ÍNDICO'S COLLABORATORS CODE OF CONDUCT

 

Introduction

In the current business world, professional and personal ethics of all those who are employed in a company have a particular relevance, always respecting, according to a proper conduct, professional ethics of the sector they operate on and basing their conduct on principles that respect values which allow for an honest performance of the company in its own society.

In general, companies must then operate based on policies and proceedings consistent with the values and conduct standards that defend and determine their strategic guidelines and their behaviour in the business world. That conduct standard must be clearly determined, properly disclosed, fully understood and faithfully followed by all company collaborators.

To achieve this goal, it is necessary to use as a basic tool a set of principles and regulations to be followed on a daily basis, whether internally or in relations with Third-parties. It is within this framework that ÍNDICO decided to create and implement its own Code of Conduct, applicable to all its collaborators, normally translating that which was, is and always will be its way of acting and being.

CHAPTER I

FRAMEWORK AND PURPOSE

Article 1

(Framework)

  1. The present Code establishes a set of conduct regulations to be respected by the Members of the Advisory and Social Bodies of Insurance Company ÍNDICO and by all its collaborators when performing professional duties for the Company, as well as by service providers that, in an independent and non-subordinated way, act for and on account of Insurance Company ÍNDICO or on its behalf.
  2. Collaborators, for all intents and purposes of the present Code, are all those who have a work relation or a similar one with ÍNDICO, as long as the activity or provided services are characterized by stability or permanence.
  3. Respecting the planned rules of the present Code does not prevent, nor dismisses, considering and regarding specific conduct regulations, issued by the sector's Authorities, Institutions or Entities, or others linked to the activity, within the framework of the respective powers and areas of intervention.

Article 2

(Purpose)

The purpose of the present code of conduct for ÍNDICO's collaborators is:

  1. Ensuring that, besides complying with regulations and duties resultant from applicable legal, contract and regulatory provisions, ÍNDICO's activity is developed according to strict professional ethics principles and a sense of social responsibility, aiming to achieve an institutional image of rigour, competence and reliability.
  2. Constituting a conduct standard and reference to be respected by members of ÍNDICO's advisory and social bodies and its Collaborators, whether in internal and external relations.

CHAPTER II

GENERAL PRINCIPLES

Article 3

(Fundamental Principles)

a) The present Code's receivers must develop their activity for ÍNDICO respecting the following principles:

  1. Legality – acting always in accordance with the applicable law and regulations issued by the appropriate authorities and always taking into account all normative and proceedings defined on Detection and Prevention of Money Laundering;
  2. Good Faith – acting, closely to internal and external interlocutors, in the suggested framework of trust, in a proper and loyal manner, with an adequate sense of cooperation;
  3. Efficiency – seeking to accomplish the mission and execute duties or tasks assigned to them with rigour and quality, through simple and swift proceedings, sense of economy and a good and rational use of resources;
  4. Truth and Transparency – establishing relations based on these values and ensuring, namely, the collecting, treatment and consolidation of data;
  5. Integrity – acting, under all circumstances, with righteousness and honesty, respecting the excellence of ÍNDICO's superior goals, while refraining from accepting from any third-party, supplier, Insurance Intermediary or Client any compensation, favour or advantage for actions performed in the service of the company, and refusing to intervene in managing situations where there is, or there might be, a conflict of personal and institutional interests.

b) It is considered to be a conflict of interests whenever the receivers' private interests of this code might, in some way, real or hypothetically interfere with ÍNDICO's interests and whenever they personally or institutionally benefit from decisions taken or guidelines received when exercising their duties. In the same manner, it is also considered to be a conflict of interests in all situations that bring about or might bring about any benefits or advantages as a consequence of family relationships between this Code's receivers or between these and ÍNDICO's Third-parties.

Article 4

(Duty of Secrecy)

  1. Receivers of the present Code are bound to keep a rigorous secrecy on all facts and/or information regarding ÍNDICO's life and activities and its associated companies, Collaborators and Third-parties, whose knowledge comes from performing their duties. They are also bound to comply and enforce regulations and control and information security systems of their circulation.
  2. Duty of secrecy only ceases in situations foreseen by law and maintains itself beyond eventual ceasing of duties at ÍNDICO, mainly, when oneself is in possession of knowledge resultant from research, development and innovation projects performed by ÍNDICO, whether they are already implemented or set for a future completion.

Article 5

(Social Responsability)

When exercising its activity, ÍNDICO and its Collaborators must fully respect the human person's values and dignity, as well as the values of preserving property, sustainability and the environment, paying proper attention to the subjects of corporate social responsibility, corporate citizenship, innovation, valuing and improvement of people and technical knowledge.

CHAPTER III

INTERNAL FUNCTIONING

Article 6

(Written Documents)

  1. Receivers of the present Code must take into account that all documents produced at ÍNDICO can eventually be made public.
  2. All written communications, including agendas, minutes of the proceedings, work documents, positions adopted, as well as other documents related with ÍNDICO's activity, whatever the support, must be drafted in a clear and easily intelligible manner, reducing to a minimum all doubts of interpretation.

Article 7

(Relations with and between Collaborators)

Instrumentally to the above mentioned general principles, relations between ÍNDICO and all of its Collaborators, and of these between themselves, should be developed:

  1. In a framework of permanent compliance of duties and mutual respect, solidarity, urbanity, loyalty and respect for the guidelines determined by the established hierarchic lines;
  2. In an environment of total assertion of the principles of rigour, discretion, responsibility, cooperation, trust, excellent competence, non-discrimination and valuing of people.

CHAPTER IV

RELATIONS WITH THIRD-PARTIES

Article 8

(Relations with Clients and Third-Parties)

In relations between Clients and Third-parties, receivers of the present Code must take particularly into account the principles of impartiality and equality of treatment, answering promptly to all requests with courtesy, rigour and the appropriate transparency.

Article 9

(Relations with Partners)

In relations with Commercial Partners, mainly Insurance Brokers, Insurance Agents, Insurance Collectors or other Distribution Channels, receivers of the present Code must take into account these partners' particular mission in the area of commercialising ÍNDICO's products and providing an after-sales service to our Clients, providing them with all the necessary support for accomplishing their mission with the highest level of quality.

Article 10

(Relations with Suppliers)

Always bearing in mind the principles of efficiency and integrity, relations with Suppliers must be developed according to processes of transparency and rigorous respect for the agreed conditions in an environment of mutual trust and high sense of technical and ethical demand, as well as with a logic of partnership that aims to ensure a fair distribution of risks, costs and added value.

Article 11

(Relations with Authorities and Associate or Tutelage Bodies)

  1. In the relation with all Authorities and Associate or Tutelage Bodies, besides the rigorous compliance of all legal and regulatory norms, receivers of the present Code must act with special thoroughness, readiness, righteousness and urbanity, promoting in a clear, rigorous and reliable manner the institutional positions defined on the matters for which the contact occurs.
  2. When there are any doubts on the institutional position regarding a certain subject or matter, these should be clarified and solved internally, within the framework of ÍNDICO's decision-making structure. ÍNDICO's position will then be posteriorly transmitted to the competent authority in a formal manner, and will prevail over any personal point of view showed in the meantime.
  3. ÍNDICO will adopt a permanent attitude of cooperation with all entities, making itself available to participate in all the studies and reflections that aim to contribute for the evolution of the activity's regulations and regulatory systems and their adjustment to any needs, current or future ones.

Article 12

(Relations with the Media)

  1. Given the need of permanently contributing for the implementation of an image of rigour and institutional and sector competence, contacts made with the media can only be made through the defined channels and with knowledge and consent of the Administrative Board, being forbidden to all outside of that framework the disclosure of any information or the confirmation or denial of any news on behalf of ÍNDICO.
  2. In its relation with the media, ÍNDICO will rigorously respect the principles of truth and transparency, properly in line with the principle of legality and duty of secrecy, whenever they must prevail.

CHAPTER V

FINAL STIPULATIONS

Article 13

(Adhesion and Compliance)

ÍNDICO will ensure the necessary disclosure and explanation of the regulations of the present code of conduct, in a way of ensuring that its content is perfectly internalised and taken by its receivers as a set of norms that binds them all.

Article 14

(Implementation, Revisions and Supervision)

  1. The present code of conduct comes into force on September 1st 2014.
  2. Annually, ÍNDICO's Administrative Board will assess the need for revision or improvement of the present code.
  3. Through its own normative, the Administrative Board will appoint the Director responsible for ÍNDICO's Code of Conduct, whose role will generically be to ensure its enforcing in emerging specific situations and interpret its stipulations in any particular situation.
  4. Any potential or concrete infringement of the present Code must be immediately reported to the Director responsible for the Code of Conduct for assessment of the situation and implementation of measures to reduce or annul any consequences that may result from such infringement. 

Maputo, September 1st 2014