BITCLUB ASSOCIATE CODE OF ETHICS

INITIAL CONSIDERATIONS

Clause 1. In establishing the Associate's Code of Ethics, BITCLUB was guided by principles that form the personal and professional conscience of the Associate and represent imperatives of its conduct, based on the ideal legal and correct conduct in and of itself and for Society as a whole.

Clause 2. These are rules of conduct and procedures which should guide the actions of all BITCLUB organization Associates in the development of their businesses.

Clause 3. We pride ourselves in conducting our activities based on legality, honesty and commitment to justice and social peace, defending the fundamental principles of respect for human dignity and adopting protective practices towards everyone’s welfare and quality of life.

Clause 4. In order to maintain the respect and confidence of our market and of society in general, the credibility we achieve must be maintained and assured day after day.

Clause 5. The present Code of Ethics was developed based on our culture, our beliefs and policies, to serve as a guide for our organization Associates.

OF BEHAVIORAL GUIDELINES

Clause 6. All Associates shall develop their business within BITCLUB, based on ethical and responsible behavior, not in violation of the rules of conduct and procedures established by the company, both in this Code and in other agreements signed, and in the applicable legal provisions, such as:

a) Never make promises of quick enrichment and easy work;

b) Never distort information regarding turnover and value of actual or potential earnings;

c) Never use unfair or misleading recruiting practices in your relationship with the prospective Associate candidate;

d) Never create expectations in the applicant regarding gains above the market standard, on the grounds that, by attracting new candidates, he could achieve such gains from the company or its shareholder network;

e) Never attempt to persuade or solicit applicants who have already been invited or registered by an Associate of another network;

f) Never misrepresent company presentations, products, services or compensation plan, using in presentations only the models approved by the company;

g) Never promote any benefits of BITCLUB products or services or of its partners in a way that is vain or that can cause damages of any kind to the company or to the network;
h) Never disparage the products, services, marketing plan or any other attribute of another company;


i) Seek to ascertainas much as possible and reasonable, that the products and / or services offered are appropriate for the purposes proposed, always clearly pointing out any potential negative consequences or restrictions which may arise from the use of such products and / or services;

j) Always inform, in a clear and complete manner, the remuneration criteria of its products and / or services, without leaving any doubt as to its total final value;


k) Accuratly identify the origin of any market research data used in the communication and any other relevant information to assess its reliability, avoiding any presentation that may lead to error or false conclusions;


l) Refrain from using any form of coercive process, including threat or promise of reward, in order to manipulate or influence in any way the distribution and communication channels for the benefit of your organization, your customers or your products and services;

m) Do not use any form of sale, promotion or communication that could be misleading either by omission of relevant data or by false or distorted presentation of information and data.

n) Always accept all the responsibilities inherent to the activity developed;

o) Diligently search for results of a material or institutional nature that have been established in BITCLUB's marketing strategy;

p) Maintain absolute secrecy about any information that is not of public nature and that you come to have direct or indirect access to, in the exercise of your professional activity and whose disclosure may, even minimally, harm clients or the institution in where you work;

q) Do not present the work of another person as your own - totally or partially -;

r) When attending meetings on collective benefit issues, where there are potential conflicts of interest, you should inform the other participants of the existence of this conflict.

COMPLIANCE WITH THE RULES AND PROCEDURES

Clause 7. The BITCLUB organization, through the Ethics Committee and the Ethics Court, has the option to take the disciplinary measures typified in this code when the conduct of the participating partners do not comply with the provisions of this code, terms of use and privacy policy, Brazilian legislation and morality.

DISCIPLINARY SANCTIONS

Clause 8. The exercise of activities related to BITCLUB implies the individual, collective and moral commitment of its professionals to individuals, clients, organizations and society as a whole and imposes non-delegable duties and responsibilities, which will result in disciplinary ethical sanctions, by The Ethics Committee and the Ethics Court, regardless of the penalties established by the laws in force in the country.

Clause 9. BITCLUB shall maintain the Ethics Committee as the first-level adjudicatory body and the Ethics Court as the highest judicial body with the objective of:

a) To supervise, advise and watch over the application of this Code;
b) To adjudicate the infractions committed and the omissions, with due process of law and the application of fundamental rights in this private sphere;
c) Violation of the rules contained in this Code of Ethics requires that, according to its seriousness, it will subject its offenders to the following penalties:
d) Written warning, reserved;
e) Confidential censorship;
f) Public censorship, in case of recurrence;
g) Fines, on a basis established by the Ethics Court, updated annually;
h) Suspension of activities, with block of the virtual office, for 30 (thirty) days, extendable for the same period, if the motivating conditions of the punishment persist;
i) Definitive termination of BITCLUB membership and disclosure of the fact to public knowledge.

PROCEDURAL RULES FOR THE ETHICAL PROCESS

Clause 10. It is incumbent upon the Ethics Committee to prosecute and adjudicate in the first instance any detracting acts of the Associate's ethical conduct.

Clause 11. The ethical process shall be instituted by a reasoned order of the Legal Director, ex officio or by representation of any member of society, observing the principles of the contradiction, ample defense and due process of law.

Clause 12. The defendant will be notified by their virtual office, within five days, to present a defense, digitally in his virtual office, or by other means informed in the notification. The defendant can thus demonstrate the lack of substantiation of the representation, gather evidence and plead his defense.

Clause 13. If the allegation of failure to state reasons for the representation is accepted, the proceeding will be closed and can not be reopened for the same reasons.

Clause 14. If the allegation of failure to state reasons for the representation in the defense is dismissed, the Ethics Committee will immediately judge the merits of the case.

Clause 15. The decision that dismisses the representation against the participating member is unappealable.

Clause 16. The decision that condemns the accused can be appealed to the Ethics Court within a non-extendable period of five (5) days, with devolution and suspensive effect. The decisions of the Court of Ethics, as the highest court, are unappealable.

FINAL PROVISIONS

Clause 17. It is up to the Ethics Committee to form jurisprudence on cases that are omitted and to incorporate it into this Code. It is the responsibility of the Ethics Court to hear the Ethics Committee, to promote the revision and updating of this Code of Ethics, whenever necessary.


Clause 18. The Ethics Committee will be composed of a total of 03 (three) members: 01 (one) member of the Legal Department, 01 (one) member of the Network Board and 01 (one) representative of the Associates.

Clause 19. The Ethics Tribunal shall consist of a total of 05 (five) members: 04 (four) of the founding members of BITCLUB and 01 (one) representative of the Associates.

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