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Ethical Code

Rev 1 - 03/31/2021 ADM-QSMS


The Code of Ethical Conduct (“Code”) applies to members of the Executive Board, employees, interns, service providers and anyone acting on behalf of ROMAGA-SAIKAI.

This Code will be periodically reviewed and updated, at least every two years, under the responsibility of the QSMS Management, with its approval being the responsibility of the Executive Board.

ROMAGA-SAIKAI will promote, annually, the training of its employees, service providers and managers, to disseminate and consolidate the principles and rules contained herein.

It is perfectly possible to come across a situation in which the guidelines in this Code are not sufficient. In these cases, evaluating risks and consequences, a personal initiative will be welcomed. In these cases, however, a reflection based on the questions below should be carried out before taking action:

• Is my conduct compatible with the company's interests and values?
• Will I have the peace of mind to explain that I did the right thing?
• Does my conduct set an example for my co-workers?
• Am I acting without any violation of what is foreseen in the legislation or internal regulations in force?
• Have I evaluated all available information for decision making?
• Have I evaluated the risks and is the decision to be taken the best for the company?

The positive response to these questions is a strong indication that the attitude to be taken is in compliance and contributes to strengthening the company's environment of integrity. Responding negatively to at least one of these questions, the immediate manager should be consulted.

Failure to comply with the principles and commitments expressed herein may result in the adoption of disciplinary measures or even dismissal from the company.


Our purpose is to provide the means and resources to ensure prosperity in an ethical, safe and competitive manner.
Our values ​​must be considered in all actions and decisions, aiming to achieve the purpose:

• Respect for life, people and the environment
• Integrity and Transparency
• Value and Result Generation


❖ The right to life is inviolable and, therefore, ROMAGA-SAIKAI gives priority attention to people's health and safety;
❖ The preservation of the environment and sustainable development are values ​​that must be observed in all the company's actions in favor of present and future generations;
❖ ROMAGA-SAIKAI's supreme and indeclinable principles are the well-being and development of its employees without any form of prejudice or discrimination, trust and solidarity in interpersonal relationships, plurality of thought and justice in working relationships.


❖ Our employees must always act with integrity in their internal and external relationships, always maintaining full coherence between discourse and practice;
❖ Transparency must guide all of the company's business relationships and must be reflected in frank and open communication, without prejudice to the security of the company's information;
❖ Meritocracy is fundamental for the professional evolution of our employees, serving to value those who are committed to their purposes and avoid possible imbalances in the execution of activities.


❖ ROMAGA-SAIKAI will always seek to compose its staff with qualified and high-performance professionals, thus considered those who act with integrity, who contribute to productivity growth and cost reduction and who prioritize innovation;
❖ The company's strategies and business will be guided by the generation of value as the most important measure of business performance, aiming not only at sustainable and economically responsible growth, but also at the profitability of ROMAGA-SAIKAI.

❖ ROMAGA-SAIKAI will observe free competition and will never condone any practices that refer to cartelization or market concentration.


Senior Management and other ROMAGA-SAIKAI leaders are responsible for promoting the principles and values ​​established in this Code, and must always serve as examples for their teams, maintaining full coherence between discourse and practice.

All employees have a duty to act diligently to add value to the business and avoid losses for Romaga-Saikai, reporting the acts they practice, in the manner established in the internal standards and whenever required.


ROMAGA-SAIKAI trusts and assumes the integrity and good faith of its employees in their professional activities, guides them to comply with norms and standards and, at the same time, recognizes that the content of the company's objectives and interests must always prevail over form and individual interests;


ROMAGA-SAIKAI values ​​the determination and proactivity of its employees in the face of adverse and challenging situations, who must be encouraged to say what needs to be said and to do what needs to be done to achieve the expected results, even in the face of circumstances challenging and outside the usual routines of the company.


ROMAGA-SAIKAI's work teams will be formed with commitment, with purposes aligned with the company's strategic objectives and with the ability to apply the different skills and aptitudes of each of its members.


Our employees guide the exercise of their activities based on cooperation and solidarity, sharing knowledge and experiences, in order to achieve the success of the company as a whole.


Innovation and the inventive and creative spirit of employees will be constantly encouraged.


Work processes remain under constant monitoring and improvement, especially in view of the analysis of concrete situations to which they are subjected.


ROMAGA-SAIKAI encourages the formation of teams with high performance standards and with orientation towards goals and measures aimed at generating value for its partners and, consequently, for society and other stakeholders.


The members of the Senior Management and the employees of ROMAGA-SAIKAI carry with them the image and reputation of the company, inside and outside it, whether in the real world or in the virtual world. Therefore, the conduct of members of the Senior Management or of any employees that violates the values ​​and reputation of ROMAGA-SAIKAI, characterizes a breach of professional decorum and may result in the application of disciplinary measures, including termination.


The company and its managers are committed to communicating transparent, truthful, easily understandable and accessible to all interested parties.


❖ It is the duty of ROMAGA-SAIKAI to conduct its business and activities with social and environmental responsibility, contributing to sustainable development
❖ It is the duty of ROMAGA-SAIKAI to preserve and care for the safety and health of its employees, both physically and psychologically, including investing in safe equipment and facilities, continually improving its processes and practices and fostering a safety culture.
❖ It is the duty of ROMAGA-SAIKAI to respect, raise awareness, prevent violations and promote human rights in its activities and act in accordance with human rights protected by international treaties and conventions.
❖ It is the duty of ROMAGA-SAIKAI to guarantee the integrity of all its assets, whether material or immaterial, including information, technology developed or acquired, software, hardware, facilities, vehicles, equipment, materials, financial assets, intangible property rights, reputation and image and credits. Therefore, it is the duty of all its employees to properly use the company's assets for purposes directly related to the activities and business of ROMAGA-SAIKAI, including intervening or reporting in case of identification of improper use or evident waste; look after the shared assets of ROMAGA-SAIKAI in order to protect them against loss and damage.
❖ It is the duty of ROMAGA-SAIKAI to guarantee the right to privacy of its employees and the public of interest, as well as the confidentiality of the personal data to which it has access, giving wide accessibility to its respective holder and making use of them only for appropriate and legally allowed.
❖ It is the duty of all its employees to act in the protection of information that is in their possession or that obtained during meetings or negotiations, especially those of a privileged nature, which must always be treated with adequate security, in accordance with the applicable internal rules.
❖ ROMAGA-SAIKAI is absolutely committed to promoting integrity in the public and private business environment, acting in full respect of applicable national and international legislation.
❖ In this sense, ROMAGA-SAIKAI repudiates any and all forms of fraud and corruption, including bribery, money laundering or trading with privileged information, at all hierarchical levels.


Distribution: ALL ROMAGA-SAIKAI employees

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