Ethics and Compliance Program

Integrity is part of our infrastructure.

At WWD Technologies, innovation creates value only when it is guided by ethics, transparency, data protection, and accountability. Our program guides decisions, relationships, and deliveries — from planning through operations.

WWD · INTEGRITY / 2026ETHICS · LGPD · GOVERNANCE · ACCOUNTABILITY

Our commitment

Doing what is right.
Every day.

The Ethics and Compliance Program is a cornerstone of WWD Technologies’ corporate culture.

It brings together the principles, controls, and responsibilities that guide our work with clients, employees, suppliers, partners, and public officials. Reputation is built through consistency: what we say must be reflected in how we decide and act.

“Integrity is more than an institutional value. It is a nonnegotiable obligation.”
01

Prevent

Policies, guidance, and risk analysis before decisions are made.

02

Detect

Communication channels, controls, and monitoring of conduct and processes.

03

Respond

Responsible investigation, impartial handling, and proportionate measures.

04

Improve

Practice reviews, continuous learning, and ongoing program development.

Principles in practice

Commitments that guide how we operate.

Effective policies must be understood and applied. These are the commitments we expect from everyone who represents or engages with WWD.

ET · 01

Nonnegotiable integrity

We conduct business with honesty, respect, fairness, and traceability. Doing the right thing does not depend on oversight; it is the foundation of every WWD decision and relationship.

Zero tolerance for corruption, bribery, fraud, harassment, discrimination, and undisclosed conflicts of interest.
DH · 02

Respect and human rights

We foster an inclusive environment grounded in dignity, equal opportunity, and respect for differences. We reject child labor, forced labor, exploitation, and every form of violence.

These principles also guide how we select and engage with partners and suppliers.
PR · 03

Privacy and LGPD

Personal data must be processed for legitimate purposes with transparency, necessity, and security. We work to embed data protection into processes, projects, and relationships with individuals.

Access controls, incident prevention, and accountability are integral to our privacy approach.
RP · 04

Responsible public-sector engagement

We participate in public procurement with integrity, fair competition, and appropriate documentation. Interactions with public officials must be transparent and consistent with applicable law.

Improper payments, undue advantages, and unauthorized hospitality are expressly prohibited.
RC · 05

Responsible business relationships

We assess risk, document transactions, and seek to understand the partners we work with. Business decisions must be based on legitimate, technical, and verifiable criteria.

Due diligence and risk management strengthen trust throughout the value chain.
ES · 06

Social and environmental responsibility

Technology, ethics, and sustainability must advance together. We pursue efficiency, waste reduction, and decisions that respect the environment and local communities.

Accountability also means considering the social and environmental effects of our choices.

Compliance

Law, governance, and accountability.

Our program observes applicable law and draws on sound governance practices to prevent, identify, and address risk.

01

Brazilian Anti-Corruption Act

Law No. 12,846/2013 and Decree No. 11,129/2022

02

Data protection

LGPD — Law No. 13,709/2018

03

Public procurement

Law No. 14,133/2021 and applicable regulations

04

International references

FCPA and UK Bribery Act, when applicable

CO · 01

Culture and training

Periodic guidance and training strengthen the ability to recognize risk, seek help, and make responsible decisions.

AU · 02

Monitoring and audit

We monitor controls, assess risk, and review practices so the program remains active, useful, and proportionate to our operations.

NR · 03

Non-retaliation

Good-faith reports must be handled with respect, confidentiality, and protection from every form of retaliation.

Reporting channel

Speaking up safely is also part of doing what is right.

If you witnessed or suspect conduct that violates our Code of Ethics, WWD policies, or applicable law, use our secure channel. Your report will be received for responsible and impartial review.