing.

Relationship in companies

Likewise, if you have a direct or indirect degree of kinship in supplier companies, competitors or with activities related to those of Modena Saúde, such as health, well-being, beauty or others, you must also inform, in writing, the Management Area of Corporate Risks.

Suppliers and business partners

The selection and hiring of suppliers must be conducted exclusively by the Supply Area.

Modena Saúde employees are not permitted to pay and/or receive bribes.

Any practice of corruption, in all its forms, through acts, omissions, creation or maintenance of favoritism, is prohibited.

It is prohibited to accept, request or offer, directly or indirectly, favors or gifts that result from relationships with the company, and that could benefit third parties to the detriment of the interests of Modena Saúde.

The offering or receipt of gifts, gifts, loans and kindness will only be acceptable if they do not influence negotiations between Modena Saude and third parties, and their value does not exceed R$500.00.

Gifts must be received within the company, observing the following criteria:

– They are not illegal nor do they violate conduct;

– They cannot be seen as a bribe, payment or undue attempt to exert influence;

– Do not cause embarrassment to Modena Saúde or its employees, when publicly revealed;

– They do not infringe, in any way, the company’s values ​​and principles.

Kinship

The company does not accept any situation of kinship between employees in the same area, regardless of the position or hierarchical level of the people involved.

All existing cases must be formally communicated immediately to the Corporate Risk Management Area, which will analyze the presence or absence of a conflict of interest.

Hiring relatives of employees should be avoided, as well as hiring employees who have relatives in competing companies, suppliers, customers and/or other service providers in the pharmaceutical segment. As relatives, we include the employee’s spouse or partner, and family members such as parents, grandparents, children, brothers, uncles, nephews, cousins, brothers-in-law and brothers-in-law of the employee and their spouse or partner.

Respect for people and the environment, respecting people and the environment is part of our culture of values ​​and is an absolute condition for the individual and professional development of each person.

Below are some behaviors that demonstrate respect for people in the workplace:

– Treat everyone you interact with politely and with dignity. Courtesy in relationships produces a more pleasant work environment.

– Do not commit or allow any type of discrimination based on gender, sexual orientation, ethnicity, religion, age group, political conviction, nationality, marital status, physical condition or social class to occur. We must value diversity and different cultures.

– Any type of harassment – ​​whether sexual, moral or economic – or situations that constitute pressure, intimidation or threats in the relationship between employees, regardless of their position, is reprehensible behavior that must be eliminated from our daily lives.

– Employees who consider themselves to be in a situation of disrespect, discrimination, prejudice, pressure or abusive practices, and feel embarrassed to discuss the matter with their immediate superior, must report the fact directly to the Corporate Risk Management Area or to the Ombudsman channels presented in the Responsibilities chapter.

– Do not use your position, function or information about the company’s business and matters, or those of its customers, to influence decisions that may favor your own interests or those of third parties.

– Critical observations regarding the acts or attitudes of public officials or comments of a political nature will not be permitted.

Avoid destructive comments towards our competitors. Treat other companies with respect and professionalism.

– Commercial relationships must be established with companies that, like Modena Saúde, respect labor and environmental legislation and do not use child or slave labor.

– Act in accordance with Modena Saúde’s Occupational Safety, Health and Environmental Policy and comply with published procedures.

Valuing human beings means improving the lives of people and the community; Preserving the environment is also part of this action.

Dignity

Having dignity means having respectability and moral authority. It’s knowing how to behave appropriately anywhere.

Every employee is responsible for the image and reputation of the company where they work.

It is prohibited to use, possess or transfer illegal drugs within company premises. It is not permitted to work under the influence of alcohol or drugs.

Employees are prohibited from acting violently or making threats, nor are they permitted to carry or use weapons in the workplace.

Betting and gaming are prohibited within the company.

These attitudes are contrary to the dignified image of professionals that we are.

Loyalty and trust

Being loyal is responding to the trust someone places in us. Being a trustworthy person means inspiring security in others.

Use facilities, equipment and materials correctly and responsibly, avoiding losses and unnecessary expenses. Remember that they are your working instruments and are intended for the exclusive use of your operations, and not for private purposes.

Use the knowledge you have about your daily activities to improve existing work processes. An innovation based on your experience can reduce costs and/or increase productivity.

Do not use the internet for personal purposes, especially to access websites unrelated to the company’s affairs or that have content of a purely social nature, such as Facebook and other networks of this nature.

Don’t waste your working hours on matters beyond your control.

Remember that email (@modenasaude.com) must be used solely for professional purposes and may be monitored as it is the property of the Company.

CONFIDENTIALITY

Modena Saúde requests confidentiality from its employees in relation to intellectual property, which are patents, registered trademarks, know-how, technical data, process and market information, among others. This is strategic information that needs to be kept confidential.

All results of intellectual work and strategic information generated in the company are the exclusive property of Modena Saúde.

Interviews

No employee is authorized to give interviews on behalf of Modena Saúde. Nor is any type of statement permitted on behalf of the company without authorization. The company has official spokespersons, authorized to speak on behalf of the Company.

When receiving any interview request, forward it to the Communication and Social Responsibility Area, responsible for conducting the process with the Press Office.

Classes and Lectures

When invited to give lectures, classes or make presentations on behalf of Modena Saúde, submit the invitation for approval by the Corporate Risk Management Area.

Directors must obtain authorization from the Partners before accepting invitations to lectures, classes or presentations from the Company.

Photos and videos

It is expressly prohibited to take photos or film footage within the company’s environment, without prior authorization from the Corporate Risk Management Area, as well as to produce videos or photos in the Company’s environments for private purposes.

The publication of these photos or videos on websites or social networks is also not authorized.

Only official and duly authorized images may be disclosed, such as marketing actions.

Partners and Shareholders

It is with the investment of partners and shareholders that we realize our growth plans.

Therefore, we are committed to providing them with a fair return and ensuring the appreciation of the company’s assets.

We seek a solid relationship, through accurate and transparent communication of our activities and economic and financial performance, and the fulfillment of our Mission and Vision.

Collaborators

Respect for people is one of the pillars of Modena Saúde’s actions.

Our company observes the rights and duties of employees and treats everyone equally, from recruitment to the end of the employment contract, a role that leaders must guarantee.

In the constant search for your satisfaction, we create communication channels that ensure active dialogue.

Customers and Consumers

Establish lasting relationships with all our external audiences based on our COMMITMENT TO INTEGRITY, with respect and cooperation. Our credibility depends on the positive relationships we build and maintain with our audiences, which are fundamental to the sustainability of our growth.

Modena Saúde works constantly to meet the needs and expectations of our Customers and end consumers.

We respect their rights and provide relationship channels with this public, so that they can make suggestions, criticisms and observations about what we produce, whenever they wish.

This direct communication allows us to develop solutions for consumers and improve our products, which benefits everyone.

Doctors and Health Professionals

Our relationship with the medical profession is based on trust. Modena Saúde has deep respect and recognized work with this public, a beneficial proximity to society. We value life. And those who value life, value medical prescriptions.

Customers

We consider clients, pharmacy chains, independent pharmacies, hospitals, oncology clinics and public entities focused on dispensing medicines. Our relationship with this audience is based on business partnerships, always guided by satisfying and exceeding their expectations.

Trust and mutual respect between the company and its customers is our way of thinking.

Suppliers

Modena Saúde works to develop its suppliers, offering learning and qualification opportunities.

To become our partners, we require companies to also comply with legislation, environmental and safety standards, and the statute of children and adolescents.

When choosing and hiring suppliers, we carry out transparent competitions, based on technical, professional and ethical criteria. At any time, any supplier that fails to meet the aforementioned requirements will be disqualified.

Community

Modena Saúde has the role of a corporate citizen.

Therefore, in addition to providing excellent products for health and well-being, we are also committed to the social development of the community and the balance of the environment.

To be an agent of social evolution with the different audiences with which we work, valuing harmonious coexistence and the common good, with transparency and integrity. Modena Saúde was born caring for people and we want to continue like this Compliance with Laws, Regulations, Internal Standards and Processes Legislation and Regulation

We do not tolerate non-compliance with any applicable laws or regulations in force, including international ones, as well as conduct that influences others to non-compliance.

We must know and comply with all laws and regulations that affect daily work completely and constantly, ensuring that activities are updated in a timely manner.

Government

We maintain a cordial relationship with the public sector, especially with the Ministry of Health, State Secretariats, Municipal Secretariats, Public Hospitals and the National Health Surveillance Agency (ANVISA), which regulates the activities of the pharmaceutical sector.

Modena Saúde and its employees undertake to comply with the legislation and not take any action that violates current laws, regulations and internal and external standards.

Competition

We believe in fair competition, based on the quality, reliability and competence of each company. We maintain a cordial and respectful relationship with our competitors and are committed to cooperation to achieve common goals.

Media and Press

Modena Saúde’s relationship with this public is guided by the truth. Our Communication Area is responsible for serving you promptly and clearly, providing institutional information and our activities, whenever necessary.

Environment

Modena Saúde reaffirms its commitment to valuing life, considering in its operations all aspects related to the environment and also work and health safety. Waste resulting from our operations must be disposed of in accordance with established legal principles and current environmental standards.

Any occurrence at our facilities that could harm employees or the community must be communicated openly.

CODE OF CONDUCT MANAGEMENT

Compliance with this Code of Conduct is everyone’s responsibility and is supported by the Corporate Risk Management Area and the Modena Saúde Ethics Committee.

All Modena Saúde professionals must read the Code of Conduct and try to understand the guidelines and guidelines published in this document. If you find it difficult to understand any topic discussed, you can clarify your doubts with your direct superior or with the Corporate Risk Management Area.

Violation of the attitudes and values ​​recommended by the Company, expressed in this Code of Corporate Conduct, is subject to sanctions by Modena Saúde.

RESPONSIBILITIES

Teams

It is the duty of every employee to know and practice the provisions of this Code of Conduct.

Employees will also be responsible, within their responsibilities, for preserving the name, reputation and image of Modena Saúde.

Employees must base their work relationships on the principles of transparency and correctness, ensuring alignment with their leadership in any situations of doubt or potential conflict.

Managers

Leaders, especially through the dedication of their time, their presence and experience and, above all, through their example, have the obligation to contribute to ensuring that their teams fully comply with this Code of Conduct, and must:

– In cases of suspicion or identification of those who have violated this Code of Conduct, the Manager must report the matter to the Corporate Risk Management Area.

– Work effectively with the team, encouraging compliance with this Code of Conduct.

Disciplinary Measures

Full understanding and compliance with the guidelines of this Code of Conduct is a fundamental condition for the professional and supplier to remain on the staff of Modena Saúde.

Failure to comply with the principles and commitments expressed in this Code of Conduct will be treated as a matter of extreme seriousness, and may result in:

For your professionals

Adoption of disciplinary measures, which may include warning, suspension, cancellation of variable remuneration and even dismissal for just cause, according to the level and nature of the infraction, as well as in accordance with applicable laws, without prejudice to civil liability, applicable criminal and/or administrative.

For your Suppliers

Termination of the commercial relationship, without prejudice to applicable civil, criminal and/or administrative liability.

ETHICAL LINE

Any professional and/or supplier who is undecided on how to act or is aware of any illegal act or non-compliance with this Code and Conduct, or suffers any form of pressure or illicit request from public or private agents, must immediately notify the company through the ombudsman.

The Ethics Line guarantees the absolute confidentiality of the identity and confidentiality of the information provided. No one will be punished or retaliated against for information provided in good faith about suspected inappropriate behavior or behavior that is contrary to this Code of Conduct.

This Code of Conduct is public and available on the website www.modenasaude.com

Any suggestion, complaint, criticism or report regarding non-compliance with the Code of Conduct guidelines can be forwarded to the Corporate Risk Management.

Your manifestation can also be directed to exclusive contact channels:

Internet www.modenasaude.com

Email compliance@modenasaude.com