Our Code

of Conduct and Ethics


E-market Participações, Marketing e Serviços em TI Ltda (Kolabori) is a company that operates in the Information Technology segment aiming at its growth, within ethical principles and the satisfaction of its customers and similar institutions, always seeking to maintain a solid reputation, with an awareness of their social and environmental responsibility. Its activities must always be guided by integrity, trust and loyalty, as well as the respect and appreciation of human beings and their privacy, individuality and dignity, without any prejudices and forms of discrimination.



This Code of Ethics aims to resolve issues related to: (i) compliance with rules of coexistence in the work environment, without distinction of hierarchy, areas or functions exercised; (ii) the transparency of operations in general; (iii) the safety of the activities of the professionals involved; and (iv) the security and confidentiality of the information that must be protected by confidentiality.



The includes guidelines for conduct based on ethical and moral standards that will serve as a reference for the behavior of all employees, internal and external, and its application to all members of the Kolabori staff, in the exercise of their functions, including service providers. services, suppliers and business partners that are linked to the institution.



The Company's Legal Representative is responsible for: (i) ensuring compliance with this Code of Ethics; (ii) informing new employees about the Code of Ethics, keeping a record of their knowledge and agreement; (iii) promoting the wide dissemination of the Code and its updates to the Company's staff, customers, service providers and suppliers; (iv) clarify doubts and verify the understanding regarding the content and application.



  • Respect for people.

  • Social responsibility and citizenship.

  • Professional and personal integrity.

  • Transparency in processes.

  • Proud to work at Kolabori.

  • I like challenges.

  • Gender and Race Equity.

  • Commitment to results.

  • Technical competence.

  • Trust and credibility.

  • Confidentiality and security of information.



The directors and employees of Kolabori base their actions on the following principles, in the relationship with the various sectors of society, ensuring:




6.1.1. Professionalism, trust and transparency;

6.1.2. The availability of solutions that add value to its clients' businesses, permanently investing in the search for appropriate technologies and in the improvement of business strategies;

6.1.3. Valuing and respecting compliance with agreements and contracts,

as well as the rights of its clients;

6.1.4. The appreciation of business opportunities and partnerships built

with its customers, aiming at results for the benefit of society; and

6.1.5. The identification, proposition and viability of innovative solutions and

which contribute to reinforcing the legitimacy and sustaining of

your customers.




6.2.1. Recognition of the role and support for the performance of Organs controlling bodies, providing them with relevant and reliable information in due time;



6.3.1. The maintenance of a work environment where the relationship is based on professionalism, trust, cooperation, integration, respect for individual differences and urbanity;


6.3.2. The sharing of their knowledge and experiences, seeking to improve technical training, methods and processes, in order to achieve a better global result for the Company;


6.3.3. Valuing people, contributing to their personal, technical and professional development;


6.3.4. The permanent zeal for the adequate and economical use of the Company's material, technical and financial resources;


6.3.5. The preservation and respect for the image, equity and interests of the Company;


6.3.6. The recognition and appreciation of the Company's intellectual capital and encouraging the emergence of new leaders; and


6.3.7. Valuing and encouraging individual and collective ethical conduct.



6.4.1. Legality, impersonality, morality, publicity and efficiency in all acts performed;


6.4.2. The maintenance of a relationship based on mutual respect, preservation and confidentiality of information relevant to the Company and its customers;


6.4.3. Relationship with suppliers and partners that have practices in harmony with the ethical standard adopted by Kolabori and with social morals;


6.4.4. The establishment of partnerships, provided that Kolabori's image and interests are preserved; and


6.4.5. The rejection of contractual provisions that affront or minimize the dignity, quality of life and social welfare of outsourced employees.




6.5.1. Recognition of the legitimacy and maintenance of a permanent dialogue with the legally constituted workers' representative institutions, maintaining channels of dialogue based on mutual respect, seriousness, responsibility and transparency in relations;


6.5.2. Negotiation as an appropriate instrument to seek integration and convergence; and


6.5.3. Compliance with the determinations made explicit in the instruments that regulate the Company's relationship with its employees.



6.6.1. The establishment of fair and balanced relations with the community through the encouragement, promotion, support and participation in actions of social responsibility and citizenship;

6.6.2. The incentive, support and participation in government actions aimed at social development and the fight against poverty; and

6.6.3. Encouraging the socio-cultural and sports initiatives of its employees.



Kolabori's officers and employees must guide their behavior by this Code of Business Conduct, as listed below.


7.1. Conduct acceptable to the directors and employees of Kolabori:


7.1.1. Preserve and cultivate the positive image of the Company;


7.1.2. To sell, on the Company's premises, only products and services owned and of interest to Kolabori;


7.1.3. Develop conditions conducive to the establishment of a productive and pleasant atmosphere in the work environment;


7.1.4. Treat people and their ideas with dignity and respect;


7.1.5. Proceed with loyalty, justice and frankness in labor relations;

7.1.6. Preserve the well-being of the community, respecting personal characteristics, freedom of opinion and the privacy of each one;


7.1.7. To act with clarity and loyalty in the defense of Kolabori's interests;


7.1.8. Present yourself adequately for the performance of your duties and activities in the Company;


7.1.9. Refrain from using internal or external influences to obtain personal and functional advantages;


7.1.10. Refrain from using the position, the position of trust held or the status of employee of Kolabori to obtain advantages for yourself or for third parties;


7.1.11. Use Kolabori's resources only for purposes of interest to the Company;


7.1.12. Contribute to the smooth functioning of the entire Company, refraining from acts and attitudes that prevent, hinder or hinder the provision of services;


7.1.13. Refuse from individuals and / or legal entities that maintain commercial relations with Kolabori gifts and / or gifts worth more than R $ 50.00 (Fifty Reais).


7.1.14. Do not prepare and present information that reflects real economic, financial, operational, logistical positions and results and any others that affect the performance of the Company;


7.1.15. Prioritize and preserve Kolabori's interests with customers, government agencies, financial institutions, suppliers, entities and other companies with which Kolabori maintains a commercial relationship;


7.1.16. To be accompanied, by another employee or the head or by a couple, when maintaining any relationship with a supplier or partner that results or may result in a contract that meets the interest or need of Kolabori;


7.1.17. Provide strict compliance with the guidelines and strategic business conduct when assuming a function of confidence of the Company; and,


7.1.18. Renounce the exercise of the trust function to which it has been assigned, when there is dissonance with the strategic business guidelines and guidelines.


7.2. Unacceptable conduct for Kolabori officers and employees:

7.2.1. Claim personal benefits or advantages for yourself or for third parties as a result of a commercial or financial relationship entered into on behalf of Kolabori with customers, government agencies, financial institutions, suppliers, entities and other companies with which Kolabori maintains this relationship;


7.2.2. Be conniving or omitted in relation to errors and violations of this Code of Ethics and the current legal and regulatory provisions;


7.2.3. Perform other professional activities during working hours, with or without profit, or even, regardless of the compatibility of schedules, perform activities that constitute losses, direct or indirect competition with the activities of Kolabori;


7.2.4. Exercise any kind of discrimination against people on economic, social, political, religious, colored, racial or sex grounds;


7.2.5. Allow persecutions, sympathies, dislikes, whims, passions or personal interests to interfere in your professional relationships;


7.2.6. Deliberately harming the reputation of an employee of the Company or of any other professional with whom Kolabori maintains a commercial relationship;


7.2.7. Deliberately harming the reputation of customers, government agencies, suppliers, entities and other companies with which Kolabori maintains a commercial relationship;


7.2.8. Plead, request or receive gifts, or advantages of any kind, for yourself or for third parties, in addition to the mere suggestion or provocation for the benefit that is given, in exchange for concessions or privileges of any nature with Kolabori;


7.2.9. Prioritize and preserve personal interests, of customers, government agencies, financial institutions, suppliers, entities and other companies, to the detriment of Kolabori's interests;


7.2.10. Obtain advantages, for yourself or for third parties, resulting from privileged access to information from Kolabori, even if they do not cause damage to the Company;


7.2.11. Use for your own benefit or pass on to third parties, documents, works, methodologies, products, tools, services and information owned by Kolabori or its customers and suppliers, except by legal or judicial determination;


7.2.12. Manifest on behalf of the Company, by any means of public disclosure, when not authorized or authorized to do so;


7.2.13. Make improper and uneconomic use of the Company's material, technical and financial resources;


7.2.14. Prevent or hinder the investigation of irregularities committed in the Company;


7.2.15. Change or misrepresent the content of any document, information or data that is the responsibility of the Company or third parties;


7.2.16. Facilitate third party actions that result in loss or damage to the Company;


7.2.17. Generate any type of patrimonial confusion between the Company's assets and its own assets, regardless of whether the financial advantages derive from this confusion; and


7.2.18. To remain in the exercise of the trust function to which it has been assigned, when there is dissonance with the guidelines and strategic business guidelines.



In case of doubts about what should be the correct conduct to adopt, the employee should seek help in a sincere and transparent manner.


Any situation that may characterize a conflict of interest, or facts that may harm the Company or that contradict the principles of this Code, must be immediately and formally communicated to the Company's Legal Representative.


The Company ensures confidentiality in the conduct of these matters and is committed to investigating reported cases. Situations that may not be explained here, will be treated as an exception and forwarded to the Legal Representative of the Company who will analyze and decide within the principles of this Code.


This Code of Ethics reflects Kolabori's values and culture and its compliance reveals the commitment to professionalism and transparency in all of our actions at work.


Failure to comply with the Code of Ethics will subject employees to disciplinary actions, which may even result in their dismissal for a just cause and in a legal process.


Everyone who has a direct or indirect relationship with Kolabori, must know and ensure compliance with this Code, having the same ethical commitments, regardless of the position they occupy.


Failure to comply with any of the practices and / or procedures described herein may influence the credibility of Kolabori's institutional image, vis-à-vis customers, the market, supervisory and regulatory bodies, the government and society in general.


This Code takes effect from the date of its disclosure. Legal representative of the company:


Manoel Ferreira dos Santos Neto

e-mail: msantos@kolabori.com.br

Mobile: +55 21 99274-7209