Code of Ethics

ABOUT

DIGITAL HUB is one of the leading companies in Latin America certified by Adobe as a Solution Partner. We work toward high code quality and the greatest possible delivery of value in projects, passionate about making large ideas and business needs viable. We help companies explore technology solutions for Digital Experience and Adobe Experience Cloud in the context of each company and business model.

Our work is holistic in sustaining operations on Adobe Experience Cloud, covering solution architecture, front-end and backend development, UX/UI design, infrastructure, and integrations.

OUR VALUES

Fellowship – We value good faith and camaraderie in all of our personal and professional relationships. For us, character and essence define people, and we work to be better human beings every day.

Team First – For us, the team matters more than the individual. That requires a continuous commitment from everyone to develop individual skills and competencies that serve the common good and shared results. We do not tolerate ego, and we value people who are willing to help and to develop new potential and talent.

Boldness – We do not hide behind mistakes and blame. We state our opinions frankly and transparently in the search for solutions, so that mistakes become teachers and not only accusers. We create a collaborative environment. We believe that constructive conflict of ideas is what leads to success.

Intensity – We turn energy into growing and steady results. We stay away from mediocrity. We do not settle, and we always aim for 101%.

Health – We create value so we can enjoy life with wisdom and share it with society. We care about the physical and mental health of all of our stakeholders.

DIGITAL HUB’s principle is to conduct business fully supported by ethics, with a commitment to the legal, environmental, and social spheres.

This code exists to share the values and principles that must guide all of DIGITAL HUB’s business and its relationships with stakeholders and with society in general.

Through this document — based on the highest international standards of corporate governance — we set the behavior we expect and the conduct of our operations.

SERVICE RELATIONSHIPS

CONTRACTS

DIGITAL HUB will enter into contracts that respect all local laws, and it will not tolerate professional and/or commercial relationships that depart from this premise or that are not governed by formal contracts.

WORKING HOURS

DIGITAL HUB will respect the maximum working hours set by the local law in force.

WORK RESOURCES AND TOOLS

All of DIGITAL HUB’s work tools and resources, such as email channels and accounts, task management and tracking software, domains, applications, smartphones, computers, and/or any other physical or digital device, exist for the sole purpose of serving our business and corporate aims. Personal use is not allowed.

VALUING AND RESPECTING THE HUMAN PERSON

DIGITAL HUB values the human person in full. It does not discriminate, and it condemns any kind of discrimination or preferential treatment based on gender, nationality, race, color, ethnic or social origin, age, marital status, motherhood or fatherhood, creed, political conviction, disability, sexual orientation, or any other form. It requires the same behavior from all of its suppliers.

HARASSMENT

DIGITAL HUB will not tolerate actions that attack human dignity. Our culture is free of any form of physical, sexual, psychological, or verbal harassment or abuse.

QUALITY OF PRODUCTS AND SERVICES

DIGITAL HUB’s strategic purpose is to be the best structured and most profitable Digital Experience company in Latin America, with a global reach. To that end, it sets criteria of the highest quality in the delivery of its products and services.

HEALTH AND SAFETY

DIGITAL HUB provides a workplace free of risk and in compliance with the laws and rules that apply to its activity, always putting everyone’s safety and health first.

CONDUCT AND POLICIES

CONFIDENTIALITY AND SECRECY

DIGITAL HUB commits to protecting the secrecy of all data belonging to its clients, partners, suppliers, employees, and every other stakeholder who relates to it and provides personal information, commercial information, technical knowledge, and other information.

It commits to using all of its powers to fulfill this item faithfully, whether in relation to partners, affiliated companies, administrators, agents, employees, and/or any people under its responsibility (direct or indirect).

It is obliged, at all times, to keep the most complete and absolute secrecy over any data, materials, information, documents, technical or commercial specifications, innovations, and improvements obtained — in short, everything entrusted to it by reason of its relationships, whether of interest to DIGITAL HUB itself or to third parties. It may not, under any pretext, disclose, reveal, reproduce, use, or make them known to third parties outside this engagement without the prior consent and agreement of the parties involved.

It is responsible for any breach of secrecy that may occur, even if carried out by its employees and/or agents who, at the time of disclosure, no longer have any contractual tie with it. If that happens, it may take every applicable legal measure against the person who violated secrecy, so that person bears the losses sustained, whether administratively or in court.

INTEGRITY AND TAX RESPONSIBILITY

DIGITAL HUB commits to being in compliance with its corporate acts, and to observing and complying with the applicable laws.

It declares that it is in compliance with all of its corporate responsibilities, in a way that does not violate its corporate acts, and that the applicable corporate law was observed in its formation.

It commits to keeping its tax standing regular and all conditions required for contracting, curing any irregularities or inaccuracies pointed out by any stakeholder in the course of a contract, and to providing tax-compliance certificates when requested.

GENERAL PERSONAL DATA PROTECTION LAW — LGPD

DIGITAL HUB will adopt every security measure aimed at protecting its own data and the data of its clients and of those who contract its services, through proper storage, the use of access-control tools and firewalls, and protection against unauthorized access, whether accidental or not.

It will keep in absolute secrecy all data and information entrusted to it. This obligation survives the end of the services. It will not process personal data in a place other than the one established, and it will not retain any personal data for longer than necessary to perform the services.

In the event of a security incident, or a suspicion of one, that may imply relevant risk or harm to data subjects, DIGITAL HUB will report the event to dpo@digitalhub.com.br within a maximum of 12 (twelve) hours of becoming aware of it, stating:

I – a description of the nature of the personal data affected;
II – information about the data subjects involved;
III – the technical and security measures used to protect the data, observing commercial and industrial secrets;
IV – the risks related to the incident;
V – the reasons for the delay, if the notice was not immediate; and
VI – the measures that were or will be taken to reverse or mitigate the effects of the harm.

When the services end, when the purpose of the processing is achieved, or when the data is no longer necessary to perform the services, DIGITAL HUB will delete it from its system, as well as any copies, whether documentary or magnetic/digital.

Any question about the processing of sensitive data inside DIGITAL HUB should be sent to the Information Security Steering Committee at dpo@digitalhub.com.br.

GIFTS AND PRESENTS

No DIGITAL HUB employee or service provider will offer or receive gifts and/or presents — or any other items — in order to avoid any conflict of interest in commercial and/or professional relationships.

If a gift and/or present is received without DIGITAL HUB’s prior knowledge, the employee or service provider must tell DIGITAL HUB’s People and Culture area what happened. That area will review internally whether the gift and/or present should be accepted or donated.

FAMILY RELATIONSHIPS

To avoid any kind of conflict of interest in personal and/or professional relationships, any family relationship or close affinity between DIGITAL HUB employees and/or service providers must be reported to the People and Culture area.

Subordination between relatives, or between people of close affinity, among service providers and DIGITAL HUB leaders is not allowed.

Family and affinity relationships can and will be accepted as long as they do not interfere with the independence and impartiality of professional relationships. Even in those cases, they must be reported to DIGITAL HUB’s People and Culture area.

ETHICAL DECISIONS

Every DIGITAL HUB employee and/or service provider is responsible for acts that could reflect negatively on the company, whether carried out inside or outside the company’s premises.

For that reason, DIGITAL HUB commits to publishing this code and making it thoroughly known to all of its employees and service providers.

Every employee and/or service provider should keep the following questions in mind before any act, whether or not it is in DIGITAL HUB’s service:

• Am I breaking any law?
• Is this in line with DIGITAL HUB’s principles and values?
• Could it bring negative consequences for me and for DIGITAL HUB?

If you are unsure what to do or how to behave in a given situation, ask for guidance. Discuss it with your manager or with the People and Culture area, who are always available.

COMMUNICATION CHANNEL AND OMBUDS OFFICE

DIGITAL HUB provides an exclusive email for our ombuds office and for reports related to this code of conduct: ouvidoria@digitalhub.com.br.

Every report and account will be investigated internally by DIGITAL HUB’s Ethics and Compliance Committee, made up of representatives from different areas who will act with discretion, impartiality, and independence.

Reporters are assured anonymity and full secrecy, and they may choose whether or not to identify themselves.