Document Control

Controlled versions and alterations

 

Version Emission Description

 

Date Person responsible
1.9 11/27/18 Lauro de Lauro Finalizing early draft
2.0 12/03/18 Rodrigo Burjato Final review before release
2.1 03/20/19 Aila Braga Final version

 

Today’s consumer has vast access to information of all kinds, becoming more demanding and aware of what they are searching for. Consequently, companies now face the challenge of understanding and suiting these needs, but more importantly, satisfying their clients and building customer loyalty. The fight for customer loyalty is a constant, which means companies have to commit more and more to the quality of their products and services.

With that in mind, Sky.One aims to position itself and be recognized in the market as a company guided by ethics, human respect and social responsibility.

Our code of ethics and professional conduct represents the values that we praise and live by in our day to day lives at the office. We are certain that its application will contribute to a healthy, dignified, respectable and successful work environment, making it clear that our commitment to others isn’t just about what we do, but more importantly about how we do it.

Come experience it with us!

Welcome to the SKY.ONE FAMILY!

 

What is a Code of Ethics and Conduct?

The Code of Ethics and Conduct describes the company’s attitude and behavior, guiding the actions of their contributors in accordance with the organization’s principles. 

All contributors must act in a correct, just and efficient manner when striving for results, incorporating the values expressed in this Code of Ethics and Conduct and obeying internal regulations and policies.

All of our values must be preserved in Brazil and abroad, as we believe ethics and principles are not mutable. The culture might change, but the beliefs and values remain the same.

 

Objectives of the Code of Ethics and Conduct

Sky.One’s Code of Ethics and Conduct was developed with the following objectives in mind:

  • Promoting company values so that all contributors know to respect and practice them daily.
  • Being a reference for attitudes and behaviors of every employee
  • Making sure these values are respected in and out of the workplace, also having an outlook for society.
  • Establishing Sky.One’s values through constant practice
  • Facilitating the creation of healthy competition among competitors
  • Consolidating customer loyalty
  • Creating value and strengthening the company’s image

 

Who does it apply to?

This Code of Ethics and Conduct applies to everyone that works at Sky.One and it must regulate the relationships these contributors have in and out of the workplace:

  • with other company contributors
  • with suppliers, clients, third parties, partners and competitors
  • with the community and society in general

 

About Sky.One

With each passing day, companies need more agility, efficiency and cost-benefits. 

The journey to digital transformation is often complex, as it belongs to a scenery that is constantly changing due to new technologies.

As specialists in planning, building and maintaining cloud environments, Sky.One gained notoriety in the Latin American cloud market with its more than 1000 clients and 1500 project implementations since 2013. Sky.One sees each project as unique, offering safe and consistent services that are based on results and upheld by strategic partners.

Relax and leave all of the complexity of the cloud to us!

Learn more about our history at: https://skyone.solutions/en/about-us/

 

Terms and expressions used

To guide proper understanding of this Code of Ethics and Conduct, the following terms will have the following meanings, regardless of being in its plural or singular form.

  • Sky.One, Auto.Sky, Sky.Saver, Guru.Sky: company denominations, our products and services;
  • Public agents: any agent, representative, employee, director, consultant or any person that, even if temporarily or unpaid, executes a job, role or function, be it elected or appointed, at any entity, department or government agency, including any entities related to Executive, Legislative and Judiciary powers, direct or indirect public administration, mixed economy systems, national or foreing public institutions, international public organizations, or any other political party, including candidates running for office in Brazil or abroad;
  • Code: Sky.One’s current Code of Ethics and Conduct;
  • Contributor: any person who works at Sky.One, including directors, employees, interns and apprentices;
  • Anti-Corruption Law: law n.º 12846, from August 1st, 2013, and its respective regulations;
  • Bidding Law: law n.º8666, from July 21st, 1993;
  • Administrative Improbity: law n.º8429, from June 2nd, 1992;
  • Money laundering Law: law n.º9613, from March 3rd, 1998; and
  • Third parties: meaning any person, natural or juridical, that acts in Sky.One’s name, interest, or for our benefit, providing services or other assets, such as commercial partners, and including limitations, agents, consultants, suppliers, resellers or other service providers. 

 

Fundamental Rights of our Contributors

All contributors at Sky.One, regardless of role, title, tasks or salary, will be treated with respect and attentiveness, being offered proper conditions to develop professionally and individually. Health and safety conditions at work must be a permanent target of attention, as to guarantee our contributors the lowest possible risk while performing tasks.

Thus, all contributors must abide by general health and safety norms, and participate in training, orientation activities and CIPA (Internal Commission for Accident Prevention, or Comissão Interna de Prevenção de Acidentes).

 

Personal Conduct and Conflict of Interests

Personal activities and relations that clash with the company’s interests must be avoided. The following is recommended:

  • If there is any doubt on whether or not there are conflicting interests, consult your immediate superior and the Human Resources department
  • Third parties should also act and take decisions thinking of Sky.One’s best interests and avoiding conflict
  • If conflict evolves, look for the director of your area and the Human Resources department, seeking the best solution for the company
  • Contributors involved in decision-making processes cannot resolve matters in which there are personal interests involved, as such interests might influence their impartiality.
  • If working for other companies, do not accept jobs or roles with conflicting schedules.
  • Previously inform your director, who must then consult the Human Resources department, when a company owned by you, a family member, or someone you have a close relationship with is hired by Sky.One to provide services or products to the company.
  • Recommending friends and family members for open positions is a traditional and accepted practice. It is up to the responsible areas to decide if they wish to move forward with the selection and hiring process, and it is considered unacceptable to pressure or influence the admission, promotion or dismissal of contributors.
  • The acceptance of gift-cards is limited to low-value items that must be associated with the brand offering it and must not be used to influence any decisions related to the company’s business. Gifts that do not fit this description must be returned. For better understanding, the value of these items cannot be higher than ½ (half) of the present minimum wage, and the offering or receiving of gifts must present a 12-month rolling period in between occurrences. 
  • It is prohibited for Sky.One contributors to offer or receive gifts with the intention of obtaining advantages or favors as retribution to other gifts and offers. 
  • Invitations to events, trips and others must be notified to the Human Resources department to assess together with the area director. 
  • The approval of individual professional expenses is the responsibility of immediate superior and directors, according to the company’s strategic planning. 

 

Communication Vehicles

Only contributors selected to exercise the role of spokesperson are authorized to speak in the name of the company. If any contributor is asked to provide information, write articles or give out interviews as a representative of Sky.One, they must notify their immediate superior, as well as the Human Resources and Communication departments.

Sky.One considers the work done by the press and other communication vehicles essential to establish an organizational image, and seeks to provide information and attend to requests, but may choose not to speak on subjects that go against company interests or in order to preserve classified strategic information.

 

Company Assets

All contributors at Sky.One have the responsibility to correctly use and preserve goods and assets belonging to the company and that are part of their work. This rule also applies to client, partner or third party goods and assets used for company activities. Such goods and assets must not be used to personal gains, except when expressly authorized by the company.

These goods and assets include: equipment, installations, properties, furniture, business plans, technical and market information, computer programs, models, work papers and documents, and other goods and assets that belong to the company.

Improper appropriation or utilization, including copying, selling or distributing to third parties, is considered a serious offense and it might result in labor and legal sanctions.

Innovation developed by professionals through their work for the company, as well as resulting patents and ownership rights, are incorporated into the organization’s assets and remain under corporate control even after the contributor’s termination of employment. 

The utilization of equipment and communication means and devices (phone, email, internet, Skype, Slach, and others) for personal use must be restricted to a minimum. The internet cannot be used to forward or receive content that is offensive, aggressive, pornographic, political or religious. On a similar note, any content created for company communication vehicles might be verified and analyzed by the Human Resources department, if necessary.

Information may only be disclosed, both internally and externally, by those authorized to do so precisely, objectively and adequately. Each contributor is responsible for the custody of the information possessed and must notify their immediate superior of anything that seems odd or incompatible with Sky.One’s values. False, slanderous or ill-intentioned information about colleagues, the company, the business, partners, suppliers or clients might result in labor and legal sanctions.

Accounting records must be elaborated and tracked closely by the person directly in charge, obeying legislative determinations, fiscal norms and company rules. New launches and records are the responsibility of the Controllership area.

Contributors that have access to private information must keep them confidential, even in case of termination of employment. The usage of such information for personal or third party benefits is a crime, and it might result in labor and legal sanctions.

Work papers, reports, mail and other documents used to exercise professional activities belong to the company and may not be taken or copied after termination.

 

Society

Sky.One wishes to coexist with its surroundings in a harmonious way that is respective of people, traditions, moral values and the environment. Through social actions, Sky.One actively tries to help in the development of society as a whole, improving the quality of life in needy communities and reducing social inequality problems.

The company is against any sort of child labor and must certify that its clients, partners and suppliers follow the same principle.

Sky.One supports and carries out activities that help kids in nearby communities and when possible, offers learning opportunities to these children. 

The company seeks to maintain a respectful relationship with syndicates and does not discriminate against contributors that are also syndicate members.

 

Anti-corruption Dispositions

It is prohibited to contributors and third parties to offer, promise, create, authorize or provide (directly or indirectly) any improper advantages, payments (including facilitation payments), gifts or transferring of anything valuable to other people, public agents or not, to influence or reward any official action or decision of such people for personal or company benefit. 

Other than the actions mentioned above, it is also prohibited to engage in any other conducts, actions or omissions that might violate Sky.One’s principles and values, as well as legislative demands like the Anti-Corruption Law, the Administrative Improbity Law, The Bidding Law, and the Money Laundering Law.

All signed contracts with Sky.One must contain an anti-corruption clause that mentions this Code.

Whenever possible, contributors and third parties must be notified of sanctions that might result from disobeying the Anti-corruption Law, always stressing the objective responsibilities foreseen by the law.

Besides the principles that have already been mentioned, all interactions between contributors or third parties and public agents, in the name or for the benefit of Sky.One, must be guided by the following principles:

  • Probity: activities that seek to dodge or influence public agents in ways that make them go against against public interests must not be exerted
  • Language precision: the language used when communicating with Public Agents must be as technical and precise as possible in order to avoid erroneous interpretations about the topics dealt with. Terms and expressions that can only be understood by those communicating are to be avoided and must not be used.
  • Information registry: whenever possible, information exchanged with Public Agents during meetings or other encounters (in person encounters, video chats or phone calls) must be formalized in written form through meeting minutes. The minutes must capture the name of the meeting participants, their job title and role, the name of the institution or organ they are linked to, the date, the time, and the topics dealt with. 

Objective responsibilities do not require proof of fraud or guilt. Therefore, even if there was no ill or corrupt intent, actions or omissions that fit the following descriptions might result in legal accountability before the Anti-corruption Law:

  • Promising, offering or giving, directly or indirectly, improper advantages to a Public Agent, or related third parties.
  • Funding, financing, sponsoring or any form of subsidizing illicit acts foreseen by the Anti-corruption Law.
  • Using interposed persons, natural or juridical, to hide or conceal your real interests or the identity of the recipients of the activities exercised. 
  • Regarding bidding and contracts: a) Thwarting or frauding the competitive procedure of public bidding by adjusting, combining or using any method; b) preventing, disturbing or frauding the realization of any procedure of public bidding; c) pushing away, or trying to push away, bidders through fraud or offers of any advantages; d) frauding public bidding or resulting contracts; e) creating a fraudulent or irregular juridical person to participate in the bidding or to celebrate administrative contracts; f) obtaining advantages or benefits, in a fraudulent manner, to modify or extend contracts signed with public administrations without legal consent, in the convocation of the bidding or respective contractual instruments;  g) manipulating or frauding the financial/economic balance of contracts signed with public administrations.
  • Hindering investigations or inspections of organs, entities or Public Agents, or interfering with their activities, including National Financial Systems regulatory agencies and inspection organs.

Interactions with Public Agents increase the risk of fitting into one or more of the descriptions mentioned above. Therefore, all people included in this Policy must be careful that none of their actions result in legal accountability before the Anti-corruption Law.

Exemplarily, the employee that promises or offers any kind of benefits, such as money, meals and trips to Public Agents (public banks, public autarchies, members of the legislative power, etc.), in an attempt to benefit Sky.One in the execution of professional activities or to speed up such processes, will be violating the Anti-corruption Law. It is considered an infringement even when the benefits promised or offered are not delivered, regardless of whether or not the Public Agent refused the proposition. 

 

Sensitive Interactions

Interactions between contributors and third parties at Sky.One, especially those involved in government relations activities with Public Agents or politicians, must always follow the guidelines of this Code as well as other Sky.One policies, more specifically the policy of interaction with public agents.

Interactions between contributors or third parties and Public Agents, when performing activities for Sky.One, must be recorded and communicated to Sky.One’s Executive Board and Compliance Officer.

 

Hiring employees and third party service providers

The hiring of contributors and third parties by Sky.One must be guided by its best interests, and the technical abilities of these professionals must be verified before they are able to occupy job roles or provide services for Sky.One. 

Sky.One will not hire employees, service providers or companies related to Public Agents to conduct its activities.

Contracts signed by Sky.One with employees and third parties must be formalized in written form, and include an anti-corruption clause with an explicit mention of this Code of Ethics and Professional Conduct.

Prior to their hiring by Sky.One, all employees and third parties must be informed of the dispositions of this Code and other Sky.One policies, encouraging them to follow such dispositions while their relationship with Sky.One persists. 

 

Reimbursing business expenses

Business expenses resulting from performing activities or acquiring goods for Sky.One by any of its contributors will be reimbursed only upon approval by Sky.One’s executive director and presentation of a receipt. 

Under no circumstances will Sky.One reimburse personal expenses of their contributors and third parties or expenses that, although not personal, result in exorbitant amounts incompatible with the market value for that specific activity or acquisition. Sky.One will also not reimburse expenses unaccompanied by evidential documentation.

 

Sanctions

Any violation of this Code or other Sky.One policies by contributors and third parties must be communicated to Sky.One’s Executive Board and the Human Resources department, which will perform the first assessment of the situation. 

Contributors responsible for the violations mentioned in this Code of Ethics and Professional Conduct are subject to disciplinary warning sanctions or termination of employment.

Third parties responsible for the violations mentioned in this Code of Ethics and Professional Conduct are subject to termination or rescission of the contract.

Other than the sanctions foreseen in this Code, under the hypothesis that the infractions mentioned in this Code of Ethics and Professional Conduct are criminal, Sky.One may notify authorities, or adopt appropriate administrative or judicial measures.

When applied, sanctions foreseen in this Code will take into consideration the severity of the acts committed. 

 

Further dispositions

 

Reporting channel

Contributors and third parties have the obligation to notify Human Resources of any violation or suspicion of violation of this Code, Sky.One’s policies, Sky.One’s bylaws, or any current Brazilian law. Therefore, Sky.One offers a Reporting Channel, which allows for an adequate and safe response to communications regarding irregularities, and also allows the person to remain anonymous, if desired. 

As a company associated with Associação Brasileira das Empresas de Software (Brazilian Software Companies Association), we use their independent reporting channel:

http://www.umaempresaetica.com.br/

All reports are sent automatically and directly to Human Resources, which will perform the first assessment of the situation and then forward it to the Ethics Council, maintaining the informer anonymous.

We will not tolerate any retaliation against those who, in good faith, report a suspected violation or illegal conduct, or any other suspicion of non-conformity to the instructions presented on this document. 

Responsibility over Code of Ethics and Professional Conduct

The general responsibilities concerning this Code belong to the Ethics Committee (the Executive Board) and the Human Resources department. 

Team leaders are seen as co-responsible, and have the obligation to:

  • Know the Code in detail in order to clarify their team’s doubts. When unable to do so, they must forward the subject to Human Resources.
  • Adopt behaviors and attitudes that correspond to the Code, presenting themselves as an example and following Sky.One’s values on their day-to-day lives.
  • Promote the company values and the definitions established by this Code to their teams, partners and clients, guiding their conducts
  • Identify Code infractions and try to correct and eliminate them, bringing known violations to Human Resources so they can be discussed with the Committee.

All contributors at Sky.One must watch over the compliance of the Code of Ethics and Professional Conduct, and inform their immediate superior and Human Resources if any violation to the norms becomes known. 

 

Code Validity

The dispositions of this Code hold good for 2 (two) years, period after which it should be reviewed.

Code of Ethics and Professional Conduct Sky.One v2.0