Whistleblower Channel
LUMIS has a confidential channel for submitting complaints and reports ("Whistleblower Channel"), which should be used to report situations where LUMIS's ethical values and principles may be being violated or at risk - or suspected non-compliance with this Code, LUMIS policies, or applicable legislation and regulations.
The Whistleblower Channel is based on the principle of confidentiality of information and reports and can be used by all Professionals and any partners, investors, and the general public. All situations reported to the Whistleblower Channel are received by the Whistleblower Committee, composed of HR and Finance Managers, investigated, and responded to with complete seriousness, confidentiality, impartiality, and independence in the analysis of the information.
Corrective actions resulting from investigations carried out through the Whistleblower Channel are never decided by a single individual, but rather by an internal committee, formed by the Whistleblower Committee and a member of the Board (acting in conjunction with other areas of LUMIS, such as Compliance, and managers as applicable, in addition to a specialized office, being a third party in the relationship between the whistleblower and LUMIS, contracted to address Compliance), ensuring that all viewpoints are considered objectively and neutrally.
It should be noted that anonymity is guaranteed to the complainant, whose identity will be preserved throughout the verification process of the reported cases. Additionally, LUMIS does not tolerate any form of retaliation against those who raise a concern about a potentially illegal or unethical act and encourages its Employees to be participative and report any adverse fact for due internal investigation.
On the other hand, the eventual making of complaints in bad faith will be subject to the investigation and sanction procedures provided for in this Code.
In general, ethical issues are not created by the people who face them. They arise before individuals due to the diversity of situations encountered in personal and professional actions.
The definitions contained in Lumis's Code of Ethics and Conduct allow for the evaluation and identification of most of these situations, avoiding behaviors considered unethical, but do not necessarily detail all situations. Thus, in the face of any fact or situation, doubts may arise about what conduct to adopt. In these cases, do not hesitate. Talk openly and honestly with leadership.
If the doubts persist, the consultation should be made to the Board or Compliance. You can always, to clear up doubts, contact the Whistleblower Channel.
A Professional who violates Lumis's Code of Ethics and Conduct, or allows a Professional on their team to do so, will be subject to disciplinary action as provided for in Lumis's Code of Conduct.
A Professional who becomes aware of a violation of this Code by any person should report the violation using the Whistleblower Channel.
It is not acceptable conduct to ignore the questionable action, remaining silent or claiming ignorance of its nature.
Each Professional, therefore, is responsible for observing, implementing, and disseminating the Code of Ethics and Conduct. It is the responsibility of LUMIS's Directors, as well as team leaders, to influence their subordinates through example to ensure compliance with the conduct defined in the Code, in conjunction and in an integrated manner with other LUMIS policies, as well as to preserve the confidentiality of information relating to investigations into Code violations.
How to report a situation to the whistleblower channel and access means
Before getting in touch, evaluate whether the reported case is related to potentially improper conduct or some operational process that can be improved. If it is an operational process that can be improved, your suggestion can be directly submitted to the immediate leader, the Board, or the HR department.
You can report a report or complaint via the Whistleblower Channel portal on the SafeSpace platform by Whistleblower Channel / Lumis following the instructions there.
When reporting any report or complaint, be prepared to provide, confidentially and always through the Whistleblower Channel itself, information about the occurrence that may assist in the proper investigation of the reported facts, such as: (i) those involved; (ii) date, time, and place; (iii) emails or other files and documents; (iv) conversation screenshots (Teams, WhatsApp, others); and (v) other useful information for tracking and investigation of the reported fact.
Investigation of complaints and reports and investigation procedure
After evaluating the reported facts, action plans will be conducted within the competent spheres in each situation, under the direction of the Whistleblower Committee and supervision of the board. In case there are indications of involvement of any board member or the Whistleblower Committee in fact subject to complaints, the contracted office for Compliance will take on the investigation of the complaint.
The Board, together with the Whistleblower Committee, fulfills the role of managing and ensuring the proper functioning of the Whistleblower Channel, as well as conducting and documenting internal investigations of potential violations of integrity standards (in which support from other LUMIS areas, such as Compliance, among others, and/or external advisors may be utilized, as applicable, or recommend the hiring of an independent investigation).
LUMIS and its board value the confidentiality of treated information, aiming at preserving the rights of whistleblowers and the impartiality of their decisions. During the appreciation and investigation of complaints received, the board may delegate investigative functions and hire third parties for this purpose.
All incident and/or complaint reports received by the whistleblower channel will be treated following appropriate investigation procedures.
The scope of the investigation is to collect information to stop ongoing fraud or corruption or deter its practice and reinforce internal controls, in addition to supporting any subsequent action, whether in the administrative, civil, and/or criminal sphere.
Responsibility
To obtain quality and risk mitigation in capturing, investigating, and resolving investigations, the internal committee will be responsible for:
(i) Conducting the case investigation, when decided that the investigation should be conducted internally, with fairness and impartiality, respecting the rights of individuals and/or entities involved, including guaranteeing the presumption of innocence until the analysis procedures are concluded;
(ii) Coordinating the case investigation, when conducted by an external company or delegated to a specific support area;
(iii) Concluding on the validity of the complaint, its extent, and those involved, when conducted internally;
(iv) Structuring the communication method to be used with the accused, the support area, and others involved;
(v) Developing and executing the action plan established with corrective measures; and
(vi) Mandatorily hiring an external company when the involvement of an internal committee member in the received report is identified and withdrawing from the analysis and/or investigation process.
Investigation of moral and/or sexual harassment, abuse of authority, physical aggression, and discrimination
(i) Identify the location and witnesses of the occurrence.
(ii) Verify if the complainant has reasons to want to retaliate against the accused.
(iii) Check the behavior history and reports associated with the accused.
(iv) Evaluate if the complainant/victim requires psychological support.
(v) When applicable, apply corrective actions provided for in current legislation to the accused; in extreme cases, assess the filing of a police report.
(vi) Disciplinary action against the reported Employee will be the application of notification/warning, unless the act is classified as committing serious offenses (in which case suspension or termination for cause may be applied). In case of a third-party accused, LUMIS may choose to terminate the contractual agreement with the accused and/or related parties.
Confidentiality
Issues under investigation must be treated with total confidentiality, so that the name of the claimant, the accused/investigated, the area where the situation occurred, and the content of the reported situation will be restricted exclusively to the Employees conducting the investigation and individuals authorized by the internal committee.
Training
LUMIS promotes training, at least annually, for all its Professionals to qualify and raise awareness about the conduct, principles, concepts, and procedures outlined in this Code. Attendance at training is mandatory and presence will be controlled through adequate means by LUMIS.
Penalties
It is each Professional's responsibility to be aware of the guidelines and instructions expressed in Lumis's Code of Conduct. Any violation of these guidelines and instructions will result in the application of appropriate disciplinary measures, which may include:
(i) oral and/or written warning;
(ii) disciplinary suspension;
(iii) termination of the employment contract (with or without cause);
(iv) adoption of legal measures related to damage restitution;
(v) when appropriate, reporting of facts to the competent authorities; and
(vi) legal proceedings, depending on the severity of the violation and the principle violated.
In the case of partners and third parties in general, disrespect to this Code may result in immediate termination of the contract and, as applicable, the adoption of legal measures for reparation or compensation.
All Professionals have the duty to immediately report any violation of the Code of Ethics. Omission in the face of possible violations will also be considered unethical conduct and may lead to the application of the same sanctions applicable to violations, as it compromises the integrity and loyalty of relations with LUMIS. The reputation and ethical integrity of LUMIS are the responsibility of each of our Professionals, as well as third-party service providers interacting with LUMIS.