# Code of Conduct This Code of Conduct (CoC) aims to ensure that the companies we work with, whether they are suppliers or CLIENTS of our services, adhere to high standards of fair and respectful treatment of individuals, a safe working environment, and other ethical practices. Bypassec and its subsidiaries continuously comply with the principles of this Code of Conduct and require their suppliers and CLIENTS to do the same. ## 1. Geral 1.1 We expect our suppliers and CLIENTS to comply with all British Virgin Islands (BVI) laws and any other jurisdictions applicable to their business operations, and to possess all necessary licenses and registrations to operate their businesses and provide products and/or services to us. Our suppliers and CLIENTS must respect and support internationally recognized human rights. They must comply with all applicable laws and regulations regarding privacy, personal data processing, and information security, specifically adhering to the BVI Data Protection Act (2021), the General Data Protection Regulation (GDPR), and the General Data Protection Law (LGPD), particularly regarding the personal information of customers and employees. 1.2 We expect our suppliers and CLIENTS to follow the rules of this Code of Conduct and implement appropriate measures to monitor and ensure compliance within their companies and supply chains. ## 2. Labor Practices 2.1 Suppliers and CLIENTS must comply with the labor laws of their respective jurisdictions, including the BVI Labour Code (2010) and the Brazilian Consolidation of Labor Laws (CLT) where applicable. They must follow local regulations regarding working hours, overtime, vacations, compensation, and social benefits, ensuring that their employees have adequate time away from work. Normal working hours and rest periods must comply with the legal limits of the country of operation, ensuring that compensation is, at a minimum, equal to the legal minimum wage. 2.2 Suppliers and CLIENTS must implement health and safety standards in the workplace that meet or exceed the legal requirements of their jurisdiction, ensuring a safe and healthy environment for all workers. 2.3 Child labor is strictly prohibited. Suppliers and CLIENTS must not employ anyone under the minimum legal age for employment in their jurisdiction, which shall not be less than 16 years of age. Under no circumstances shall they allow anyone under the age of 18 to perform work that is hazardous or harmful to their safety, health, or education. 2.4 Suppliers and CLIENTS must respect the right to freedom of association, allowing employees to join or form unions and engage in collective bargaining without fear of reprisal, intimidation, or harassment, in accordance with applicable local laws and international labor standards. 2.5 Forced, bonded, or compulsory labor is prohibited under all circumstances. All work must be voluntary, and employees must be free to leave their employment upon reasonable notice as defined by their local legislation or employment contract. ## 3. Non-Discrimination 3.1 Suppliers and CLIENTS must not practice or tolerate discrimination in their operations or business relationships. 3.2 All policies regarding recruitment, wages, access to training, promotions, terminations, retirements, and other aspects related to employment must be based on equal opportunity, regardless of origin, race, color, religion, political affiliation, sexual orientation, union membership, nationality, social class, gender, pregnancy, illness, disability, or any other characteristic that could lead to discrimination. ## 4. Anti-Bribery and Corruption 4.1 Suppliers and CLIENTS must strictly adhere to all applicable anti-corruption and bribery laws in the jurisdictions where they operate, as well as international standards. This includes, but is not limited to, the BVI Corruption Act, the UK Bribery Act, the US Foreign Corrupt Practices Act (FCPA), and the Brazilian Law No. 12.846/2013. They must not offer, promise, or provide anything of value to Bypassec personnel to improperly influence them or obtain an unfair advantage, nor shall they accept such items from third parties in relation to Bypassec’s business. Gifts, hospitality, or benefits may only be offered or accepted if they are transparent, modest, permitted by relevant local regulations, and consistent with accepted ethical business practices. 4.2 Suppliers and CLIENTS must avoid any situation that creates a conflict of interest and must immediately notify Bypassec of any potential or actual conflict that could influence the integrity of the business relationship. ## 5. Respect for Nature and the Environment 5.1 Suppliers and CLIENTS must conduct their business with respect for nature and the environment, complying with all applicable environmental and sustainability laws in their respective jurisdictions. This includes adherence to the Environmental Protection and Improvement Act of the British Virgin Islands, the Brazilian National Environmental Policy (Law No. 6,938/1981), and any other relevant local or international environmental regulations. ## 6. Money Laundering and Fraud 6.1 Suppliers and CLIENTS must adopt rigorous measures to prevent any direct or indirect involvement in activities involving money laundering, fraud, or other illegal financial practices. Any suspicious transaction must be immediately reported to the competent authorities, in accordance with the BVI Anti-Money Laundering and Terrorist Financing Code of Practice, the Brazilian anti-money laundering laws, and any other applicable international financial regulations. 6.2 Suppliers and CLIENTS must implement internal policies and procedures to prevent fraud and money laundering, ensuring the integrity and transparency of their commercial and financial operations. ## 7. Global Legal Compliance 7.1 All Bypassec suppliers and CLIENTS must ensure that their operations, policies, and procedures are in full compliance with the laws and regulations of the British Virgin Islands and any other jurisdiction where they operate, including Brazil. This includes, but is not limited to, legislation related to commercial practices, environmental protection, labor rights, anti-corruption, privacy, and data protection. 7.2 By working with Bypassec, suppliers and CLIENTS affirm they are aware of and comply with all legal requirements applicable to their specific industry and sector, ensuring continuous fulfillment of these obligations throughout the business relationship with Bypassec. ## 8. Amendments 8.1 Bypassec reserves the right to update this Code of Conduct periodically to reflect changes in legal requirements or business practices. ## 9. Corrective Measures 9.1 Compliance with the principles set forth in this Code of Conduct is essential for Bypassec. Any failure to comply gives Bypassec the right to immediately terminate the business relationship and any active agreements with the supplier or CLIENT. This article shall prevail over any conflicting terms in other agreements between Bypassec and the supplier or CLIENT. --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://docs.bypassec.com/legal/code-of-conduct.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. 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