Master Standard of the GRICCO Integrity System
Courtesy translation. The official version of this document is the Portuguese original, published on gricco.com.br; in case of divergence, the Portuguese text prevails. Read the original (Portuguese)
Our Commitment to Integrity:
At GRICCO, we understand that lasting success is not built on financial results alone, but on the strength of our reputation, the trust placed in us, and the integrity of our everyday actions.
We operate in an environment of high regulatory complexity and social responsibility. Our clients, partners and suppliers rely not only on our technical expertise, but also on the certainty that we act with ethics, transparency and respect for the law in every jurisdiction where we operate.
This Code is the MASTER STANDARD of our Integrity System. Rather than duplicating rules already detailed in other documents, this version 3.1 consolidates the ETHICAL PRINCIPLES that guide the entire GRICCO ecosystem, with express cross-references to the employment-related implementation (GRICCO-GOV-003), corporate governance matters (GRICCO-GOV-002), data protection and remote work (GRICCO-POL-002), quality/safety/environment (GRICCO-POL-001 and MAN-001) and other procedures.
Every decision, every action, every relationship must reflect these principles. Integrity is not the responsibility of leaders alone — it is a duty shared by all: shareholders, board members, employees, interns, apprentices, partners, suppliers and service providers.
This version 3.1 preserves the advances of version 3.0 — JUST CULTURE, responsible use of GENERATIVE AI and the integration of NEURODIVERSITY — in a LEANER format, avoiding repetition with the Internal Regulations.
We invite you to internalize and live the principles established here. Asking when in doubt is not weakness — it is commitment to our values.
GRICCO Soluções Integradas
This Code formalizes GRICCO's non-negotiable parameters of ethical conduct. Adherence is NEITHER OPTIONAL NOR ASPIRATIONAL — it is a systemic condition for remaining in the ecosystem.
As the MASTER STANDARD of the Integrity System, this Code prevails in the event of interpretive divergence over the other instrumental standards (Internal Regulations, Policies, Manual and Procedures), without prejudice to mandatory legal provisions and the applicable Collective Bargaining Agreements (CCT/ACT).
This Code applies to all members of the GRICCO ecosystem:
These guidelines apply to interpersonal relationships, relationships with clients, with suppliers/partners, with the community and government, in digital communication and social media, and in the use of technology and AI. When in doubt in a situation not expressly provided for, use ethical judgment — ask your manager, Compliance, HR or the Ethics Channel.
In the event of interpretive divergence, the following hierarchical order applies, without prejudice to mandatory legal provisions:
We believe every company deserves to operate with excellence in a simple, uncomplicated way, and every professional deserves an environment where they can apply their talent with freedom and meaning. We exist to make both possible through intelligent connections between people, processes and technology.
We transform regulatory complexity into competitive advantage through integrated solutions that combine technical expertise, artificial intelligence, technology and exceptional human talent, delivering measurable results while creating the environment where the best professionals thrive.
By 2030, to be the most admired compliance manager in the Brazilian energy and navigation sector, recognized as a value-adding partner that turns compliance into competitiveness — innovative, where technology drives results and the best talent reach its full potential.
At GRICCO, the OPERATING PRINCIPLES are PERPETUAL and constitute the ultimate reference of coherence for every decision, document and conduct. The VALUES are expressions derived from these Principles and may be refined over time, provided they never contradict them.
“Our recommendations are based on facts, data and the most rigorous technical criteria. We do not yield to external pressure or momentary convenience. We make the correct diagnosis, even when the truth takes courage to be told.”
“We reject blind bureaucracy and complexity that only confuses. Our role (and our magic) is to distill regulatory and operational complexity into clear, direct, actionable solutions.”
“‘Average’ has no place in our ecosystem. We take full authorship of our projects, from start to finish, claiming for ourselves the responsibility of ensuring the final result generates real, measurable value.”
“We see technology and artificial intelligence not as substitutes for talent, but as levers that expand our capacity. We automate processes to free minds for what humans do best: think critically, create and connect.”
“We are not spectators; we take the lead on challenges. Leadership is an attitude, not a job title. Professional growth and rewards precisely reflect the impact generated and the dedication invested.”
“What brought us here is not enough to take us forward. We remain eternal learners, questioning dogmas and seeking smarter, more innovative ways of working.”
“We communicate openly, honestly and directly, with no hidden agendas. This clarity goes hand in hand with deep respect for the confidentiality of our clients' and partners' strategic and confidential information.”
“We do not treat environmental and social impact as accessory obligations, but as pillars of the business. We design solutions that ensure compliance, financial longevity and protection of the ecosystem.”
“Behind every technology and every contract there are human beings. We prioritize the physical, mental and psychological well-being of our team and partners, with empathy, respect, inclusion of all forms of diversity — including cognitive and neurodivergent — and psychological safety.”
“We look after assets, equipment, the quality of the environment and personal presentation compatible with the level of service we deliver. Care is the tangible manifestation of our professionalism.”
“A complex problem is not solved with an isolated view. We analyze the whole — people, processes, tools and environment — integrating disciplines to deliver complete, definitive solutions that work in practice.”
“We do what is right, even when it costs money. We do not accept victory at any price — we would rather lose a deal than compromise our honor and reputation.”
“Courage to innovate, without losing humanity. In our ecosystem, the HONEST ERROR in the pursuit of innovation is tolerated as collective learning, without retaliation — but arrogance never is.”
“Being good at what you do is not enough; you must be a good human being. We do not tolerate toxicity, lack of camaraderie or disrespect, regardless of position.”
“Technology is the tool; partnership is the goal. We do not deliver mere code or systems — we deliver solutions that solve real problems.”
“Our ecosystem thrives where there is harmony. We promote a healthy, collaborative climate — free of toxicity, light, welcoming and suited to all personality profiles.”
“We build bridges, not just contracts. We value relationships where intelligence and experience are shared transparently. We demand and offer ‘win-win’.”
“We believe in real, transparent meritocracy. We celebrate achievements and ensure that financial and professional growth keeps pace with the size of the deliverables.”
This chapter states the ethical PRINCIPLES of professional conduct applicable to the entire GRICCO ecosystem. Detailed employment-related implementation is set out in the Internal Regulations for Employees (GRICCO-GOV-003 v1.6) — cross-references to the corresponding articles are provided throughout the text.
A conflict of interest arises when personal, financial or family interests interfere — or appear to interfere — with professional decisions made on GRICCO's behalf. The ethical duty is to AVOID conflicts and to IMMEDIATELY REPORT any actual or potential situation.
Fundamental principles:
Implementation: Art. 49 of GRICCO-GOV-003 v1.6 (definition, examples, 5-business-day reporting deadline to the Ethics Channel, anti-nepotism, related-party transactions).
GRICCO's assets — equipment, systems, information, brand, IP, reputation, time and collective labor — are collective resources to be protected and used RESPONSIBLY.
Principles:
Implementation: Arts. 52 to 54 of GRICCO-GOV-003 v1.6 (specific prohibitions, common-sense rules, serious/gross misconduct cases).
The duty of confidentiality is ABSOLUTE and covers information belonging to GRICCO, its clients, partners, suppliers and employees. It survives throughout the contract and for a minimum of five (5) years after separation — subject to specific statutory periods for trade secrets (Law 9,279/96) and sensitive personal data (LGPD, the Brazilian General Data Protection Law).
LGPD principles:
Data Protection Officer (DPO): dpo@gricco.com.br / compliance@gricco.com.br.
Implementation: Art. 47 of GRICCO-GOV-003 v1.6 (confidentiality duties, time limits, sanctions), the Flexible Work and Electronic Monitoring Policy (GRICCO-POL-002 v1.0 — legal bases by purpose, DPIA, data subject rights) and the Data Protection Manual.
Leading by example is a pillar of the Integrity System. Managers, officers and board members have the ADDITIONAL, NON-NEGOTIABLE duty to inspire ethical conduct, foster PSYCHOLOGICAL SAFETY for reporting, and NEVER ignore, conceal or tolerate violations.
A leader's OMISSION in the face of misconduct within their team is an infraction AS SERIOUS as the misconduct itself. PUNITIVE leadership in response to an honest error is itself a disciplinary infraction (consistent with Just Culture).
GRICCO adopts generative AI as a lever for productivity and quality, consistent with the Operating Principle “Technology as a Human Multiplier”.
Ethical principles applicable to employees, partners and third parties:
Implementation: Art. 54 of GRICCO-GOV-003 v1.6 and periodic AI-literacy training (role-based training matrix).
GRICCO proactively assesses ethical risks in operations and partnerships, especially in regulated sectors (maritime, oil & gas, ports).
Annually, or before new contracts of relevant risk, the ETHICAL RISK CHECKLIST — ANNEX 1 to this Code (11 sections, including integrity history, ultimate beneficial owner, public sector, ESG, LGPD, AI and cooperation) is applied. Identified risks require a mitigation plan or rejection of the partnership.
A safe, healthy and psychologically safe work environment is a RIGHT of all and an ABSOLUTE PRIORITY for GRICCO. Employment-related implementation and detailed procedures are set out in GRICCO-GOV-003 v1.6 and GRICCO-MAN-001.
Shared Ethical Responsibilities:
GRICCO adopts JUST CULTURE as a core pillar of the management of errors, incidents and deviations — applicable to the entire ecosystem. This paradigm distinguishes:
Complementary principles:
Implementation: Arts. 36 to 38 of GRICCO-GOV-003 v1.6 (principles), Art. 79 (investigation procedure with Just Culture classification) and ANNEX 2 to this Code (Decision Tree).
GRICCO recognizes that the human element is central. It adopts the discipline of HUMAN FACTORS to consider human capabilities, limitations and behaviors in the design of systems, processes and products — internally and in the solutions delivered to clients. Human errors are frequently the result of poorly designed systems, not individual failures; we design solutions that make correct behavior easy and error difficult.
GRICCO values an environment where everyone feels safe to express ideas, question decisions and raise concerns without fear of retaliation. We support the legal frameworks of Law 14,831/2024 (Mental Health Promoting Company Seal), the updated NR-1 (psychosocial risks) and ISO 45003:2021.
A LISTENING AND PSYCHOLOGICAL SUPPORT CHANNEL is made available through the contracted HEALTH PLAN — ensuring FULL CONFIDENTIALITY and the company's COMPLETE DETACHMENT from the content of the sessions.
Implementation: Art. 38 of GRICCO-GOV-003 v1.6 (mental health program, psychosocial risks, training).
Entering, remaining on premises or performing activities under the influence of alcohol, illicit drugs or non-prescribed psychoactive medication is prohibited. Drug testing in the pre-employment medical examination (ASO) applies ONLY TO LIFE- OR SAFETY-CRITICAL ROLES, as expressly indicated by the occupational physician in the PCMSO (NR-7). For administrative and consulting roles without such risk, testing is NOT required, out of respect for the constitutional right to privacy (Federal Constitution art. 5, X) and the settled case law of the Superior Labor Court (TST). Offshore roles are subject to a reinforced regime (NR-30, NR-37).
Implementation: Art. 35 of GRICCO-GOV-003 v1.6 (detailed rules, chain of custody, LGPD).
GRICCO follows the settled position of the TST and the WHO: CHRONIC ALCOHOLISM IS AN ILLNESS (ICD-11/F10.2). Isolated intoxication on duty may give rise to proportionate disciplinary measures; chemical dependency recognized as an illness does NOT give rise to immediate termination for cause — the Company adopts a HEALTH-PROTECTION approach, with referral to Occupational Medicine, the health plan, possible referral to the INSS (social security), treatment support and absolute confidentiality (LGPD).
Implementation: Art. 78, § 1, of GRICCO-GOV-003 v1.6 (full interpretive note with the scenarios in which termination for cause does not apply immediately).
Mutual respect, collaboration and team cohesion are pillars of our culture. HOW we work is as important as WHAT we deliver. No technical skill, tenure or client relationship justifies an inability to work as a team or the creation of internal conflict.
Regardless of stated intent, context or hierarchy, the following CONDUCT IS NOT TOLERATED:
Implementation: Arts. 56 to 59 of GRICCO-GOV-003 v1.6 (12 detailed prohibitions, professional conduct regarding side conversations, behavioral diversity and REASONABLE ACCOMMODATIONS FOR NEURODIVERGENT PEOPLE integrated into the routine, in line with Law 13,146/2015 — Brazilian Inclusion Law, Law 12,764/2012 — Berenice Piana Law, Law 14,768/2023 and Decree 6,949/2009 — UN Convention).
GRICCO recognizes and celebrates diversity in all its dimensions — gender, race, ethnicity, religion, sexual orientation, age, disability, neurological condition. PRESUMPTION OF COMPETENCE, EQUITY, AUTONOMY and CONFIDENTIALITY guide the relationship. Employees are NOT required to disclose a diagnosis or condition in order to receive reasonable accommodations.
We represent GRICCO in every client interaction. Professionalism, clear communication, transparency, confidentiality and professional boundaries are NON-NEGOTIABLE.
Principles:
Implementation: Art. 43 of GRICCO-GOV-003 v1.6 (context-based dress code — smart casual for clients, business casual at the office, casual Friday when there is no external agenda, attire under the flexible-work regime).
EXECUTIVE GUIDELINE: “If the action requires concealment to be accepted, it is already illegal.”
Gifts and hospitality may be appropriate in professional contexts, but must never influence decisions. Ethical limits:
We compete on the basis of merit, quality and innovation. Prohibited: unlawful acquisition of competitor information; price fixing or market allocation; defamation. Interactions with public officials require special care — gifts, hospitality and entertainment for public officials require prior Compliance approval and a record of the interactions.
Implementation: Arts. 48 to 50 of GRICCO-GOV-003 v1.6 (specific zero-tolerance prohibitions; CEIS, CNEP, OFAC; reporting to the Ethics Channel).
Compliance with environmental legislation (Law 6,938/1981 — National Environmental Policy, Law 12,187/2009 — National Climate Change Policy, Law 12,305/2010 — National Solid Waste Policy); waste reduction and efficient use of resources; sustainable practices across the value chain; evolution toward sustainability reporting under the ISSB IFRS S1/S2 standard as applicable.
If you face an ethical dilemma, ask yourself:
If the answer is “no” or “I'm not sure”, seek help: your direct manager, Compliance, HR or the Ethics Channel.
Implementation: Arts. 70 to 72 of GRICCO-GOV-003 v1.6 (Ethics Channel); Art. 79 (Just Culture disciplinary procedure); ANNEX 2 to this Code (Decision Tree).
Currently, Senior Management decides directly on reports and sanctions. As GRICCO grows, the following transition is formalized:
The Compliance function issues quarterly reports to the Executive Board covering: number of reports; training adherence rate (100% target); violation KPIs; Just Culture indicators (spontaneous reports, Lessons Learned, recurrences). Annual internal audits focus on risk areas (gifts, conflicts, AI, LGPD).
Violations are handled with IMPARTIALITY and PROPORTIONALITY, observing the JUST CULTURE typology. Recurrence escalates the level by one. This matrix states the ethical PRINCIPLE; the detailed employment-related implementation is set out in ANNEX I of GRICCO-GOV-003 v1.6.
| Typology (Just Culture) | Ethical Characterization | Organizational Response (principle) |
|---|---|---|
| HONEST ERROR | Unintentional mistake by a competent, diligent worker; failure caused by deficient process, instruction, system or training. | NO PENALTY. Systemic correction + training + Lesson Learned. |
| MINOR | One-off non-compliance with a procedure; carelessness without material damage; improper incidental personal use of assets — AFTER guidance. | Verbal warning → written warning upon recurrence. |
| MODERATE | Repeated absences; negligence; non-compliance with low-risk OHS rules; misuse of equipment or social media; minor insubordination. | Written warning; 1–3 day suspension (CLT art. 474). |
| SERIOUS | Intoxication on duty (not illness-related); refusal to use PPE; material breach of confidentiality; undisclosed conflict of interest causing loss; personal use of high-value assets. | 5–30 day suspension + remediation plan + risk of termination for cause. |
| GROSS MISCONDUCT | Dishonesty; theft; fraud; bribery; cartel conduct; moral/sexual harassment; discrimination; retaliation; willful IP breach; use of AI for fraud/deepfakes; willful LGPD violation; unfair competition. | TERMINATION FOR CAUSE (CLT art. 482) + civil/criminal action + reporting to authorities. |
This Code will be reviewed every twelve (12) months or upon a material legislative change. Any waiver for officers/executives may only be granted by the Executive Board or by a committee of the Board, with disclosure as required by law.
Signing the ADHERENCE TERM to this Code is NOT a one-time event — employees and leadership will renew their commitment ANNUALLY, attesting to reading, understanding and the absence of unreported violations.
SUPPLIERS AND THIRD PARTIES — bound by standard clauses in commercial contracts, with contractual sanctions in case of violation (termination and inclusion on a block list).
TRAINING PROGRAM — all employees take part in an annual program under the ROLE-BASED TRAINING MATRIX maintained by HR/Compliance, which reflects legal requirements (NRs), contractual requirements (operator clients) and ethical requirements (Code of Ethics, LGPD, Anti-Corruption, Just Culture, AI, DE&I/Neurodiversity, OHS).
This Code is publicly available at www.gricco.com.br/etica-e-compliance, accessible to all employees, partners, suppliers and other stakeholders.
Applied annually and before new contracts of relevant risk. Documented by the Compliance function.
1. Identification
Name/CNPJ (tax ID); country; type of relationship; sector; contract value and term.
2. Integrity History
☐ Public records of corruption/fraud/cartel/laundering ☐ Relevant negative news ☐ CEIS/CNEP/OFAC listings ☐ Compliance history with regulated companies ☐ Abnormal volume of labor/environmental lawsuits
RED FLAG: consistent evidence of prior involvement in corruption, fraud or cartels.
3. Corporate Structure and Ultimate Beneficial Owner
☐ Ultimate beneficial owners identified ☐ Complex structures with unjustified offshore entities ☐ PEPs in ownership/management ☐ Headquarters in high-risk jurisdictions ☐ Size compatible with the operation.
RED FLAG: unidentified ultimate beneficial owner, offshore entities or PEPs without controls.
4. Relationship with the Public Sector
☐ Frequent interaction with public bodies ☐ Intermediation of licenses/permits ☐ Offers of “facilitation” ☐ Internal anti-corruption policy ☐ Documented records of interactions.
RED FLAG: proposals to “facilitate” processes with extra payments lacking contractual clarity.
5. Commercial Terms
☐ Prices aligned with the market ☐ Disproportionate discounts/commissions/bonuses ☐ Payment to third-party accounts, abroad or in cash ☐ Opaque clauses ☐ Intermediaries with unclear compensation.
RED FLAG: payments to third parties, unexplained payments abroad, or excessive unexplained commissions.
6. The Third Party's Compliance Program
☐ Formal code of ethics ☐ Periodic training ☐ Whistleblowing channel ☐ Segregation of duties ☐ Accepts anti-corruption and LGPD clauses.
RED FLAG: refusal to sign anti-corruption/LGPD clauses.
7. Data Protection (LGPD)
☐ Processes personal data for GRICCO or clients ☐ LGPD policy ☐ Information security controls ☐ Accepts processor/controller clauses ☐ Incident history.
RED FLAG: resistance to LGPD requirements or to notifying incidents.
8. ESG, Human Rights and Labor
☐ Commitment against child/forced/slavery-like labor ☐ Adequate working conditions ☐ DE&I policies ☐ History of citations ☐ Environmental concern.
RED FLAG: serious history of human rights violations or slavery-like labor.
9. Sector Risks — Maritime/Oil & Gas/Ports
☐ Operations in ports/vessels/platforms ☐ History of informal payments to pilots/agents/inspectors ☐ Pressure for incompatible deadlines ☐ Understanding of NORMAM/ISM/ANP ☐ Reports of “workarounds” (jeitinhos).
RED FLAG: promises to resolve everything quickly through non-transparent means with authorities.
10. Generative AI Risks
☐ Use of AI in deliverables for GRICCO/clients ☐ Internal use policy ☐ Commitment not to train models with GRICCO IP/data ☐ Human verification of outputs ☐ Accepts responsible AI use clause.
RED FLAG: use of AI without governance or with exposure of sensitive data.
11. Cooperation and Conclusion
☐ Responded completely and in a timely manner ☐ Verbal/documentary inconsistencies ☐ Openness to providing documents ☐ Delays or evasiveness.
Ethical risk rating: ☐ LOW ☐ MEDIUM (mitigating controls) ☐ HIGH (not recommended / reinforced mitigation + Executive Board approval)
Mitigation measures: ☐ Reinforced clauses ☐ Limitation of scope/values ☐ Joint training ☐ Frequent monitoring.
Executive Board decision: ☐ Approved ☐ Approved with conditions ☐ Rejected
Summary of the Just Culture methodology applied by GRICCO in any investigation of an incident, error or deviation. Operational detail in Art. 79 of GRICCO-GOV-003 v1.6.
“Would another competent worker, under the same conditions (same training, instruction, resources, pressure), have acted the same way?” YES → honest error / systemic failure. NO → Test 2.
“Was there knowledge of the rule and adequate training?” NO → systemic training failure. YES → Test 3.
“Was the conduct conscious and deliberate?” NO → at-risk behavior (coaching). YES → Test 4.
“Did the person perceive the risk and proceed anyway?” NO → at-risk behavior. YES → reckless conduct (proportionate sanction). If there was INTENT TO HARM/DEFRAUD → willful misconduct (full accountability).
The worker's history is used to calibrate the sanction, respecting gradual escalation.
Outcome — Regardless of the Diagnosis, Always:
Confidentiality guaranteed, no retaliation. Reach Compliance or our Data Protection Officer (DPO).