Polo Surgical is committed to the highest ethical standards, basing its business activities and relations on the principle of transparency and integrity.
This Code of Ethics and Conduct was revised in January 2026.
Legality – The activities routinely performed by all partners and employees must always comply with the legal provisions of our area of operation, ensuring that our business follows high ethical standards, in strict compliance with applicable laws.
Transparency – We are committed to providing accurate and correct information about the product or service to be provided, respecting the relationship between supplier and consumer, always prioritizing health care, improving quality of life, and protecting the economic interests of our end customer.
Search for Excellence – Polo Surgical is constantly striving for continuous improvement and excellence through ongoing monitoring of performance indicators, process evolution, and employee training and development.
Commitment to Quality – All of us who work at Polo Surgical are committed to life, which is also expressed through the quality of our products and services. In all our activities, we must ensure compliance with Quality policies and procedures, guaranteeing our customers, patients, and regulatory agents the high standard of safety and effectiveness of our brand.
Accounting – Our accounting books are detailed to reflect the reality of each payment and expense. All entries will be accurate, honest, and made in such a way that the company complies with legal and regulatory obligations. No employee or director will sign and distribute, or allow others to sign and distribute on behalf of the company, any documents or statements that the declarant suspects to be false.
Discrimination and Harassment – It is the duty of all of us to ensure that there is no form of discrimination or harassment within the workplace or in labor relations between colleagues, whether based on race, age, color, religion or any other grounds that may exist. In this way, all Polo Surgical employees are guaranteed dignified and respectful treatment in the work environment.
Use of alcohol, illegal drugs and possession of weapons – Polo Surgical does not allow its employees to be under the influence of alcohol, drugs, or substances that may alter or cause deviant behavior during working hours. During business trips, events, and meals, common sense should be exercised when consuming alcohol. Under no circumstances is the use of illegal drugs permitted.
Smoking is prohibited in work areas and/or air-conditioned environments, including hallways, as well as in areas where it is not permitted for safety reasons.
Weapons of any kind are not permitted on Polo Surgical premises.
Company assets – The company’s property constitutes its assets, and we must use them only in the development of the business activities for which they are intended, avoiding their unnecessary deterioration.
Confidential information – Confidential information to which we have access by virtue of our employment or business relationship with the company may not, under any circumstances, be disclosed to third parties without prior written authorization, nor may it be used for personal gain.
We are also committed to not disclosing information that is not in the public domain and that could be useful and give an unfair advantage to competitors or that would harm Polo Surgical and its customers.
Data privacy – At Polo Surgical, we understand that it is essential to guarantee the privacy of everyone’s data, including partners and directors, employees, customers, and service providers. We comply with the privacy and data protection laws and regulations that govern the processing of personal data, in particular the Brazilian General Data Protection Act (Law No. 13,709/18 – LGPD).
The processing of personal data may involve the collection, production, reception, classification, use, access, reproduction, transmission, sharing, distribution, processing, filing, storage, elimination, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction of data.
We follow the principles of the LGPD (Brazilian General Data Protection Act) for all personal data processing activities, such as:
At Polo Surgical, personal data is processed to the extent necessary to achieve legitimate and legally authorized purposes. All personal data processing activities carried out by Polo Surgical will only be performed if there is a legal basis that justifies it, as provided for in the LGPD.
If you have any questions about the legality of any personal data processing activity, please contact us at: dpo@polosurgical.com.br
IT IS THE RESPONSIBILITY OF ALL EMPLOYEES, PARTNERS, DIRECTORS, AND SERVICE PROVIDERS TO ENSURE THE PROTECTION OF PERSONAL DATA IN ACCORDANCE WITH OUR POLICIES.
Appropriate use of social media – Polo Surgical does not allow its employees to share or disclose images or videos related to their professional activities on their social media accounts. Documents and digital files owned by the company, including corporate emails, must be safeguarded and their content used only in the interests of the company’s business and interests, or when required by a competent authority.
Use of passwords – Polo Surgical recognizes the importance of providing employees with passwords for personal and exclusive use to ensure the protection of corporate data and, consequently, business continuity. For this reason, sharing access passwords is strictly prohibited, and employees are informed of this prohibition through training conducted by HR when new employees join the company.
Negotiations – Negotiations between Polo Surgical and customers, suppliers, and any other parties must comply with legal requirements, and it is prohibited to obtain undue advantages through manipulation, omission, misuse of privileged information, misrepresentation of facts, or any other type of inappropriate negotiation or practice.
Contracts – Our relationships with service providers or contracted third parties will, whenever possible, be formalized in writing. Such contracts will ensure compliance with applicable legislation and best practices under current law, while also guaranteeing the right to conduct independent audits and terminate the contract if the other contracting party fails to comply with the relevant legal regulations.
Payments – We at Polo Surgical will not make any improper payments to customers, suppliers, service providers, individuals, or entities, especially those working in public administration, nor will we request or accept any improper payments from suppliers, customers, or any individual/entity that wants to do business with the company.
Competition – Our competitive practices will be conducted in a legal, ethical, and fair manner, and will comply with all antitrust laws and regulations and other applicable laws and regulations. We do not permit collusion with competitors to divide markets, fix prices, or engage in other practices that prevent fair competition.
Bidding – Our contacts with public officials in the context of bidding must be made in accordance with the rules of the bidding agency and other applicable regulations. Informal contacts with public officials involved in bidding are not permitted.
In discussions for negotiating or extending contracts, we cannot aim to obtain undue advantage from the employee or public agency.
Individual advantages – When acting on behalf of the company, our actions must prioritize the interests of Polo Surgical over our personal interests and, under no circumstances, may we engage in activities that may compete with the activities of Polo Surgical, refraining from obtaining individual advantages by virtue of the exercise of our business activities. Company assets and facilities may not be used for employees’ personal purposes, except in exceptional cases and with prior and express authorization.
Relationship with Healthcare Professionals – Interactions between Polo Surgical employees and their partners with healthcare professionals may only involve the presentation or discussion of educational/scientific topics related to the medical products marketed by Polo Surgical. No commercial negotiations, gifts or payments to healthcare professionals are permitted by any Polo Surgical representative.
Donations, Gifts and Entertainment – The transfer of anything of value to public employees, healthcare professionals, or any others, such as gifts, presents, or entertainment expenses, is not permitted.
Donations may be made for charitable purposes to philanthropic entities, nursing homes, and institutions that care for cancer patients. These donations shall always be made in good faith and shall not be made to customers or directed by sales.
Social Responsibility and Civil Society – Polo Surgical acts with social responsibility in all its policies, practices, and relationships, whether with its internal or external audiences, always attentive to human rights and compliance with good labor practices.
Respect for the Environment – Polo Surgical operates responsibly and with respect for the environment, keeping its Solid Waste Management Program up to date in accordance with applicable legislation, contracting a specialized company that is licensed by the competent authorities whenever it is necessary to dispose of expired or damaged medical products in its inventory.
In order to ensure compliance with this Code of Ethics and Conduct, cooperating at all organizational levels, the Compliance area is available for clarification, through its agents and existing communication channels, whenever any questions arise regarding the interpretation and observance of the rules consolidated herein.
Incident Communication – Denouncements Channel
All Polo Surgical associates have the right and duty to report violations of this Code, the Compliance Manual, Quality Procedures, as well as other internal Policies and Standards and applicable law. To do so, the Polo Surgical Whistleblower Channel is available via email: compliance@polosurgical.com.br or by calling the Compliance Officer’s cell phone: 21-99013-0006.
Polo Surgical, through its Compliance Officer, will diligently investigate the allegations presented.
The protocol followed is one of confidentiality and aims to preserve the integrity of the information, the success of the investigation process and the principle of non-retaliation.
Responsibility for internal investigations – Polo Surgical’s Compliance Officer is responsible for internal investigations and the collection of evidence, as well as for taking the measures deemed appropriate regarding violations of this Code, internal policies, and applicable laws.
The Chief Executive Officer is responsible for ensuring that employees understand and comply with this Code of Ethics and Conduct, as well as for creating a work environment in which compliance is expected and rewarded.
All Directors, Managers, and other employees certify in writing that they understand and agree to comply with the provisions of this Code of Ethics and Conduct and its principles.
Violation of the ethical principles described herein or failure to comply with internal policies will not be tolerated and will result in disciplinary action, which may include termination of employment, if appropriate.
The foundations and principles that comprise this Code must be constantly observed and respected by everyone.
We value the cooperation of all employees in solving problems and clarifying doubts related to the rules of this Code. Consultations are welcome and encouraged.