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Code of Conduct

We may update Our Code of Conduct from time to time. We will try our best efforts to notify You of any changes by posting the new Code of Conduct on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Code of Conduct. Changes to this Code of Conduct are effective when they are posted on this page.

Last updated: September 12, 2024


For us, DOING THE RIGHT THING is a non-negotiable principle.

It is from this principle that we have built our Code of Ethics and Conduct. For us, no result is justified if we do not do it the right way.

The Code of Ethics and Conduct is a fundamental and imperative document, aimed at all our employees and associates, regardless of their area of ​​expertise, position or function, and geographical location. It must be understood as a priority in all our activities, as it expresses the commitment and engagement in adopting conduct based on the highest ethical standards.

In this sense, the Code of Ethics and Conduct addresses the expected attitudes of employees and instructs on the main situations in which there may be doubts about how to ethically conduct our business.

The expected conduct of our employees is:
• Not tolerating any situation contrary to the Code of Ethics and Conduct.

• Acting with integrity, honesty, and professionalism.

• Report any doubts or situations that may represent or be interpreted as contrary to the law and/or the Code of Ethics and Conduct.

• ALWAYS DO THE RIGHT THING.

RESPECT
We value a diverse and inclusive work environment and do not tolerate acts of prejudice or discrimination, whether based on race, ethnicity, gender, religion, sexual orientation, nationality, ancestry or origin, political position, time spent in the prison system, social class, age, marital status, pregnancy, disability, weight, height, lifestyle, or any other physical or personal characteristic.

Any type of harassment or intimidation is unacceptable. All employees must commit to preventing and eliminating this type of behavior in the workplace and business environment. Harassment and intimidation include any form of inappropriate behavior with sexual, abusive, aggressive, humiliating, discriminatory, or intimidating connotations.

We provide a climate of trust, in which employees have complete freedom to point out problems and clarify their doubts, aiming to solve them in the best possible way with their managers and the employees involved.
We have an obligation and are committed to promoting human rights in our sphere of influence, including our production chain and in our relationships with suppliers, customers, and other third parties. We take due care to identify and eliminate any risk contrary to the definitions of human rights.
We require that operations, suppliers, and customers base their business practices on the eradication of child labor, slave labor, and compliance with current legislation.
THIRD PARTIES
Our relationship with partners must observe integrity, ethics, transparency, and respect for free initiative and free competition. We do not tolerate unethical or illegal practices.
If irregularities on the part of our third parties, or reputational problems, are proven, they must be reported to the manager for analysis of the situation and, if necessary, the adoption of necessary actions.
CONFLICT OF INTEREST
A conflict of interest arises when, due to their own interests or those of third parties, an employee acts or is influenced to act against the company's objectives and principles, making an inappropriate decision that prioritizes personal or third-party interests to the detriment of the company's interests, or failing to fulfill any of their professional responsibilities.
Sometimes, these situations may go unnoticed by the employee, who may think it is an action that does not represent relevance or direct financial loss for the company. However, it is important to be clear that they impact transparency, violate our principles, and may generate risks to the company's image and reputation.

CORRUPTION PREVENTION
The company does not tolerate and prohibits its employees or third parties from acting in their interest or benefit to commit any act of corruption or bribery with public officials or business partners.
The following situations are prohibited and must be immediately reported to the Ethics Hotline if they occur, or are even suspected:
• Omitting, allowing, inducing, or facilitating any form of corruption or bribery, directly or indirectly, through another employee or company representative.
• Failing to report any payment suspected of being improper.
• Manipulating accounting records with the aim of omitting records and transactions.
• Offering, promising, or giving payment, gifts, hiring a family member, or offering any other type of benefit (direct or indirect) to any person, aiming to induce or reward inappropriate conduct, influencing or attempting to illegally influence a decision by a national or foreign public official, or any other person, for the benefit of the company or third parties.

• Soliciting, accepting, or agreeing to receive gifts, payments, or undue advantages from any person (directly or indirectly)

Reward or incentive for inappropriate conduct or conduct that influences or gives the impression of influencing decisions for the benefit of the Company.
COMPLIANCE WITH LAWS
The company and its leaders do not tolerate any type of involvement that represents illegality or that is associated with criminal actions. To this end, the Business areas must establish adequate controls and have their professionals instructed not to engage in actions contrary to the law.
COMPETITIVE PRACTICES
We believe in and adopt free and fair competition, and consider it fundamental to our business relationships.
The company competes ethically and with respect for competition and antitrust legislation. We do not condone and do not accept that our professionals engage in anti-competitive practices, such as cartel formation, market division, price manipulation or predatory conduct.
CORRECT INFORMATION AND DATA
We must follow the laws, internal and external accounting requirements and internal procedures for the disclosure of financial and other business information to shareholders, investors, regulatory bodies and interested publics.

DONATIONS AND SPONSORSHIPS
In this type of relationship with the community, laws must be followed, and involvement in local political issues must be avoided, as well as seeking any reciprocity, present or future, from beneficiaries or third parties who may be served.

CONFIDENTIALITY AND DATA PROTECTION
We must protect the data and privacy of employees, clients, suppliers, and all holders of sensitive information controlled by the company, in accordance with current laws.

DISCIPLINARY CONDUCT AND PROCEDURES
If any action contrary to the Code of Ethics and Conduct occurs, according to evidence and manner of action, disciplinary sanctions proportional to the severity and seriousness of the infractions will be applied, which may even include termination of the contract.

ETHICS CHANNEL
The Ethics Channel is a tool available to receive complaints or suspected cases of violation of laws, this Code, and/or the Company Guidelines.

It is very important that anyone, whether internal or external to the company, who knows or suspects a violation of the laws, the Code of Ethics and Conduct, and/or company procedures (that has occurred, is occurring, or may occur) feels comfortable reporting their concerns directly to the Ethics Hotline.

It is the obligation of employees to report any violation of this Code, if they become aware of it, to the email address finance @ cbjourney.com, marking the subject line “Code of Ethics”.

 

Revision: September 12, 2025

 

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If you have any questions about this Privacy Policy, You can contact us through the contact form on Our website.

Version in Portuguese available here

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