Code of Conduct

Safer, Clearer, Better

To show the ways to achieve and maintain excellence in all areas of its activity, Xcalibur Multiphysics has gathered in this Code of Conduct some standards to guide the ethical behavior of all its administrators, employees, suppliers, and business partners, regarding the relationships and interactions with their key stakeholders. The conducts contained in this Code are not intended to cover all situations or circumstances that Xcalibur Multiphysics employees may deal with but are intended to establish general rules to guide them in the way they act during the performance of their professional activity.


The activities of Xcalibur Multiphysics contribute to the conscientious use of natural resources and the prevention of environmental accidents, confirming the Group’s respect for the Environment. Such respect is one of the foundations of our operational excellence. Xcalibur Multiphysics understands its relevance in the global context for the conservation of natural resource sources, supporting the search for sustainable development. Additionally, the Group is committed to the safety of its members and to promoting the best market practices and providing a healthy and safe work environment. In this sense, Xcalibur Multiphysics keep looking for solutions, including technological ones, to identify, manage, reduce, and eliminate the exposure of employees and partners to risks that threaten health and safety at work.


Each employee is responsible for ensuring a work environment free from harassment, discrimination, or other inappropriate conduct, including in a digital environment. The Xcalibur Multiphysics Group respects and promotes an environment free from discrimination based on gender identities, sexual orientation, religion, race, culture, nationality, social class, age, or physical characteristics. Xcalibur Multiphysics encourages equal opportunity hiring and promotion practices for all qualified employees. Xcalibur Multiphysics recognizes the human rights of all people as outlined in the Universal Declaration of Human Rights and the United Nations Guiding Principles on Business and Human Rights. The Group also supports all internationally recognized human rights, including, but not limited to: (i) The right to dignity and privacy; (ii) The right to life and liberty; (iii) Freedom of opinion and expression; (iv) Freedom of association; and (v) The right to work and education. Xcalibur Multiphysics prohibits any form of discrimination and harassment of employees. If an employee believes they have been victimized or are subject to discrimination or harassment, or that they observe or have observed an act of discrimination or harassment, they should report the matter to


Xcalibur Multiphysics conducts its operations in accordance with good governance principles and rules. The Group promotes among its suppliers, without prejudice to the contractual conditions, the commitment to the practices of the standards of conduct included in this Code. Whenever possible, the Group will require its suppliers to formalize their commitment to complying with the standards set out in this Code.


A conflict of interest can occur if the employee acts to achieve interests, contrary to the interests of the Group or that may cause damage to the Group. Xcalibur Multiphysics prohibits any action based on conflict of interest and excludes any action, influence or decision motivated by interests contrary to the rules in force.


All information entrusted to employees is the property of Xcalibur Multiphysics and its employees and partners must act to protect the information in their possession or that obtained during the execution of projects or confidential information that must always be treated with the adequate security, in accordance with the applicable internal regulations.


Xcalibur Multiphysics guarantees the right to privacy of its employees and its partners. Likewise, it guarantees the confidentiality of the personal data to which it has access, guaranteeing its holder access to its data, as well as guaranteeing that its use will only take place for appropriate and legally permitted purposes.


Xcalibur Multiphysics is committed to promoting integrity in the public and private business environment, complies with applicable local and international legislation, especially the Law for the Defense of Administrative Probity (Brazil), the Corporate Anti-Corruption Law (Brazil), the Anti-Corruption Pact of OECD, FCPA – Foreign Corrupt Practices Act (USA), UK Anti-Bribery Act and SOX – Sarbanes-Oxley Act (USA), among other legal norms in the fight against corruption. Xcalibur Multiphysics repudiates all forms of fraud and corruption, including bribery, money laundering or insider trading, at all levels of hierarchy. Thus, it is prohibited for any of its employees: a) To request, obtain, receive, promise, offer or give undue advantages of any nature to themselves or to third parties, including facilitation payments due to the public function performed; b) Inducing or persuading colleagues to act improperly or illegally on behalf of or in favor of the company; c) Refrain from situations of fraud and corruption (local or international), in any form, directly or indirectly, actively or passively, whether or not involving monetary values; d) Finance, fund, sponsor or otherwise subsidize the practice of unlawful acts; e) Adopt, in relation to the public sector, local or international, any initiative that could be interpreted as influence peddling and as an act harmful to the Public Administration.

Xcalibur Multiphysics supports initiatives aimed at complying with international agreements, treaties and conventions in the matters dealt with in this Code, including the Universal Declaration of Human Rights of the United Nations (UN), Business Pact for Integrity and Against Corruption and Oil, Gas and Biofuels Industry Integrity Pact and International Labor Organization (ILO) guidelines.


Gifts, travel, meals, and entertainment of any offer of value to any Public Agent or any other person or entity, including any entertainment, hospitality, travel, or gift of significant value, may be considered an improper payment and/or a violation of laws applicable anti-corruption. Therefore, Xcalibur Multiphysics employees, acting on behalf of the Group, are prohibited from providing such courtesies. Employees are also prohibited from soliciting or receiving, directly or indirectly, any gift of relevant value, including courtesies. This provision does not prohibit giving or receiving business courtesies of small value that do not create the appearance of impropriety or a conflict of interest.


Xcalibur Multiphysics employees are prohibited from directly or indirectly promising, offering, authorizing, or donate to political parties or candidates for public office with the resources or on behalf of the Group, when prohibited by applicable law.


Failure to comply with the commitments of this Code, applicable laws, or any Group guidelines can lead to serious consequences, including loss or restrictions on doing business, civil and/or criminal liability, or very high fines. Employees and Third Parties are also subject to civil and criminal liability, fines and/or imprisonment. In addition, employees who do not comply with the commitments of this Code, the law, or the Group’s instructions, or who allow a member of their team to do so, or who know of any violation and do not report it, are subject to appropriate disciplinary action, including possible dismissal. Any attempt to avoid efforts to report any violation of this Code is also grounds for disciplinary action, including termination. The Compliance area must investigate all known violations or allegations received at