231 Model

The Open Fiber Model consists of a “General Part” and specific “Special Parts” prepared for the various types of offenses and unlawful acts to be prevented, with the Code of Ethics being an integral part of the Model.

The Model represents the essential elements of Open Fiber’s internal control system, understood as the set of all necessary or useful tools to direct, manage, and verify business activities with the objective of ensuring compliance with laws and company procedures, protecting corporate assets, managing activities in an optimal and efficient manner, and providing accurate and complete accounting and financial data.

The guidelines provided by the Model are addressed to all individuals who perform, even de facto, management, administration, direction, or control functions within the Company; to the Company’s employees of any level and under any type of contractual relationship; as well as to those who, although not belonging to the Company, operate in any capacity in its interest, including collaborators and contractual counterparts in general.

All recipients of the Model must collaborate in the full implementation of its principles and provisions, directing their behavior to mitigate risks associated with business activities and processes. The Company sanctions any conduct that violates, in addition to current legislation, the provisions of the Model and the Code of Ethics, particularly concerning the behavioral principles defined by the Company.