Version and change control
|Date||Responsible||Finalization of the initial version|
|27/11/2018||Lauro de Lauro||Finalization of the initial version|
|1.9||27/11/2018||Rodrigo Burjato||Final review for release|
|2.0||27/11/2018||Aila Braga||Final version|
Message from the Board
Today's customers have vast access to all kinds of information and, therefore, are increasingly demanding and aware of what they are looking for. With this, companies have in their hands the great challenge of understanding these needs, meeting and, more than that, satisfying them, seeking to retain the customer. This loyalty is a permanent struggle, making companies increasingly commit to the quality of their products and services.
With that in mind, Sky.One seeks to position itself in the market, in order to be recognized as a company that bases its conduct on ethics, human respect, as well as responsibility towards society.
Our code represents the values that we cherish and live by in our office day-to-day. We are sure that its application will contribute to a healthy, dignified, respectful and extremely successful work environment, making it clear that our dealings with everyone depends not only on what we do, but we mainly take into account how we do it.
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Welcome to the Sky.One .
What is the Code of Conduct
The code of conduct describes the attitude adopted by the company, guiding the actions of its employees so that they act in accordance with the principles of the organization.
All employees must act in a correct, honest and efficient manner in the search for results, incorporating the values expressed in this code and obeying the internal regulations and established policies.
All of our values must be preserved in Brazil and abroad, as we believe that ethics and principles are not changeable. The culture of each place changes, but beliefs and values remain.
Objectives of the Code of Conduct
Sky.One 's Code of Conduct has been developed with the following objectives in mind:
- Promote the company's values, so that all employees are aware of, respect and practice them;
- Serve as a reference for attitudes and behaviors of each employee;
- Contribute so that these values are respected inside and outside the company, having a differentiated look turned to society;
- Facilitate the development of healthy competitiveness among competitors;
- Consolidate loyalty and customer loyalty;
- Add value and strengthen the company's image;
Who does the code apply to?
The corporate code of conduct applies to all professionals working at Sky.One and must regulate the relationships that these professionals maintain inside and outside the company:
- With the other employees of the company;
- With suppliers, customers, third parties, partners and competitors;
- With the community and society in general;
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Terms and expressions used
To guide the proper understanding of this Code of Ethics and Conduct, the terms defined below will have the following meanings, whether in the singular or plural and regardless of gender:
- Sky.One , Auto.Sky , Sky.Saver, Guru.Sky: Names of the company, its products and services;
- Public Agent: any agent, representative, employee, employee, director, counselor or any person exercising, even if temporarily and without remuneration, a position, function or job, elected or appointed, in any entity, department, governmental agency, including any entities of the Executive, Legislative and Judiciary powers, direct or indirect public administration, mixed-capital companies, public foundations, national or foreign, public international organization, or any political party, including candidates running for public office in Brazil or abroad;
- Code: this Sky.One Code of Ethics and Conduct;
- Collaborator: all people who work at Sky.One , including directors, employees, interns and apprentices;
- Anti-Corruption Law: Law No. 12,846, of August 1, 2013, and respective regulations;
- Bidding Law: Law No. 8666, of July 21, 1993;
- Administrative Improbity Law: Law No. 8,429, of June 2, 1992;
- Money Laundering Law: law. No. 9613, of March 3, 1998; and
- Third Party: means any person, natural or legal, acting on behalf of, in the interest or for the benefit of Sky.One , providing services or providing other goods, as well as business partners, including, without limitation, agents, consultants, suppliers, resellers or other service providers.
Fundamental Rights of Employees
Every Sky.One employee, regardless of their function, position, position or salary, will be treated with respect and attention, being able to develop professionally and personally. Occupational health and safety conditions must be the subject of constant attention, assuring employees the lowest possible risk in the performance of their duties.
To this end, everyone must comply with general health and safety standards, participating in training, CIPA and orientation activities.
Personal Conduct and Conflict of Interests
Activities and personal relationships that conflict with the interests of the company should be avoided, and the following attitudes are recommended:
- In case of doubts about the existence of conflicts of interest, consult your immediate superior and the Personnel Management area;
- Third parties must also act and make decisions with Sky.One 's best interest in mind, avoiding conflict;
- If there is indeed a conflict, contact the director of the area, as well as the People Management area, with a view to making the best decision for the company;
- Collaborators with decision-making power cannot deliberate on matters in which they have a personal interest capable of influencing their impartiality;
- Do not accept a position or function in other companies at hours that conflict with your work schedule;
- Referring friends and relatives to existing vacancies is a traditional and accepted practice. It is up to the responsible areas to decide on selection and hiring, with pressure to influence admission, promotion or dismissal by related professionals not being admissible;
- Acceptance of gift certificates must be limited to gifts of no great value, identified with the brand of the person giving the gift and must not be seen as a way to influence any decision regarding business with the company. Gifts that do not meet this definition must be refused. For a better understanding, the value of gifts and gifts cannot exceed ½ (half) of the current minimum wage, as well as the offering and/or receiving gifts and gifts must respect the period of 12 months for a new occurrence;
- It is forbidden to offer or receive gifts or presents by Members of Sky.One , the purpose of which is to obtain an advantage or favor in consideration for the good offered or received;
- Invitations to events, trips and others must be informed to the People Management area, for joint evaluation with the director of the area;
- The approval of expenses for each professional is the responsibility of the immediate superior and the director, in accordance with the provisions of the strategic planning;
Conduct in relation to the media
Only employees appointed to act as spokespersons are authorized to speak on behalf of Sky.One . If any employee is sought to provide information, write articles or give interviews on behalf of the company, he must inform his immediate superior, the Personnel Management area, as well as the communication area.
Sky.One considers the role of the press and other communication vehicles to be fundamental in shaping the organizational image and seeks to provide information and always respond to requests, but considers its right not to express itself on issues that are against its interest or to keep confidential information considered strategic.
Conduct towards the company and its assets
Each Sky.One professional is responsible for the correct use and preservation of the company's goods and assets that are part of their work. The rule also applies to goods from customers, partners and third parties used in the company's activities. Such goods and assets must not be used for personal benefit, except when expressly authorized by the company.
Among the goods and assets, we can mention: equipment, installations, real estate, furniture, business plans, technical and market information, computer programs, models, working papers and documents and others that are part of the group's assets.
The appropriation or improper use of any of these assets, including their copying, sale or distribution to third parties are serious violations that may result in labor or criminal sanctions.
The innovations developed by professionals through their work at the company and the patents and property rights resulting from these inventions are incorporated into the organization's assets and remain with it after the employee leaves.
The use of the group's equipment and means of communication (telephone, email, internet, Skype, Slach and others for communications and personal contacts must be restricted to what is necessary. The internet cannot be used to transmit or receive offensive, aggressive information , pornographic, about political, religious or other positions.Likewise, any and all content conveyed by the company's means of communication can be verified and analyzed by the People Management area, if necessary.
Information must be disclosed internally and externally only by those who are authorized to do so in an accurate, objective and adequate manner. Each employee is responsible for safeguarding the information available to them and must inform their immediate manager of any fact that may seem strange or incompatible with Sky.One 's values. False, slanderous or malicious statements about colleagues, the company, businesses, partners, suppliers or customers may be subject to labor or criminal sanctions.
Accounting records must be prepared and monitored by those directly responsible, in compliance with the legislation, tax rules and company rules. Entries and records are the responsibility of the controlling area.
Employees who have access to privileged information have a duty to keep them confidential, even if they no longer work for the company. The use of this information for personal benefit or that of third parties is a crime, subject to labor and criminal sanctions.
Work papers, reports, correspondence and other documents used in the exercise of professional activity are the property of the company and cannot be taken or copied when the employee is dismissed.
Conduct towards society
Sky.One Sky.One live harmoniously with its surroundings, respecting people,
traditions, values and the environment. Likewise, through social actions, it seeks to collaborate actively for the development of society as a whole, in improving the quality of life of needy communities and in reducing the problems of social inequality.
The company is against any type of child labor and must make sure that its customers, partners and suppliers follow the same principle.
Sky.One supports and carries out activities that help to develop children in nearby communities and, as far as possible, offers learning programs for these young people.
The company also seeks to maintain a relationship of respect with union entities and does not practice any type of discrimination against unionized professionals.
Sky.One Members and Third Parties are prohibited from offering, promising, making, authorizing or providing (directly or indirectly) any undue advantage, payments (including facilitation payments), gifts or the transfer of anything of value to any person, whether public official or otherwise, to influence or reward any official action or decision of such person for his or Sky.One 's benefit.
In addition to the acts mentioned in the caput, all other conduct, of action or omission, that may represent a violation of Sky.One 's principles and values, current legislation, in particular the Anti-Corruption Law, Administrative Improbity Law, Bidding Law and Money Laundering Law.
All contracts entered into with Sky.One must contain an anti-corruption clause, mentioning this Code of Ethics.
Whenever possible, Members and Third Parties of Sky.One must be made aware of the sanctions that may arise from non-compliance with the Anti-Corruption Law, always emphasizing the forecast of strict liability based on said law.
In addition to the general principles already mentioned, all interactions between Members or Third Parties and Public Agents, on behalf of or for the benefit of Sky.One , must be guided by the following specific principles:
- Probity: Acts aimed at circumventing or improperly influencing Public Agents to act or remain silent contrary to the public interest must not be practiced.
- Accuracy in language: the language in all communications with Public Agents must be as precise and technical as possible, in order to avoid misinterpretations of the topics addressed. Terms or expressions should not be used that only the people who maintain that communication are able to understand them.
- Registration of information: whenever possible, the information exchanged with Public Agents in meetings or other meetings (face-to-face, by videoconference or through telephone calls) must be formalized in writing in the minutes and subsequently stored. In addition, these minutes must include the names of the participants in the meetings or meetings, their position, the name of the institution or body to which they are linked, the date, time and the topics that have been discussed in these meetings.
Strict liability does not require proof of intent or fault. Thus, even if the intention was not to commit an act of corruption, if the action or omission in question falls within the following hypotheses, there may be liability based on the Anti-Corruption Law:
- Promising, offering or giving, directly or indirectly, an undue advantage to a Public Agent, or a third person related to him.
- Proven to finance, fund, sponsor or in any way subsidize the practice of illegal acts provided for in the Anti-Corruption Law.
- Proven to use an intermediary natural or legal person to hide or disguise their real interests or the identity of the beneficiaries of the acts performed.
- With regard to bids and contracts: a) frustrate or defraud, through adjustment, combination or any other expedient, the competitive nature of a public bidding procedure; b) prevent, disturb or defraud the performance of any act of public bidding procedure; c) remove or seek to remove a bidder, through fraud or offering advantage of any kind; d) defraud a public bidding process or the resulting contract; e) create, fraudulently or irregularly, a legal entity to participate in a public bidding process or enter into an administrative contract; f) fraudulently obtain an undue advantage or benefit from modifications or extensions of contracts entered into with the public administration, without authorization by law, in the public bidding act or in the respective contractual instruments; or g) manipulate or defraud the economic-financial balance of contracts entered into with the public administration.
- Hinder the investigation or inspection activity of bodies, entities or Public Agents, or intervene in their performance, including within the scope of regulatory agencies and inspection bodies of the national financial system.
Interaction with public agents increases the risk of behavior falling into the above-mentioned hypotheses. Accordingly, all persons covered by this Policy must be aware that none of their acts may generate liability based on the Anti-Corruption Law.
For example, the employee who promises or offers some type of benefit, such as money, meals and trips to Public Agents (public banks, public authorities, members of the Legislative Branch, etc.), in order for them to perform official acts more quickly or more beneficial to Sky.One will violate the Anti-Corruption Act. There will be no need to deliver the promised or offered benefit, either by refusal or not by the Public Agent itself, for the infraction in question to be configured.
The interaction of Sky.One Members and Third Parties, especially those who perform government relations activities, with public or political agents must always be guided by the guidelines of this Code and other Sky.One policies, in particular the Interaction with Agents Policy public.
Interactions between Members or Third Parties and public agents, in the performance of their activities provided to Sky.One , must be recorded and reported to Sky.One 's Executive Board and Compliance Officer.
Hiring employees and third-party service providers
The hiring of Members and Third Parties by Sky.One must be based on their best interest, and the technical capacity of these professionals to occupy functions, positions or provide services to Sky.One shall be verified.
Sky.One not hire as an employee or service provider people or companies related to public agents to carry out its activities.
Contracts entered into by Sky.One with employees and Third Parties must be formalized in writing and contain an anti-corruption clause and explicit mention of this Code of Ethics.
Prior to being hired by Sky.One , all employees and Third Parties must be made aware of the provisions of this Code and other Sky.One policies, being encouraged to comply with them for the duration of their relationship with Sky.One .
Corporate expense reimbursements
Corporate expenses, that is, incurred in the performance of activities or acquisition of goods for the benefit of Sky.One by any of its Members, will be reimbursed exclusively upon presentation of a receipt and approval by the Executive Director of Sky.One .
Under no circumstances will Sky.One reimburse the personal expenses of its Members or Third Parties or, even if not personal, that involve exorbitant amounts, not consistent with the market value for carrying out a certain activity or acquiring a certain well, or that are not accompanied by supporting documentation.
Any violations of this Code or other Sky.One policies by Members and Third Parties of Sky.One must be communicated to Sky.One 's Executive Board and the People Management area, which will carry out the first assessment of the communication.
Members who commit to the violations mentioned in this Code of Ethics may be subject to warning or dismissal sanctions.
Third Parties that commit the violations mentioned in this Code of Ethics may be subject to sanctions of dismissal or contract termination.
In addition to the sanctions provided for in this Code, in the event that the infractions mentioned in this Code of Ethics constitute a crime, Sky.One may inform the competent authorities or adopt the appropriate administrative or judicial measures.
The sanctions provided for in this Code will be applied taking into account the seriousness of the acts performed.
Members and Third Parties have a duty to notify the Personnel Management area of any violation or suspected violation of the provisions of this Code, Sky.One's policies, Sky.One 's Sky.One or any current Brazilian law. To this end, Sky.One provide a Whistleblowing Channel, which will allow the appropriate treatment of communications of identified irregularities in a secure and, if desired, anonymous manner.
As a company associated with ABES, we use the independent reporting channel: https://www.umaempresaetica.com.br/
All denunciations will be forwarded automatically and directly to the Personnel Management area, which will carry out the first analysis and take the matter to the Ethics Committee, keeping the complainant safe.
No retaliation will be permitted and tolerated against anyone who, in good faith, reports a concern about unlawful conduct or non-compliance with the instructions set forth in this document.
Responsibility for the Code of Conduct
Overall responsibility for the Code of Ethics rests with the Ethics Committee (formed by directors) in partnership with the People Management area. Each team leader is seen as co-responsible, having an obligation to:
- Get to know the code in detail, clarifying doubts from your teams. When you are unable to provide support, you should refer the matter to the People Management area
- Adopt behaviors and attitudes that correspond to what is proposed in the code, being an example and living the values that Sky.One believes in its day to day
- Disseminate the company's values and the definitions established in this code to teams, partners and customers, guiding them on how to proceed
- Root Sky.One 's values through its permanent practice
- Identify violations of the code and act to correct and eliminate them, bringing cases to the attention of the People Management area for discussion by the committee
Each Sky.One employee must ensure compliance with the Code of Ethics and inform their immediate superior and the People Management area when they become aware of any violation of the rules.
Validity of the Code
The provisions of this Code shall be in force for a period of 2 (two) years, when they shall be revised.
Code of ethics and conduct Sky.One v2.0