Code of Ethics
São Paulo Surgical is committed to the highest ethical standards, basing its business activities and relations on the principle of transparency and integrity.
The activities routinely performed by all partners and employees must always be in accordance with the legal provisions of our area of operation, ensuring that our business follows high ethical standards, within strict compliance with applicable laws.
We are committed to providing accurate and correct information about the product or service to be provided, respecting the relationship between supplier and consumer, always considering health care, improving the quality of life and protecting the economic interests of our end client.
São Paulo Surgical is in constant search for continuous improvement and excellence through the permanent monitoring of performance indicators, the evolution of its processes, training and qualification of its employees.
All of us who work at São Paulo Surgical have a commitment to life, which is also expressed through the quality of our products and services. In all our activities we must ensure compliance with Quality policies and procedures, guaranteeing our customers, patients and regulatory agents the high standard of safety and effectiveness of our brand.
Our accounting books are detailed to reflect the reality of each payment and expense. All entries will be accurate, honest and made so that the company will comply with legal and regulatory obligations. No employee or director will sign and distribute, nor allow others to sign and distribute on behalf of the company, any documents or statements in which the declarant suspects them to be false.
WORK ENVIRONMENT AND LABOR RELATIONSHIP
It is the duty of all of us to take care that there is no form of discrimination or harassment within the work environment or in working relationships with each other, whether based on race, age, color, religion, or any other that may exist. In this way, all São Paulo Surgical employees are assured of dignified and respectful treatment in the work environment.
Weapons of no kind are allowed on the São Paulo Surgical premises.
Company properties constitute the company’s assets, and we must use them only in the development of the business activities for which they are intended, avoiding the unmotivated deterioration of them.
It is also our commitment not to disclose information that is not in the public domain and that may be useful and give undue advantage to the competition or that would harm São Paulo Surgical and its clients.
We at São Paulo Surgical understand that it is fundamental to guarantee the privacy of each person, whether partners and directors, employees, customers and service providers. We respect the privacy and data protection laws and regulations governing the processing of personal data, in particular the General Data Protection Law (Law No. 13,709/2018 – “LGPD”).
Personal data processing may involve the collection, production, receipt, classification, use, access, reproduction, transmission, sharing, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction of data.
We follow the LGPD principles for all personal data processing activities, such as:
Purpose – All processing must be carried out for legitimate, specific, explicit and informed purposes to the data subject;
Adequacy – The processing must be compatible with the purposes informed to the data subject;
Necessity – The processing must be limited to the minimum necessary for the fulfillment of its purposes;
Free access – Guarantees, to data subjects, of easy and free consultation regarding the form and duration of processing;
Data quality – Guaranteeing to data subjects the accuracy, clarity, relevance and updating of data in accordance with the need and for the fulfillment of the purpose of its processing;
Transparency – Guaranteeing to data subjects clear, precise and easily accessible information about the processing and the respective processing agents;
Security – The processing activities must be guided by the security and protection of personal data, avoiding unauthorized access and accidental situations of destruction, loss, alteration, communication or diffusion;
Prevention – Adoption of measures to prevent damages related to the processing of personal data;
Non-discrimination – The processing may not be carried out for unlawful or abusive discriminatory purposes; and
Accountability – The adoption of measures to prove compliance with data protection regulations is not enough. It is necessary to achieve such measures and their effectiveness.
At São Paulo Surgical, personal data is treated as necessary for legitimate and legally authorized purposes. Any activity of personal data treatment performed by São Paulo Surgical will only be performed if there is a legal basis that justifies it, as provided in the LGPD.
If you have any doubts about the legality of any personal data processing activity, please contact email@example.com .
It is the responsibility of all employees, partners, directors and service providers to ensure the protection of personal data in accordance with our policies.
São Paulo Surgical does not allow its employees to share or disseminate images or videos related to their professional activities on its social networks. Documents and digital files owned by the company, including corporate e-mails, must be protected and their content used only in favor of the company’s business and interests, or when required by the competent authority.
São Paulo Surgical recognizes the importance of providing employees with passwords for personal and exclusive use to ensure the protection of corporate data and, consequently, the continuity of business. For this reason, it is strictly forbidden to share access passwords, and employees are informed of this prohibition through training conducted by HR when integrating new employees.
INTERACTIONS WITH THIRD PARTIES
Negotiations between São Paulo Surgical and clients, suppliers and any others must respect the legal precepts, being forbidden to obtain undue advantages through manipulation, omission, inappropriate use of privileged information, incorrect disclosure of facts, or any other type of negotiation or inappropriate practice.
Our relations with service providers or third parties will be, whenever possible, formalized in writing. Such contracts will guarantee the compliance with the applicable legislation and the best practices of the law in force, also assuring the right to perform independent audits and to contract rescission in case the other contracting party does not comply with the pertinent legal regulation.
We at São Paulo Surgical will not make any undue payments to customers, suppliers, service providers, individuals or entities, especially those who act in public administration, nor will we request or accept any undue payments from suppliers, customers or any individual/entity wishing to do business with the company.
Our competitive practices will be legal, ethical and fair, and will comply with all applicable antitrust and other laws and regulations. We do not allow adjustments with competitors to divide markets, to combine prices or to adopt other arrangements that prevent a fair competition.
Our contacts with public employees in the context of bidding must be made in accordance with the rules of the bidding body and other applicable rules. Informal contacts with public employees involved in bids are not allowed. In discussions for contract negotiation or extension, we cannot aim at obtaining undue advantage from the employee or public agency.
When acting on behalf of the company our actions must prioritize São Paulo Surgical’s interests in relation to our personal interests and under no circumstances may we engage in activities that may compete with São Paulo Surgical’s activities, refraining from obtaining individual advantages due to the exercise of our business activities. São Paulo Surgical’s assets and facilities may not be used for personal purposes by our employees, except in exceptional cases and with prior and express authorization.
The interactions of São Paulo Surgical employees and their partners with healthcare professionals may only involve the presentation or discussion of educational/scientific topics related to the medical products marketed by São Paulo Surgical. No commercial negotiation, delivery of gifts or values to health professionals is allowed by any São Paulo Surgical representative.
Donations may be made for charitable purposes, to philanthropic entities, nursing homes, institutions that care for cancer patients. These donations will always be motivated by good faith and will not be made to clients or directed by sales.
SUSTAINABILITY IN BUSINESS
São Paulo Surgical acts with social responsibility in all its policies, in all its practices, in all its relations with its internal or external public, being always attentive to human rights and to the fulfillment of good labor practices.
In order to ensure compliance with this Code of Ethics and Conduct, cooperating at all organizational levels, the Compliance area is available for clarifications through its agents and existing communication channels whenever any doubt arises regarding the interpretation and compliance with the rules consolidated herein.
INCIDENT COMMUNICATION – DENOUNCEMENT CHANNEL
All São Paulo Surgical associates have the right and duty to report violations of this Code, the Compliance Manual, the Quality Procedures, as well as other internal Policies and Norms and current legislation. For this purpose, the São Paulo Surgical Denouncements Channel is available, accessible through written communication and directed to firstname.lastname@example.org or to the address Av. Engenheiro Luis Carlos Berrini, 105/sala 1201, Ed. Thera Office, Cidade Monções – São Paulo SP, CEP 04571-010, to Compliance Officer. It is also possible to contact by phone 21-99013-0006.
In case of an anonymous report, the report can be made through 0800 878.9030, São Paulo Surgical’s website or https://www.canalintegro.com.br/surgical .
The company, through its Audit and Compliance Committee, will diligently investigate the allegations presented.
The protocol followed is that of confidentiality and aims to preserve the integrity of the information, the success of the verification process and the principle of non-retaliation.
The São Paulo Surgical Audit and Compliance Committee is responsible for internal investigations and for the collection of evidence and evidence, as well as for taking the measures it deems appropriate regarding violations of this Code, internal policies and applicable laws.
Violation of the ethical principles described herein or failure to comply with internal policies will not be tolerated and will result in disciplinary action, which may include termination of employment, if appropriate.