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    History of Approvals and Changes

    Skyone Code of Conduct.

    Hello! This is our Code of Conduct. Use the side menu to navigate through the document.

    Hello! This is our Code of Conduct. Use the menu above to navigate through the document.

    Message from the Board

    Skyone understands that the durability of our business and the success of results depend on the way in which Skyowners guide their actions and attitudes and that of everyone who interacts with us, which are based on the values ​​and ethical principles adopted by the company.

    In this sense, Skyone expects and believes that all its employees, business partners, suppliers and third parties base their conduct in compliance with the highest standards of personal and professional integrity.

    healthy, dignified and harmonious business environment , through a high level of trust, respect and transparency in interactions in any area of ​​activity, driving Skyone's unique vision that The extreme success of our dealings with everything and everyone depends not only on what we do, but mainly on how we do it.

    I'm ready. Let's go!

    Field of Applications

    This Code of Conduct is a guide for all Skyone employees (regardless of position) including business partners, franchisees, suppliers and third parties who have a relationship with Skyone.

    As we deal with many people and companies on a daily basis, it is difficult to predict every situation that may arise. Therefore, this document presents principles and good practices to promote an environment of transparency, integrity and mutual respect .

    Terms and Definitions

    A

    Public Agent: any person who performs a public function, whether temporary or permanent, whether paid or not, by election, appointment, designation or any other type of investiture or connection with the public service.

    Senior Management: are Skyone's leaders, including executives, shareholders, advisors and directors.

    Moral Harassment: abusive behavior that can cause damage to a person's personality, dignity or physical or psychological integrity, threaten their job or harm the work environment. This can also occur in virtual environments, such as emails, video conferences, text messages, social networks, among others.

    Sexual Harassment: behaviors of a sexual nature, expressed physically, verbally or through gestures, that are imposed on a person against their will, causing embarrassment and violating their sexual freedom.

    W

    Employee(s): all Skyone employees, including those with permanent or temporary employment contracts, interns and apprentices.

    Corruption: abuse of power to obtain personal benefits.

    F

    Family members: people in the employee's family, including spouse (husband or wife), brothers or sisters, parents, in-laws, children, partner.

    L

    LGPD (General Data Protection Law) : Law No. 13,709/2018 which establishes guidelines for the protection of personal data.

    Learn More

    Anti-Corruption Law (Law 12,846/2013): Federal law that deals with the administrative and civil liability of companies for acts of corruption against the public administration.

    Learn More

    P

    Skyone relationship audience: customers, business partners, suppliers (service providers) and third parties.

    Relatives: person linked to another by the same blood link, affinity or adoption.

    Simplify reality. Impact tomorrow.

    We work with what is invisible, but essential to move the world. And, if it's up to us, not even the sky is the limit for this movement, because we're already there. Skyone breathes innovation to deliver much more than productivity.

    With the integrative power of technology in our hands, we simplify today to impact tomorrow. This way, we evolve businesses, solidify careers and help build a more prosperous society.

    We are tireless in perpetuating our competitive strength and leading a competent and ethical technological structure. And, of course, ensuring a peaceful sleep for customers and partners: this is how we earn their trust.

    Positively impact the productivity of 1 million people by 2028.

    The Skyone platform impacts the daily lives of thousands of people, anywhere across the globe. This impact is reflected in hours saved from the lives of those who have time as their main ally in changing the world.

    By increasing productivity, we eliminate barriers to growth and deliver unlimited scale to any business.

    Our values

    Trust

    We create trusting relationships. We think about the impact of our speech and actions. We care about the beginning, middle and end of everything we do.

    Expected Behaviors:

    • We treat people how they would like to be treated.
    • Everyone can trust that we do our part for the safety of everyone, our business and our customers.
    • Everyone can trust that we ensure the sustainability and longevity of the business.

    Collaboration

    We work to delight and simplify the daily lives of our customers. We contribute constructively to achieving joint objectives.

    Expected Behaviors:

    • We understand the reality of the company's areas and help everyone achieve the best results.
    • We show openness to doing things in different ways and see multiple perspectives.
    • We understand other departments, including their services, results and goals, and involve them in decision-making that affects them.
    • We clarify and align activities with peers and teams, to ensure everyone's effectiveness.
    • We use our resources to build a more just and egalitarian society, beyond our walls.

    Sense of Prioritization

    We are decisive and evaluate the impacts of our priorities. We are agile in decision making.

    Expected Behaviors:

    • We balance the quality of work with meeting deadlines.
    • We respond positively to change, adopting and using new practices to achieve goals and solve problems.
    • We always do our best to deliver with excellence and speed.
    • The customer's business is our business. We understand the reality of the business to prioritize actions.

    Nonconformity

    We are nonconformists. We push each other to always do better.

    Expected Behaviors:

    • We practice “finishing”, nothing remains in our hands.
      We deliver what we commit to with combined excellence.
      We adapt methods to achieve solutions and results in dynamic situations.

    Tireless

    We overcome challenges to bring what matters: impactful results.

    Expected Behaviors:

    • We point out improvements in all situations.
    • We constantly develop to be better professionals.
    • We share our learning and good practices, contributing to everyone’s development.
    • We are tireless in satisfying our customers and partners: we seek to improve and develop new ways to surprise them.

    Legislation, Regulations and Internal Standards

    Skyone values ​​compliance with the laws and regulations of our country.

    All employees need to know and respect our internal rules, and if they notice something that violates these rules, it is important to report it to the Ethics Channel .

    Data and Information Protection

    All employees have a responsibility to protect company information.

    To help you with this mission, we have internal rules on how to classify this information to ensure it is secure.

    Each of us needs to take care of Skyone's important things such as computers, data, copyright and other information . To do this, we must follow the rules of the Information Security Policy and Standards, which are based on good market practices.

    It is very important to keep information confidential, ensure that it is not changed without authorization, and that it is always available when needed. If someone does not do this, they will be going against the rules of this document and the Information Security Policy.

    Personal Data Protection

    Every employee is responsible, not only for company information, but also for the personal data they process in their day-to-day life. Here are some important tips:

    • Protect data from unauthorized access, change, destruction or disclosure.
    • Do not share personal data with unauthorized people;
    • Use the resources that Skyone makes available to you solely for operational purposes;
    • Ensure that the systems, data and information you manage are accessible and protected in accordance with security standards;
    • Ensure continuity of processing of essential business data;
    • Keep the resources available to you in good working order, operating according to specifications;
    • Follow Skyone's guidance on where to store documents and information, especially on cloud storage services;
    • Respect Skyone's guidelines and Code of Conduct to maintain information security during remote work, avoiding exposing confidential information or personal data;
    • Immediately report any questions or incidents to Skyone's Information Security and Governance, Risks and Compliance area, in accordance with the Information Security Policy.

    Heritage and Assets

    Responsibility

    At Skyone, each of us is responsible for taking care of the company, customer, partner and other assets we use at work. We must not use these things for our own benefit unless Skyone authorizes it.

    Appropriation/misuse

    The misappropriation or use of these assets, including their copying, sale or distribution to third parties, can generate serious problems for the employee, such as labor or even criminal sanctions.

    Communication in case of loss, theft or misuse

    If you notice or know of any case of loss, theft or misuse of these assets, you must notify your manager immediately and follow the internal procedures established for these cases. In the event of termination, it is necessary to return cell phones, notebooks and other items provided by Skyone within the stipulated period and in good condition.

    Desktop

    At Skyone, we value a safe work environment that promotes freedom of expression, transparency and respect for everyone's health and privacy.

    We respect the personal lives of our employees, as we understand that it is a personal matter. However, it is important that each person's behavior does not harm Skyone's image or assets.

    Regardless of position, we expect everyone to be treated politely and respectfully. We do not tolerate any type of discrimination, intimidation or embarrassment, whether based on race, color, gender, sexual orientation, religion, origin, social class, age, physical or mental abilities, health conditions, marital status or position.

    Unacceptable Behaviors

    • Discrimination for any reason whatsoever;
    • Carrying out personal tasks during working hours;
    • Unethical or illegal conduct;
    • Violation of external laws and regulations;
    • Hire relatives without formal authorization from the Board of Directors and the People Management area, or influence their hiring without the knowledge of the person responsible for recruitment;
    • Use company resources for personal purposes;
    • Accept corrupt practices (kickbacks, bribes, influence peddling for undue favors) and other illegal behaviors;
    • Prioritization of personal interests or a specific area over those of Skyone;
    • Consume alcohol or illicit drugs on Skyone premises;
      ATTENTION: Moderate alcohol consumption is permitted at Skyone social events, as long as it does not affect behavior or violate the Code of Conduct inside or outside working hours.
    • Carry weapons inside Skyone, unless the position requires it;
    • Share passwords and users of Skyone systems.

    Expected Behaviors

    • Act with objectivity and clarity to strengthen respect and trust in relationships;
    • Stimulate teamwork and focus on the best results for Skyone;
    • Respect the authorship and merit of all activities, ideas and work carried out;
    • Be transparent in relationships and communicate any type of conflict of interest;
    • Practice open dialogue and listen respectfully to other opinions.

    Affective Relationships

    At Skyone, it is important that employees act in a manner compatible with the work environment, ensuring the smooth running of activities.

    Therefore, we have established that no emotional relationship between employees should harm their professional conduct.

    Moral and Sexual Harassment

    At Skyone, we do not accept any type of harassment , whether sexual, moral or any other behavior that disrespects or intimidates colleagues, regardless of their position in the company.

    In addition to Skyone's disciplinary measures, those who commit harassment may face legal action. The company follows Law 14,457/2022 , which combats sexual harassment and other forms of violence at work.

    Inclusive and diverse work environment

    At Skyone, we value diversity and give opportunities to all people, regardless of their cultural, ideological differences, opinions, disabilities, gender, color, ethnicity, origin, political convictions, religious beliefs, generation, marital status, union membership status, social class, sexual orientation or level of education.

    Our commitment is to create a welcoming and collaborative environment where everyone feels included.

    Unacceptable Behaviors

    • Letting personal characteristics hinder work or limit professional growth;
    • Using the position to impose political or religious opinions;
    • Associate Skyone's image with political or religious activities without prior authorization from the right area;
    • Be conniving with any type of moral, sexual harassment, aggression or violence; It is
    • Express yourself in a way that harms work relationships, avoiding offensive words or jokes.

    Expected Behaviors

    • Respect the qualities, characteristics and rights of everyone;
    • Working together, accepting different ideas and talking constructively;
    • Recruit, promote and reward based on merit, providing equal opportunities to all;
    • Promote diversity when composing the team;
    • Make decisions without prejudice or personal preferences;
    • Create a work environment that reflects the appreciation of diversity;
    • Report any discriminatory behavior you may have witnessed to the Ethics Channel;
    • Respect each person’s religious beliefs, as well as the right not to participate in religious events; It is
    • Respect each other's political opinions and do not carry out political propaganda on Skyone's premises.

    Health and safety

    We believe that all employees have the right to a safe and healthy work environment. Therefore, we guarantee adequate working conditions, following hygiene and safety principles.

    We constantly carry out and evaluate actions to prevent and correct problems, including adjustments to the environment and ergonomics. Each of us must follow the rules and procedures to maintain our physical integrity and that of our colleagues, both inside and outside the company.

    Unacceptable Behaviors

    • Working under the influence of alcohol, drugs or other substances that impair the ability to carry out activities, putting one's own life and that of others at risk;
    • Carrying out activities or exposing colleagues to situations that pose risks to physical integrity.
    • Forcing colleagues to carry out activities that put their health and safety at risk due to their position.

    Expected Behaviors

    • Refuse to carry out activities or situations that pose risks to health and safety.
    • Immediately report to the People Management area any situation that puts someone's integrity at risk;
    • Understand and follow legal requirements and internal health and safety standards;
    • Carry out activities only if you are qualified, authorized, with the appropriate tools and in good physical and mental condition.;
    • Contribute to a safe and healthy work environment, both physically and mentally;
    • Comply with Skyone's rules regarding the performance of periodic occupational examinations;
    • Report to the People Management area any unsafe act or condition in the work environment, as well as accidents and illnesses related to work.

    Socio-environmental Commitment

    At Skyone, we strive to reduce our impact on the environment as much as possible.

    We develop actions that aim to reduce the consumption of electricity, water, plastics, paper and other materials, in addition to encouraging recycling practices and respect for the environment.

    Expected behaviors

    • Develop and operate projects minimizing impacts and avoiding damage to the environment;
    • Meet Skyone's goals for the sustainable consumption of resources such as water, electricity, among others.

    Social networks

    Access

    We believe that all employees have the right to a safe and healthy work environment. Therefore, we guarantee adequate working conditions, following hygiene and safety principles.

    The employee may not speak on behalf of Skyone or promote causes on social media, unless authorized by the Board of Directors or related to the content published by Skyone.

    Undue disclosure

    Otherwise, it is important to avoid sharing any post that contains defamation, slander, insult, harassment, discrimination or intolerant opinions of a political or religious nature, as this may harm your image and that of Skyone itself.

    Otherwise, it is important to avoid sharing any post that contains defamation, slander, insult, harassment, discrimination or intolerant opinions of a political or religious nature, as this may harm your image and that of Skyone itself.

    Improper use of the brand or company name in embarrassing situations will subject offenders to disciplinary measures or even dismissal.

    Undue disclosure

    On professional social networks, such as LinkedIn, when you link your profile to Skyone, you become a representative of the brand.

    Therefore, when accepting connections who present themselves as Skyone employees, check the authenticity of the information to avoid fraud.

    Unacceptable Behaviors

    • In the case of defamation, slander, insult, harassment and discrimination against Skyone or co-workers, the employee may be punished according to the seriousness of the situation, with the offender being subject to disciplinary measures and/or penalties, based on applicable legislation, including verbal or formal warning, suspension and dismissal.

    Expected Behaviors

    • Always maintain an attitude aligned with our Values;
    • Do not make commitments on behalf of Skyone unless it is part of your responsibilities and you have the necessary approvals; It is
    • Do not criticize colleagues or Skyone on social media or other channels that expose those involved. Send criticisms or complaints to the company's official channels.

    Corporate email

    Corporate email is a work tool used mainly to exchange professional messages.

    Inappropriate content

    You can use corporate email for personal matters, but with moderation and common sense. Make sure the content does not include:

    • Competitors;
    • Promotions;
    • Paid side activities;
    • Anything inappropriate, such as erotic, pornographic, discriminatory, violent, political or harassing content.

    Mobile devices

    It is important to avoid excessive or inappropriate use of personal mobile devices (cell phones or tablets, for example) during work.

    External Relationship

    Clients

    Our relationship with customers must be:

    Unacceptable Behaviors

    • Disclose and provide incorrect or inaccurate information;
    • Neglecting service to any customer, regardless of value or size.
    • Using illegal means to gain or maintain customers, such as paying amounts or any type of undue benefit. This constitutes corruption, as it can be understood as bribery or kickbacks.

    Expected Behaviors

    • Maintain commitment to the satisfaction of our customers;
    • Treat customers politely and efficiently, always providing accurate, clear and transparent information;
    • Fulfill what was agreed with the customer, preserving Skyone's credibility and image.

    Suppliers and Business Partners

    Our partners and suppliers must follow the same ethical principles as us, respecting Skyone's internal rules.

    Suspicious attitudes, such as bribery or illegal favors that could harm Skyone , its employees or society, are completely prohibited by both Skyone and the Anti-Corruption Law, which regulates these practices.

    Unacceptable Behaviors

    • Have relationships with suppliers that may generate conflicts of interest;
    • Offer, promise, induce or give undue gifts or advantages to influence decisions in favor of Skyone or for your own benefit.

    Expected Behaviors

    • Treat our suppliers with respect and honesty;
    • Hire partners who do not exploit child or slave labor;
    • Do not accept services or materials that are not in the purchase documents (contracts, for example), even if they seem advantageous to Skyone.
    • Protect the information used in our partnerships with suppliers and proponents (technical, commercial, strategic, financial, registration information, among others), whether ours or those of third parties;
    • Do not do business with suppliers who do not follow the rules of our Code of Conduct.

    Competitors

    At Skyone, we value fair and fair competition, acting transparently and respecting all competition and antitrust laws. We follow the free enterprise system , which means:

    • Never speak incorrectly about our competitors' products or services;
    • We must use only legal methods to obtain competitive information.
    • Respect the confidential information and intellectual property rights of our competitors and other companies.
    • If you notice something that could harm Skyone, report it impartially and based on concrete evidence to the Ethics Channel.

    Press and Corporate Information

    At Skyone, we deal with important information every day. Here are some important guidelines on how to handle press and corporate information:

    • Only the Marketing team is authorized to speak to the press on behalf of Skyone, whether in writing or verbally.
    • Each employee is responsible for protecting the information they have. If something seems strange or incompatible with Skyone's values, it is important to report it to your manager immediately.
    • Accounting records must be prepared and monitored by those directly responsible, following all laws, tax regulations and our company rules. The Controllership area is responsible for these tasks.
    • If you have access to privileged information, it is essential to keep it confidential, even after you leave the company. Improper use of this information may result in serious labor and criminal consequences.

    Unions

    We recognize the category union(s) and employer unions as legitimate representatives of the parties involved in labor and union relations, with respect for free association and permanent dialogue in the construction of productive and harmonious labor relations.

    Anti-corruption

    At Skyone, we act with integrity and ethics in all of our business dealings. Here are our guidelines regarding corruption prevention:

    Ethical principles

    All Skyone business must be conducted within legal and corporate ethical principles. We do not tolerate any form of corruption, whether passive or active.

    Transparency and Exemplary

    Our relationships with external agents, both from the public and private sectors, must be transparent and exemplary, preserving the reputation of Skyone and everyone involved.

    Offers and Payments

    We do not authorize practices that involve offering payments or benefits to government or private authorities to obtain commercial advantages. If you are faced with a situation of this type, inform the GRC or Legal area immediately.

    Legal Compliance

    Although we follow Law 12,846/2013 , which deals with acts of corruption within the scope of public administration, we adopt practices to curb any corrupt behavior, regardless of the type of business.

    Good Practices

    We recommend that, when holding meetings with public agents, you are accompanied by at least one other Skyone colleague, and that you do not accept or pay expenses during these meetings, communicating that this is in accordance with Skyone's Compliance rules.

    Constant Update

    We are always up to date with the best market practices on the subject, including anti-corruption clauses in our contracts and dissemination of this Code, Policies and Standards in the available internal channels.

    Invitations, Giveaways, Gifts and Courtesies

    At Skyone, we have clear guidelines regarding invitations, giveaways, gifts and amenities. If someone offers you a gift, you can only accept it if:

    • The value of the gift does not exceed half of the current minimum wage (small value).
    • The gift bears the mark of the giver (identification of the giver).
    • It must not influence any business decision-making (anti-corruption).
    • Respect an interval of 12 months since the last gift/gift given by the person (one gift per year).

    Donations, sponsorship and charity

    Any donation, sponsorship or act of charity on behalf of Skyone must be approved by the areas of:

    Compliance

    Marketing

    Legal

    People management

    This is done to evaluate the suitability, mission and actions of the organizations that will receive the benefit, avoiding conflicts of interest and only benefiting entities that comply with the law.

    Dress and Personal Presentation

    Employees represent the image of Skyone.

    Therefore, they must follow the guidelines of the People Management area regarding clothing and personal presentation, maintaining an image consistent with the company's values.

    Inventions, Discoveries and Improvements

    Any invention, discovery or improvement made by an employee during the period of employment will be the property of Skyone and may not be used for personal purposes or passed on to third parties. 

    Employees must classify information in accordance with Skyone's Information Classification Standard.

    Leaking information can cause image and financial damage to Skyone , in addition to causing disciplinary and/or legal penalties.

     

    Conflict of interest

    A conflict of interest occurs when the personal interests of an employee or leader conflict with those of Skyone or its network of relationships.

    These situations can affect the company's image, integrity and reputation, in addition to harming third parties and partners. Therefore, they must be communicated quickly to the competent areas and handled with transparency and efficiency.

    Relatives

    If a family member of yours works for Skyone's suppliers, customers or competitors, or has significant financial interests in these companies, be alert to a possible conflict of interest.

    Before doing business with a company in which a family member is involved, it is necessary to inform the leadership of the situation for evaluation and obtaining approval, if necessary.

    It is essential to document this approval if it is granted.

    Any outside activity must be completely separate from working at Skyone, whether it be a second job or self-employment. We must not use working time at Skyone or involve other employees in external activities without specific and clear authorization from the manager.

    Limitations

    As an employee, there are some limitations you must observe to maintain a safe work environment and avoid problems for yourself and Skyone.

    Prohibited situations, regardless of authorization

    It is prohibited to film or take photos inside the Skyone that would compromise its image in the market.

    Prohibited situations, regardless of authorization

    • Enter Skyone with alcoholic drinks, radio, entertainment material and animals;
    • Circulate sweepstakes, raffles, lists, petitions, distribute or sell invitations, tickets or similar, or carry out any type of commerce within Skyone;
    • Use Skyone's name for personal activities;
    • Carry out political campaigns and/or place notices about them within Skyone;
    • Place notices, invitations, posters of any nature inside Skyone;
    • Disclose professional and confidential knowledge acquired at Skyone to other people;
    • Promote external conferences, publish articles or use other means of dissemination on matters related to Skyone.

    Situations that must be authorized by the employee's leadership:

    • Bring visitors to Skyone;
    • Use Skyone tools, phones, materials, computers and vehicles for personal purposes or for services unrelated to Skyone during working hours.

    High admnistration

    Our senior management has an important role in being an example for all employees. They must promote, follow and highlight the values ​​and behaviors of this Code of Conduct.

    Leaders

    Leaders have the mission to publicize and ensure that everyone follows this Code of Conduct.

    Collaborators

    They must know and follow the rules of this Code of Conduct. To show this commitment, they must sign the Skyone Code of Conduct Commitment.

    Treatment of Nonconformities and Penalties

    Failure to comply with this Code of Conduct or other Skyone policies will have consequences. Depending on the severity of the situation and applicable laws, this may include:

    Warnings

    Suspensions

    Layoffs

    For Skyone employees, if non-compliance is repeated, they may end up being fired for just cause, based on insubordination.

    It is important to know that Skyone can take immediate action, without having to wait for repeat offenses to apply punishments, if the situation is serious enough.

    Violations

    Any violation of Skyone's Code of Conduct must be reported via the Ethics Channel and the case will be analyzed by the Skyone Ethics Committee.

    Access our Ethics Channel

    Validity

    This Code of Conduct comes into force Skyone's media

    Final considerations

    If you have any questions, just contact the Governance, Risks and Compliance Area by email:

    grc@skyone.solutions

    Review Participants

    Adriano Cruz da Silva
    Adriano Cruz da Silva

    Governance, Risk and Compliance Manager

    History of Approvals and Changes

    Historic

    Version
    Date
    Change
    Responsible
    1.9
    27/11/2018
    Finalization of the Initial Version
    Lauro de Lauro
    2.0
    13/12/2018
    Final Review for Release
    Lauro de Lauro
    2.1
    20/03/2019
    Final version
    Aila Braga
    3.0
    23/05/2022
    Final version
    Lauro de Lauro
    3.1
    22/03/2024
    Full review
    Renata Miziés de Barros

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