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Code of Conduct Hotmart

Why should we have a Code of Conduct?

Culture is the most valuable asset at Hotmart. It is our Culture that is the compass for the people in our teams, and guides the manner in which the routine of the Company is conducted. Our Culture is so decisive in all of our decisions, that it represents a determinant step in the promotion, dismissal and selection processes, in order for everyone who joins the team shares the same moral standard of the Company and the people of which it is composed. Thus, and from the assumption that the Company is made up of people with similar values, why should we have a Code of Conduct?

The answer to this question is simple.

Even though the Culture of the Company guides, assertively, the disposition of the people in the team, it is natural, and extremely likely, that situations will arise in which making decisions may seem difficult and challenging..

When in doubt, therefore, it is always better to have a document to resort to, and direct attitudes based on the conduct established by the Company. After all, we put autonomy first and our goal is to make it possible for all to act, in different situations, without the need to consult with their leaders.

We also expect this document to guide the behavior, not only of our employees, but also of our partners, clients, suppliers, and all those who, in any fashion, do business or maintain a relationship with our Company and with our services.

CONDUCT WE EXPECT FROM OUR TROOPERS

To perform their activities in accordance with this Code and comply with the policies and internal norms established by Hotmart, encouraging and guiding their colleagues to do the same;

To maintain a positive professional attitude, being worthy, loyal, honest, respectful, trusting and collaborative to fellow Troopers;

To act with impartiality, objectivity, honesty, respect, transparency, loyalty, and politeness when dealing with administrators, employees, suppliers, customers, shareholders and investors;

To act with strict conformity with all applicable laws, including anti-bribery and anti-corruption laws, from the countries in which Hotmart is present;

To protect Hotmart’s property, including its image and reputation, facilities, equipment and materials;

To respect the rules and norms in effect in the place the Trooper is performing tasks on behalf of Hotmart;

To be diligent and responsible when dealing with Authorities, customers, competitors, suppliers, members of the community, and any other individuals, companies and organizations Hotmart does business with regularly, constantly seeking to preserve the good reputation, image and relationships of the Company;

To avoid situations in which there may be a conflict of interests between the Trooper and Hotmart, and when this is not possible, to abstain from representing Hotmart in the subject in question, immediately communicating this fact to the leader and the Talents Team;

Not to establish commercial dealings with companies or individuals that do not follow ethical, health and safety standards that are compatible to those followed by Hotmart;

To act with social responsibility, and respect for human dignity; and

To perform daily tasks respecting the safety and health standards defined by the Company

CONDUCT THAT IS NOT TOLERATED THUS SUBJECT TO DISCIPLINARY AND LEGAL MEASURES

To use one’s position in the Company with the intention of obtaining personal gain or any other form of advantage or illegitimate personal benefit, for himself or herself, for family members or others;

To offer or receive presents against the rules established in this Code and as a means to exert inappropriate influence, or obtain personal gain or prize to himself or herself, or others;

To offer, pay, promise or authorize any kind of personal benefit (be it in the form of payment or any other kind of personal benefit), directly or indirectly, to any Governmental Employee, from any sphere or country;

To discriminate against ethnicity, origin, gender, sexual orientation, religious belief, union state, political and ideological views, class, disability, marital status, age or physical appearance;

Any kind of harassment, including moral and sexual harassment, leading to the embarrassment of others;

To impose on others his or her political, ideological, spiritual or religious views, once Hotmart stands neutral in relation to these aspects; and

To offer hospitality or entertainment, to make donations or social contributions on behalf of Hotmart in disagreement with its policies and rules or without the necessary internal authorization.

HIRING AND SELECTION PROCESS

Troopers who are aware that a relative in any degree, friend or acquaintance, is a candidate to one of the positions at Hotmart (recommended by him or her, or not) should inform this fact to the Recruitment Team during the selection process.

The selection process will be analyzed by the departments responsible for such processes in order to avoid any conflict of interest from any party, especially if there is a significant difference in hierarchy among the people involved.

Recruiters that are friends with or related to a candidate cannot participate directly to the stages in the selection process of this particular candidate.

The process of choosing candidates must take into consideration their competencies and adherence to the Culture, and any sort of discrimination is expressly prohibited.

RELATIONSHIP BETWEEN CO-WORKERS

The Company does not forbid personal relationships (including romantic and sexual) between co-workers. However, it does not permit romantic and/or sexual relationships between an employee who is subordinate to another, or who, directly or indirectly, respond to the partner or may have an influence on the partner’s activities. Situations that fit the description stated in this item have to be informed to the Talents team in order to be monitored, or be analyzed in order to verify if one of the Troopers should change teams or departments.

For every case, the parties involved should keep their relationship, inside the Company or in work functions, professional, never allowing the personal relationship (including romantic and sexual) to influence their professional behavior. In no circumstances should any of the parties involved create or allow situations of harassment, abuse of power, conflict of interest or a violation to any rules or policies in effect.

Relationships should not interfere in the decisions or performance of the co-workers involved.

Starting or spreading rumors and intrigues is unacceptable.

It is strictly forbidden to defame co-workers by making embarrassing comments or negative criticism about their professional performance, as well as any kind of discrimination.

It is forbidden to commit, allow or be complicit with any kind of harassment¹.

Any kind of harassment against a person, or any situation that was described above, must be informed in private to the Trooper’s direct leader or to the Talents Team, without running any risk of recrimination. The situation will be analyzed and the necessary measures will be taken. Although we are in a light and relaxed environment, jokes are only allowed if they are respectful, accepting of the limits established by the people involved.

1 . Harassment

Harassment is any verbal, virtual or physical behavior with the intention of humiliating, coerce, belittle or threaten the physical or psychological integrity of another person. No type of harassment is acceptable, be it sexual, moral, or any other, nor are any situations that constitute disrespect, intimidation or threat in the relationship among co-workers, regardless of their hierarchical position. We illustrate, below, some situations that may constitute harassment and that are not accepted, under no circumstances in our workplace and routine:

Public humiliation through jokes, insults and embarrassing insinuations;

Leaders who disrespect subordinates and make use of tone of voice or vocabulary considered inappropriate to refer to them;

Any kind of relationship between leader and subordinate that constitute threat or abuse of power;

Sexual harassment, defined as unwanted and unwelcome words and gestures, unrequited touching, or nonverbal expressions of sexual nature.

CONSUMPTION OF ALCOHOL, DRUGS, AND CARRYING WEAPONS IN THE COMPANY’S FACILITIES.

The consumption of alcohol is not recommended in any situation in which the professionals are performing tasks that demand quick reflexes, focus and it is strictly forbidden when there are any kind of risk involved.

In regards to the consumption of alcohol in certain situations, as stated above, it is the sole responsibility of the employee to consume alcohol in a sensible and moderate manner. Therefore, the employee will answer for any acts or inappropriate behavior that constitutes a violation to this Code of Conduct, other internal policies from the Company and the applicable legislation, caused by the inappropriate or excessive consumption of alcohol, provided by the Company or not.

The Company promotes many internal events in which the consumption of alcohol is allowed, however, it is necessary that the employee is of the legal drinking age locally permitted for the consumption of alcohol where the event takes place.

Carrying or using any kind of illegal substance in the workplace and surroundings is strictly forbidden, in any situation.

Smoking in the Company’s facilities is not permitted, in any situation.

Carrying firearms in the Company’s facilities is not allowed and any person caught in violation of this rule will be subjected to legal measures.

Carrying replicas or melee weapons such as knives in the Company’s facilities is not recommended. It is forbidden to leave them out in the open, and/or use them to hurt, threaten, coerce or any similar action. Items such as penknives, cardboard cutters, scissors and others may only be used as tools.

In the case of toy guns, they can only be used in situations that do not interfere with the work of others and involve only people who are comfortable with this kind of play.

RELATIONSHIP WITH SUPPLIERS AND THE INFORMAL SELLING OF PERSONAL GOODS

Every negotiation must be established formally, with respected, certified supplies who will provide an invoice.

During negotiations with suppliers and the like, it is not permitted to establish business relationships for personal gain or for the benefit of family member or close friends.

Recommending suppliers is allowed, if there is no sort of commissioning or bonus to either party.

It is strictly forbidden to receive any kind of benefit, be it in the form of money, property, services or others, directly or indirectly, from suppliers or third-parties that have a business relationship with Hotmart.

If gifts or presents are received from suppliers, customers, or others, we orient Troopers that, regardless of the monetary value of the item, hand these gifts or presents to the Marketing team, so that a draw among all employees takes place. Exceptions to this rules are simple corporate items, such as water bottles, and low-value office supplies (up to $25.00 or equivalent in local currency), such as pencils, pens, notebooks, appointment books, and the like. In the case of non-transferable gifts, such as dinners, lunches, trips, tickets to events, and others, the Trooper should immediately inform his leader about what he or she has received. And for other items, we also guide the Trooper to talk to the leader.

Every estimate must be approved according to the budget made available for the purpose in question. The restructuring of the budgets must be discussed with the leader of each team and with the financial department.

The informal selling of different kinds of goods is allowed in the Company’s workplace. However, corporate emails cannot be used for such purposes. What’s more, these activities cannot interfere in the work activities of the people involved. The promotion of such items is allowed in extra-official channels, such as Whatsapp groups and Sparkle.

RELATIONSHIP WITH THE GENERAL PUBLIC

As stated in our Culture Deck, we should treat our public, be it customers, partners, suppliers, employees and fans, with a lot of respect, care, and attention.

We must never fail to reply, in an adequate manner and by the people who were assigned to do so, to doubts and requests from people who contact us through social media, blog, or telephone.

We should receive visitors to our offices and workspaces with a lot of care and attention, showing them our facilities and providing an amazing experience. Therefore, it is necessary to constantly pay close attention to our work environment, keeping it clean and pleasant, besides being careful to deal with delicate and confidential issues in reserved, private rooms, whenever someone from outside is visiting.

It is forbidden to use offensive language or publish content that configures a violation of this Code of Conduct in our communication channels.

We must not take a political stand or articulate controversial opinions on behalf of the Company.

It is forbidden to talk to the press if you are not an official spokesperson for the Company. If you are invited for an interview, lecture or any other kind of situation in which some exposure will occur, please report to the Marketing team.

Our positioning on the media and with people we deal with must always be one of respect towards diversity, free of any kind of discrimination.

RELATIONSHIP WITH THE ENVIRONMENT

It is the duty of the employee to avoid wasting water, power, materials and food, as well as to practice and properly dispose of organic, recyclable and electronic waste.

RESPECT TO INTELLECTUAL AND INDUSTRIAL RIGHTS

Considering the market niche in which Hotmart acts, it is undeniable that the search for a market that is free of acts and actions that violate or may violate intellectual and industrial rights is essential to build a digital business environment that is strong and robust, making it possible for people to create and distribute digital content safely.

With this in mind, the following practices by our employees are strictly forbidden:

To access, encourage or facilitate, to himself or herself, or to others, content or products, be them physical or digital, that violate intellectual or industrial rights from the Company or others.

To keep or make use of any items belonging to Hotmart, be them digital or physical, for purposes that are not related to work being done for Hotmart, including source-codes, data models, text, templates, curriculums, images and any other piece of information belonging or obtained during work activity.

INFORMATION CONFIDENTIALITY AND INTERNAL ACCESS DATA

People who have access to confidential information about the Company, customers, partners and employees must be committed not to disclose it under no circumstances

This information must never be disclosed, not to the market, nor informally to co-workers or personal friends, in everyday situations inside or outside the Company.

Access data such as logins to social networking sites, blogs, image banks, digital resources shopping websites, or internal control systems should never be disclosed to people who do not work for Hotmart, or even to non-authorized employees.

The access to the resources used for shopping, such as credit cards and profiles in payment websites should be restricted only to authorized personnel.

RELATIONSHIP WITH COMPANY PROPERTY

It is not permitted to make use or take possession of Company items, such as equipment, office supplies, food or others, for personal use.

Always observe and comply with the Information Security Policies established by the Company.

Whenever it is necessary to use Company equipment elsewhere, especially in events, the employee must provide the equipment identification to the Infrastructure Team, informing the purpose of the use, date the equipment was checked out and the date it will be returned. If there are any doubts, please check the company’s Security Policy.

In case of loss, theft, or any other situation that leads to equipment not been restored to the company, the employee must provide a police report in up to 24 hours after the incident has taken place, and immediately report to the Infrastructure Department so that the access is blocked and, if possible, the equipment is tracked down and located. The Infrastructure Department must also be notified in case of loss or theft of mobile phones for personal use if these have apps that access company’s information.

The access of pornographic material in the workplace is strictly forbidden.

We recommend caution when accessing content that may be considered violent or offensive, in the workplace. The Trooper must be careful so that his or her actions do not make others uncomfortable.

RELATIONSHIP WITH THE MARKET AND COMPETITION

Even though we follow our competitors closely, it is forbidden for any Hotmart employee to act in an offensive way against any of our competitors, be it via social media, or other communication vehicles.

Competitors must be treated respectfully and ethically, in a strategic way, without violating the values of our Company and without harming the performance of these other companies or individuals in a dishonest and slanderous way.

The opposite must also never take place. Meeting competitors at events in the market is something that happens often, therefore, information about the Company must never be shared with employees from other companies by Hotmart employees.

All the information, strategies, goals, and issues dealt must be kept confidential from outside people.

RELATIONSHIP WITH THE GOVERNMENT AND PUBLIC INSTITUTIONS

Information to any sphere of the government, including public municipal, state and federal institutions, must always be provided by the Board of Directors or by the legal/personnel departments, and be registered.

Whenever a requirement is presented by a government representative, including fiscal auditing, the Company must do everything in its power to obtain all the necessary documents for the audit and Company assessment, always notifying the legal department.

RELATIONSHIP WITH PARTNER COMPANIES, EVENTS AND SPONSORSHIP

Hotmart is free to establish partnerships with companies and events with which we share objectives and values.

The partnership and sponsorship relationships must be established based on the financial situation of the Company and the eventual return they may offer.

If a Trooper has a recommendation or identifies an opportunity, he or she should take this information to the area responsible.

The conditions for Hotmart to establish sponsorship and partnership relationships are that the companies involved:

1. Do not establish a sponsorship partnership with companies that notably do not share our values;

2. Make sense to the business strategy set by Hotmart, be it through partnerships, own events and for others, and marketing actions;

3. That the Company or partner are aligned with the leaders from the department required to take part, the Events and Marketing teams;

4. Have sufficient budget to carry out the partnership, sponsorship, or support, after prior agreement;

5. Do not involve any activity that leads to a violation of the conducts in this Code.

RELATIONSHIP WITH THE PRESS

The Press Relations from Hotmart is conducted by a company hired specifically for this purpose, and it is this company’s responsibility, through the employee who is stationed inside the company, to establish necessary contacts and dialogues with communication vehicles.

Only the leaders assigned to each area, the Marketing Department, and the co-founders of the Company are authorized to talk on behalf of the Company. Exceptions must be made with the authorization from these leaders and managers, so that there’s coherence in the image presented by the Company to the market through communication vehicles.

No employee is authorized to speak on behalf of the Company, except if the employee in question is authorized by the people who possess this autonomy, and therefore the employee must report to these people, explain the situation so they can analyze what the best course of action is beforehand.

No promotion material from Hotmart must be published or supplied without prior authorization from the communication department or the Company’s founders.

This Code of Conduct has one major goal: to ensure the safety of every Trooper, so they are aware of their rights and responsibilities, and so that they can consult it whenever necessary. This reinforces the spirit of team autonomy and allows us to, more and more, act assertively in different situations.

And although this document was created to guide our behavior in the Company, don’t forget that the whole Talents team and the members of the All for One committee are always ready to listen to you, support you and help you, whenever you need.

Our email address for any doubts, clarifications, or suggestions, is allforone@hotmart.com.

Definitions

Workplace

The workplace is made up of the Company’s facilities, places in which Troopers provide their services on behalf of Hotmart and any environment where there are get-togethers, parties or celebrations promoted by the Company.

Do you know what harassment is?

Harassment covers a wide range of behaviors of an offensive nature. It is commonly understood as behavior that disturbs or upsets, and it is characteristically repetitive. This repetitive aspect does not, in any way, mean that one instance may not be considered harassment. We once again reinforce that any behavior that is noticed, understood, witnessed or felt as harassment should be reported immediately to the Talents Team, your leader, or a member of the All for One.

In the legal sense, harassment is behavior that appears to be disturbing or threatening.

Sexual Harassment

This is a kind of harassment that can happen anywhere but is most common in the workplace and schools. It involves unwanted and unwelcome words, deeds, actions, gestures, symbols, or behaviours of a sexual nature that make the target feel uncomfortable. It is defined as any kind of approach, be it verbal, virtual, or physical, that aims to take advantage sexually from the victim, by using the hierarchy in the workplace or not.

Moral Harassment

Moral harassment is the exposition of someone to humiliating and embarrassing situations. It is the repeated and prolonged exposure of workers to embarrassing and humiliating situations during the workday and in the performance of their jobs. Very often this concerns the relations in the chain of command and can mean authoritarian or negative behavior on behalf of superiors without ethical conduct over a long period of time. It can involve one or several superiors and how they conduct themselves with someone who reports to them resulting in the destabilization of the victims and their relationships to their work environment and organizations.

Do you know what discrimination is?

Discrimination is the treatment or consideration of, or making a distinction in favor of or against, a person or thing based on the group, class, or category to which the person or thing is perceived to belong rather than on individual attributes. It may occur in different contexts, being the social the most common, through cultural, ethnic, political, religious, sexual or age discrimination, but not limited to these, that may lead to social exclusion. The International Convention on the Elimination of All Forms of Racial Discrimination (ICERD), in 1966, defined discrimination as

“Any distinction, exclusion, restriction or preference based on race, colour, descent, or national or ethnic origin which has the purpose or effect of nullifying or impairing the recognition, enjoyment or exercise, on an equal footing, of human rights and fundamental freedoms in the political, economic, social, cultural or any other field of public life.”

ADDENDUM TO THE CODE OF CONDUCT

ESTABLISHES RULES AND PROCEDURES FOR THE PREVENTION AND FIGHT OF HARASSMENT AND DISCRIMINATION AT THE WORKPLACE

I) HOTMART'S COMMITMENT TO THE PREVENTION AND FIGHTING HARASSMENT

1 - Hotmart is jointly responsible for the welfare and integrity of all Troopers in the performance of their duties, in any situation where they are representing the company.

2 - We consider any type of discrimination or harassment, by Hotmart employees with clients, suppliers, coworkers and partners, unacceptable. And, on the other hand, it is unacceptable for clients, suppliers, coworkers or partners to discriminate against or harass Hotmart Troopers, regardless of the means or place where they are. The procedure and measures to be taken will be detailed in the items below.

3 - Hotmart provides training programs for its employees created by experts on how to act in cases of discrimination or harassment.

4 - Hotmart is committed to the proper investigation and referral of reported discrimination and harassment cases of any nature.

5 – The investigation of discrimination and harassment complaints will be done through the establishment of a specific procedure, ensuring the anonymity of the complainant, the confidentiality of the procedure, the impartiality of the committee representing Hotmart, the right to information of its phases to the complainant and the protection of the complainant, including labor rights, unless bad faith is proven.

7 – Hotmart shall always maintain its channel for reporting irregularities active, especially for harassment and discrimination cases, as specified in item 22.

8 – Hotmart may discontinue any professional relationship as a result of discrimination and harassment after due investigation in a specific procedure, considering the seriousness of the conduct.

9 – The Trooper who feels harassed or discriminated against is guaranteed the immediate interruption of interaction with the client, by communicating the fact to his/her leader and/or team manager.

(II) WHAT IS HARASSMENT AND DISCRIMINATION AT THE WORKPLACE?

10 – Anywhere the Troopers are, while performing their duties for the company is considered their workplace for the purposes of this addendum.

11 - The notion of harassment and discrimination practiced by Hotmart is contemporary and therefore, broad and open so as to cover any unwanted behavior by the Trooper, contrary to the human dignity or that creates an intimidating, hostile, degrading, humiliating or destabilizing environment, violating the behaviors already described in the Code of Conduct.

12 – Hotmart understands that the conceptualization of harassment and discrimination is subjective, and is committed to prevent and combat all types of harassment and discrimination in their most varied conceptions.

13 - Moral harassment is related to any conduct that aims to diminish a Trooper’s self-esteem and ultimately, his/her job termination.

14 - Sexual harassment is related to unwanted behaviors with a sexual connotation, with the prevalence of the agent of asymmetrical relations of power, not only hierarchical, but in all spheres and within all scopes.

“Embarrass someone with the purpose of gaining sexual advantage or favor, with the prevalence of the agent using his/her superior hierarchical status or ascendance inherent to the exercise of employment, position or function" (Law 10,224, 2001 - Brazil.)

15 – Discrimination is related to the act of distinguishing, differentiating or relegating someone based on physical, racial, sexual orientation, gender, etc.

(III) REINFORCING OUR CODE OF CONDUCT: HOW TO DEAL WITH CLIENTS FOR THE PURPOSES OF THIS ADDENDUM

16 - The bases of the relations between Hotmart and the client are established, as a matter of priority, in our Terms of Use, which is widely known and publicized, as well as in commercial agreements eventually signed between the Parties.

17 - Any interaction with our clients, whether in person, by telephone, email, or any other channel, must focus on positive results for both the client and Hotmart.

18 - Any interaction must be based on mutual respect, from both Hotmart as well as the client.

19 - Hotmart recommends that meetings with outside clients be conducted in public places, and undertakes to bear the costs for the leasing of a conference room whenever possible, if necessary.

20- Hotmart does not require the availability of its professionals for activities that put the Trooper in situations of embarrassment caused due to an improper attitude by the client.

(IV) WHAT YOU SHOULD DO IN CASES OF HARASSMENT OR DISCRIMINATION

21 - All harassment or discrimination, whether in an attempted or disguised manner, of a racist, homophobic, chauvinistic, sexist, moral or other nature, must be reported to the employee’s manager, the Team of Talents, or the All for One committee, at the first sign that this is occurring, so that the quickest and most assertive action can be taken.

22 – We guarantee the anonymity of the complaint made by a Trooper who feels harassed or discriminated against, or who has witnessed any situation involving harassment or discrimination, hrough the complaint channel (https://troopers-report.hotmart.com), protecting the anonymity of the complainant.

Sole Paragraph: After the investigation is established based on an anonymous complaint, the accused party will be informed by the committee about the responsibility to maintaining confidentiality, preserving harmony in the workplace until the investigation is completed.

23 – Based the complaint informed, a specific procedure will be established by the team of talents and the All for One committee, for the investigation, clarification of the facts, protection of the denouncer and necessary channeling, as described in the Specific Procedure.

24 – The procedure shall begin with the preparation of an Initial Document, with the description of the conduct, and shall mention the confidentiality nature of the procedure, as well as that it shall be ruled, in all phases, by the adversarial system and ample defense, whenever the supposed agent is a Hotmart Trooper.

(IV.i) Specific procedure for harassment or discrimination practiced by clients

25 – The communication of harassment or discrimination practiced by a Hotmart client on the specific channels has the immediate effect of interrupting his/her contact, in any form, with the Trooper.

26 – In view of Hotmart's commitment to the subject of harassment and discrimination, and the automatic generation of effects from its communication, a specific procedure will necessarily be established to investigate the complaint.

27 – The Trooper who believes that the client's treatment is being discriminatory or abusive shall seek to record all communication, saving messages, emails, and print conversation screens, so that there is an effective contribution in the investigation of the specific procedure.

28 – All calls made to corporate telephones may be recorded and filed for 6 months.

29 - Within the specific procedure, all means of proof admitted by law may be produced, such as those described in item 27.

30 – When establishing the procedure, the Team of Talents shall indicate in the Initial Document, the preliminary proceedings necessary to determine the reprehensible conduct, such as the requisition of documents, breach of confidentiality of institutional emails and corporate phone recordings, among others deemed necessary.

31 – The procedure’s term shall be thirty days (30), extendable for equal and successive periods, provided that it is by a decision based and approved by the committee referred to in item 32.

32 – The committee, indicated in the Initial Document, which will analyze the complaint, formed by five (5) members, with two (2) necessarily belonging to the Team of Talents (one from the Personnel Department), one from the All for One Committee, one (1) member from the Legal Department and one (1) member of the Culture Committee, excluding from this group any person who may be involved in the case.

32.1 - The committee indicated in the Initial Document will elect a rapporteur to analyze the complaint and who will be responsible for all proceedings of the process, the collection of evidence, arrangements with those involved and the issuance of a conclusive report indicating the measures applicable to the case, which shall be submitted for approval by the respective committee.

32.2 - Both the rapporteur, as well as the committee itself, shall act during the entire proceedings observing the principles of impartiality and fairness, and prohibiting conducts that indicate the pre-judgment of either party until the conclusion of the process.

33 – If the complainant has identified him/herself, he/she, at the discretion of the committee, may be informed of the proceedings, including the conclusions, and in any case shall be advised of the duty of confidentiality.

34 - The procedure shall be strictly confidential, safeguarding the privacy of the party potentially involved and the complainant.

35 – The specific procedure will be concluded with a decision by the committee, which shall result in:

(i) the acknowledgement of harassment or serious discrimination, leading to the breach of contract with the client;

(ii) the acknowledgment of harassment or mild discrimination, leading to notification of the client about Hotmart's policy regarding harassment and discrimination, with the possibility of breach of contract in case of repeated conduct;

(iii) filing for failure to prove harassment or discrimination;

(iv) filing due to absence of harassment or discrimination, characterizing the bad faith of the complainant.

Sole Paragraph: The characterization of the complainant's bad faith may lead to his or her employment termination.

36 - Those directly involved may have access, if thus required, to the decision document.

37 – Hotmart, at its sole discretion may, if deemed appropriate, forward a copy of the proceedings to the responsible authorities in cases where there is evidence of a crime or criminal violation.

(IV.ii) Specific procedure for harassment or discrimination practiced by a Trooper

38 – If the alleged conduct was theoretically performed by a Trooper, the specific procedure shall follow the rules of the procedure set forth in item IV.i., in particular the provisions of item 32.2.

39 – The confidentiality of the procedure is guaranteed for both the complainant and defendant, safeguarding the privacy and dignity of those involved, as set forth in item 22.

40 – All means of evidence admitted by law may be produced, as described in item 29.

41 – The right to broad defense and the adversary system is guaranteed to the defendant.

42 – The decision will be made by the committee appointed by the responsible body and sent to the Team of Talents for the application of disciplinary sanctions, as the case may be, as detailed in the Specific Procedure.

43 – Whenever possible and advisable, Hotmart will promote the right to retraction, as educational and remedial measures.

44 - The Trooper that initiates a complaint procedure cannot suffer any type of retaliation for that reason, safeguarding the possibility of being responsible in the case of bad faith.

45 – Hotmart, at its sole discretion, may if deemed appropriate, forward a copy of the procedure to the responsible authorities in cases where there is evidence of a crime or criminal violation.

Hotmart is anticipating the discussion and regulation of this issue, and is open to think and review its procedure.

* This Addendum to the Code of Conduct Hotmart was written with the consultation of the Legal Teaching and Consultancy Institute (Instituto de Ensino Jurídico e Consultoria).

(Version updated 08/13/2018)