Code of Conduct

Here at Rentcars we are all united with the same purpose: to connect people with the best car options around the world. From the beginning, we dreamed of becoming a reference and taking the lead in our market. With great pride and thanks to an extraordinary team, Rentcars is among the global market leaders and is the largest online company specialized in car rental in Latin America. We serve customers in over 160 countries.

To provide an exceptional experience for car rental users around the world, offering the best prices and quality solutions to our customers and partners, contributing to greater social equality that encourages the exploration of new cultures and societies.

To be world leaders in the vehicle rental and land mobility market.

Our values determine and guide all decisions made in the contexts of our business. Five values describe our way of being and working:

Ethical conduct above all else

The conduct we want to see in the world is the one we follow. Responsibility to our employees, customers, partners, society and the market in which we operate is what guides our decisions. Ethics and honesty are our pillars and we believe they are the foundation for building a fair and better world.

Excellence first

We relentlessly strive for the highest quality in all our products and services. Every day we want to go further, so our main goal is to achieve excellence in everything we do, always thinking about the utmost satisfaction of our customers.

Engaged and restless by nature

We constantly want to exceed expectations, whether they are from our customers, partners or even our team. Our achievements motivate us to do more than is expected. We always want more, always better.

Always in search of innovation

We are focused on always offering the most advanced and innovative solutions to our customers, partners and team. That is why we invest a lot, seeking the constant improvement of our team and also our methods, products and services.

Together we are stronger

Our work is collaborative. Here relationships matter and everyone is free to suggest new ideas. We believe that people with different visions and stories, working together with determination, focus and energy, can make the impossible possible.

Ethics principles are constructed to govern desirable individual and organizational behavior, and they delineate behaviors and attitudes that benefit and make our life in society easier.

This Code of Conduct introduces Rentcars' values so that Renties, Partners, Suppliers and stakeholders understand and put them into practice in their daily lives. We pride ourselves on acting correctly, so this material should serve as a reference for attitudes and decision making.

The Code applies to all Renties (employees, third parties, interns, apprentices or temporary workers, regardless of position or role), customers, suppliers, partners, among other interested parties.

Renties working with third parties must provide them with a copy of this Code and make a commitment to honor it with us.

This Code must be strictly followed and violations will be dealt with immediately, adopting applicable corrective and disciplinary measures.

Actions that violate the Code of Conduct, when based on unlawful behavior duly ascertained and proven, will be submitted to the appropriate authority.

All Renties are encouraged to report possible fraud immediately, even those committed in good faith, which should also be part of the verification process.

In this sense, it is the responsibility of those involved, whether Renties, Partners or Suppliers, to cooperate with internal investigations that deal with unethical behavior.

No retaliation by any party involved during the investigation process will be tolerated by Rentcars, regardless of the finding of guilt or not.

Open communication on issues and concerns, without discriminatory acts, is essential for the successful implementation of this Code.

The Code of Conduct indicates what Rentcars expects from each professional in the different situations they may face at work or even outside of it. Whenever you are indecisive about how to act, refer to it.

If you have any questions or in the event of becoming aware of the practice of any unlawful, unethical or contrary act to Rentcars' policies, this must be communicated through the Rentcars Ombudsman for the immediate investigation of the Legal department.

The channel ensures the confidentiality of information, preserving the identity of the people involved, internal or external, and helps to promote a better environment for all.

Respect is one of the most important values of human relationships and has great importance in social interaction. It prevents one person from having reprehensible attitudes toward another. When mutual, it represents a healthy coexistence.

Here at Rentcars, we recognize and value professional conduct based on respect for human beings, society, laws and the environment.

Maintaining a respectful posture also means being in compliance with the rules. Rentcars is committed to conducting its business within full compliance with the law and best market practices. Likewise, all those who have a direct or indirect relationship with Rentcars are expected to comply with current laws, rules and regulations, as well as internal policies.

The number and complexity of these laws are constantly increasing. We are aware that it is not possible to know all of them completely, however, one must have the necessary knowledge to the activities related to their area of expertise.

If you have questions about the laws or regulations that apply to a particular situation or need to understand a specific legal or regulatory requirement, please contact the Rentcars Talents team, who will be responsible for guiding you or handling the matter with Legal team. In specific cases, the teams will together check the best practice to be adopted, ensuring that both the law is fully complied with and Rentcars' values are honored.

Remember: in no situation should you proceed in an unlawful or unethical manner, nor instruct or encourage others directly or indirectly to do so, for any reason.

Becoming familiar with the company's rules and procedures that are available on our website, and complying with them is also part of your responsibility.

TALENTS CONTACT ADDRESS:

For internal employees: GLPI

For others: [email protected];

Respect does not mean agreeing in every aspect with someone; but rather, not discriminating or offending that person because of their way of living or thinking. Therefore, to speak with respect is to speak in a thoughtful and sensitive manner.

Here at Rentcars we value diversity and do not tolerate any form of discrimination based on race, gender, sexual orientation, color, appearance, nationality, religion, age, physical and mental condition, marital status, political ideology, age or any other situations that are inherent to the human being.

We are proud to propagate and encourage a workplace with equal opportunities, acting affirmatively in the engagement of our Renties, Partners and Suppliers with the different ways of being. All of our job openings are open to anyone with the ability to take them on, regardless of any particularities they may have.

Here diversity is welcome, appreciated, and everyone is individuality respected. Therefore, all Renties, Partners and Suppliers must honor this commitment and value plurality in their work environment.

The word "harassment" refers to any conduct, verbal or physical, explicit or implicit, that by its nature has the effect of embarrassing.

Any kind of harassment or unprofessional or inappropriate behavior, even if it is not considered illegal, violates our values and is strongly repudiated by Rentcars. This principle applies whenever the Rentie is at your workplace or representing the company at external events and meetings, or when Partners and Suppliers are on or off Rentcars premises, but acting to fulfill their agreement.

No Rentie, Customer, Partner or Supplier may be the subject of discrimination, disrespect, prejudice or suffer any kind of physical sanctions, harassment or psychological, physical or sexual abuse, in the same way that no Rentie, Partner or Supplier may be the author of any of these conducts, so that everyone should feel free to report their concerns and raise issues, without fear of retaliation.

In this sense, any type of retaliation is prohibited and will not be tolerated by the company.

All Renties, Partners and Suppliers, who have access to Rentcars resources and movable or immovable property, must protect them and ensure their proper use. Care must be taken not to waste them, and use them sustainably to Rentcars and the environment as a whole.

All resources must be used for corporate purposes. No property owned by Rentcars shall be removed from the physical premises of the company, unless expressly authorized by its manager. This includes office, kitchen, and cleaning supplies, furniture, equipment, among others, under penalty of disciplinary measures.

In addition, if there is access to data or information that directly or indirectly involves Rentcars, through private devices not authorized by the IT team, the user of this mechanism must ensure the protection of all said data and information that, for all purposes, are considered confidential, under penalty of disciplinary measures.

Rentcars recognizes and emphasizes the protection of the environment in its processes and facilities. In planning and carrying out our activities, we consider the need to protect the environment, to contribute to social development, and to act in respectful and cooperative relationships with our customers, community, suppliers, government authorities, and all other parties involved in our activities.

Particular attention should be paid to ensuring that the influence of relationships with friends and family does not lead to conflicts of interest or misinterpretations related to Rentcars' responsibilities. Renties, Partners and Suppliers must always take care that such relationships do not have a negative influence on their responsibilities at work or on their ability to make correct, impartial and objective decisions

For the purposes of this policy, “affective bond” refers to any type of relationship, whether intimate, affective, loving, marital and family of any instance.

Renties, Partners and Suppliers must avoid inappropriate or compromising personal ties, which may impair their performance at work. In this regard we state:

• It is forbidden to supervise, coordinate or manage, directly or indirectly, a person with whom one has an affective bond.
• It is forbidden to maintain an affective bond with any member of the company's governing body.
• Rentiers, Partners and Suppliers may not use their affective links to privilege information, directly or indirectly, and influence the decisions of the company causing transfers, promotions and/or disciplinary issues of any person.
• It is forbidden to transfer, hire or promote Renties, Partners and Suppliers based on an affective bond.

If, by any chance, any affective relationship arises, the Rentie, Partner or Supplier involved in it must communicate the management of the Rentcars Talents team, so that, in the need of any relocation to be made, it occurs in the most adequate way to all those involved and does not harm the work environment.

Renties must inform their line manager when someone with whom they have an affective bond works for a business partner, potential business partner or competitor, or occupies a position that may influence decisions affecting Rentcars.

Renties, Partners and Suppliers must avoid relationships, circumstances, investments or situations in which their loyalty is put in conflict between Rentcars' interests and their personal interests. It is important to avoid situations that could lead to a conflict of interest. If you have any questions, talk to your supervisor or the Talents team for advice.

Before taking on any particular activity that has any kind of conflict of interest with your direct activity at Rentcars or services we provide, please contact the Talents team to make sure that it will not harm your work or in any way influence our values and policies. Such external activities cannot compete with internal activities during office hours, nor interfere with their performance within the work environment.

Conflicts of interest may arise if a family member of a Rentie is an employee of a competing company, customer, supplier or does business with Rentcars, or vice versa. Before establishing business relationships between Rentcars and members of your family, be sure to formally communicate with the Talents team.

5.3. Use of Company Opportunities for Personal Gain

Professional earnings or promotions must always come from meritocracy. Therefore, any illicit, unethical or contrary to Rentcars' values and policies that aim at such promotions, whether within the work environment or for personal enjoyment, will be strictly banned.

In this sense, it is also prohibited to take advantage of any opportunities identified or created as a result of the assets owned by Rentcars or arising from the information or positions held within the company.

Due to the high flow of information that Renties, Suppliers and Partners have access to, unless otherwise provided for in a contract, they are also prohibited from competing with the services provided by Rentcars, either directly or indirectly. That is, they cannot, under any circumstances, operate or provide any type of assistance to a competitor company of Rentcars, nor engage in any competing activities.

As a company that cares about the society in which it operates, Rentcars can offer donations (voluntary contributions without consideration) and sponsorships (contributions based on a mutually agreed partnership) that aim to transform the environment and strengthen its brand.

In order to avoid any possible conflict of interest, donations and sponsorship actions will only be allowed after a social impact assessment and approval by the board.

Fair competition is encouraged by Rentcars. Any combined agreements and behaviors between competitors that aim at or cause the impediment and restriction of free competition is condemned. Everyone must honor free competition and market competition by applying all legal guarantees.

Renties, partners, affiliates, suppliers or advisors shall not carry out any misleading advertising of the activity of their business and shall avoid any conduct that constitutes or may constitute abuse or unlawful restriction of competition.

Renties are instructed to act in a fully professional manner when dealing with people and companies with whom they are doing or trying to do business, with no other intentions than the interests of our company.

In this sense, they must not give or accept from customers, suppliers or competitors gifts, courtesies or favors that are not previously agreed by the company's board of directors as a commercial strategy.

We know that everyone likes gifts, but when they come from business relationships, they can interfere with decisions or cause discredit to both Rentie and Rentcars.

Thus, gifts or favors received through these business relationships will be returned to those who offered them, accompanied by acknowledgments and justifications of corporate ethical standards and conduct.

Institutional gifts, without commercial value or with a value less than R$50.00 (fifty reais), are allowed. Such as office supplies, promotional pens, planners, calendars, books, chocolates, among others.

In case of questions, Renties, Partners and Suppliers should always consult the Talents team before offering or accepting any item of value.

Rentcars seeks to meet, whenever reasonable and justified, the requests of the Government, its regulatory and inspection agents, unions, class entities and non-governmental organizations with ethics, promptness, speed and transparency.

We are honest and upright in all dealings with managers and employees in the public and private sector, avoiding that our conduct could appear improper in any situation.

We must not publicly express an opinion about acts or attitudes of public officials or make comments of a political nature that may reflect negatively on the image of Rentcars.

In defending the interests of the company, those involved must act based on our standards of action and values, always observing the highest ethical principles and respect for current laws and regulations.

All Rentcars financial transactions are only carried out after approval by the board. In addition, they must always be treated and processed in accordance with normally accepted accounting principles and corporate accounting standards, correctly recorded in our books and records, and within the stipulated period.

Renties, Partners and Suppliers must pay attention to the current accounting requirements of each country/state where Rentcars operates or may operate. All payments and other transactions must be in strict legal compliance, as well as in line with the company's accounting systems. These systems incorporate internal controls that defend our assets and protect us from fraud.

In this sense, Rentcars creates, every day, servaral records, whether financial or business including, among others, purchase orders, agreements, service records, expense reports, invoices, spreadsheets, telephone records and many others. Accordingly, it is your obligation to ensure that all records you hold reflect the true nature of your operations with Rentcars. Information on Rentcars' internal control standards and procedures must be obtained from the Financial Department.

Any information must always be published and reported in a correct, timely and honest manner. This includes invoices, sales records, travel expense reports, summary of hours worked, and all public reports and records. Under no circumstances may false, incomplete or misleading entries or records be created. All transactions must have complete and correct documentation.

Undisclosed or unrecorded amounts may not be separated or allocated for any purpose. Under no circumstances may Rentcars resources or values be deposited or allocated in personal accounts that are not owned by the company, in order to fraud, obfuscate the truth or even evade. In the event of such cases, administrative and legal measures will be taken to immediately remedy the situation.

Those involved should be aware that they may be dealing with restricted or highly restricted information.

As a result of the work, we know that Rentiers, Partners and Suppliers are in contact with private company information, which can and should be considered an industry and business secret. Therefore, this information must be treated confidentially, in accordance with Act 13.709/18 - LGPD, under any condition, and cannot be disclosed to unauthorized third parties.

As a member of the company, even if indirect, as in the cases of Partners and Suppliers, each one is responsible for security measures that prevent unauthorized access to systems, files, directories and physical accesses such as rooms, keys, garage among other places.

Passwords are personal and non-transferable, and disclosure to other members will constitute an infraction. In addition, the disclosure of information is classified according to its degree of secrecy, in order to ensure proper treatment and standardization.

Even after its termination or expiration of an employment contract or service provision, each Rentie, Partner or Supplier must maintain the confidentiality of the information for at least two years, at the risk of legal action.

The classification levels of the information are:

9.1.1. Public

It is information that can be accessed by the general public, including competitors, without implications for the institution. As an example, information disclosed by the company on the website, social networks and press - news, company website, logo, official publications made on LinkedIn, Instagram and Facebook of Rentcars.

9.1.2. Internal

It is the information that can be shared between those involved in the business, so that external people cannot have knowledge. As an example, we can mention the contents disseminated by the Internal Communication channels - intranet, Workplace, emails, internal policies, general reports and daily departmental matters.

9.1.3. Restricted

It is strategic information that should be available only to restricted groups. They can be protected, for example, by restricting access to a network folder or directory.

Access by unauthorized persons or their disclosure compromises the operation of the institution, causing financial damage or loss of market to competition. The breach of confidentiality of confidential information may result in disciplinary and legal measures. Examples: information on security vulnerability of institutional systems, agreements, balance sheets, payroll, financial results, bank balances and surveys.

9.1.4. Highly Restricted

It is also called private information. This is knowledge content from just one person or a small strategic group, composed of a high-trust summit. If disclosed either internally or externally, they can bring great financial or reputational losses to the company. As examples we can mention data and strategic drivers and new business projects.

Corporate emails are a work tool, owned by Rentcars, and can be monitored by the company within legal standards. Therefore, they should not be used for particular activities and should contain clear language and a professional stance.

In addition, its use for propagation of documents not related to the scope of work is prohibited. Its use for dissemination or transmission of content that is offensive to modesty, discriminatory, defamatory, rumors or chain letters will be immediately censored by the company and disciplinary and legal sanctions may be applied.

The use of the corporate Internet must be carried out responsibly. Under no circumstances may Rentie, Supplier or Partner, who is on the company's premises, use access to Rentcars' Internet network to:

• Download apps, music and movies;
• Access games;
• Access sites encrypted on deepweb, pornographic content, which propagate violence, disseminate defamatory content;
• Perform any other actions and accesses to restricted sites that violate Brazilian laws or are in violation of Rentcars policies and values.

To the extent permitted by law, Rentcars may monitor Internet access by users. Thus, internet access must be based on Rentcars' ethics and values and always be in accordance with the law. If you have any questions, please do not hesitate to contact the Talents team.

The work tools, including the computer, supplies, software, corporate email and Workplace profile, are integral parts of the company's assets and are intended solely for the execution of the work, disclosure of organizational information and corporate interaction. Misrepresentation and abuse of this purpose are subject to penalties.

In order to connect your Renties, Rentcars provides communication tools such as Workplace and Workchat, which should be restricted only to matters of interest to the company. The Workplace account will only be available for the duration of the employment relationship.

Topics such as politics, religion, improper exposure involving Renties, inappropriate language, among others, should not be part of the discussions on the social platform. The information exchanged via these tools is restricted only to Renties, and the transfer of the content to third parties, partners, customers and competitors is not allowed, as it is internal classification content.

Renties, as explained above, corporate mail must be used solely and exclusively for work purposes. It should be avoided that emails go unanswered, there is excessive delay in resending or that messages are sent outside the standard established by the company. It is expected from everyone: standardized signature, clear and polite communication and care with the information passed on.

Rentcars provides a safe and healthy workplace and strives to minimize the impact of our operations on the environment.

We prioritize the health and safety of the Renties, Partners and Suppliers that operate here. In our activities, we seek to be always aligned with the best practices and conducts of accident and incident prevention. Accident prevention and health promotion actions are part of our scope.

Rentcars managers or the Legal team shall promote disciplinary and/or legal measures when a Rentie, Partner or Supplier demonstrates inappropriate behavior.

For the purposes of this policy, it is understood as inappropriate behavior that is in violation of current legislation, the values of the company, and that impacts on the business, customers, or in any way disrespects the matters already dealt with in this Code of Conduct.

At the first sign of inappropriate behavior, the manager must verbally warn the Rentie. The second warning should be written. If the Rentie insists on the conduct, the manager must suspend them. After this step, upon recurrence of the conduct, the employee will be dismissed.

Despite the recommendation to follow the sequence of verbal, written and suspension warning to then carry out the dismissal, any Rentie may suffer an immediate dismissal, in view of the severity of the conduct and its legal impacts.

This Code of Conduct is comprised of our most important ethical principles and values that define what we expect from our Renties, Suppliers and Partners. In it, we summarize key compliance principles, highlight issues that could have serious legal and ethical consequences if handled improperly, and provide guidance on appropriate action to take.