Code of ethics and conduct

Version and change control

 DateResponsibleFinalization of the initial version
1.927/11/2018Lauro de LauroFinalization of the initial version
2.003/12/2018Rodrigo BurjatoFinal review for release
2.120/03/2019Aila BragaFinal version
3.023/05/2022Lauro de LauroFinal version

Message from the Board

Since its foundation, Skyone has sought to position itself in the market in order to be recognized as a company that is guided by ethical conduct, conducting business with integrity, respect for human beings and responsibility towards the society in which it operates.

Our Conduct Manual represents the values ​​and behaviors that we value and experience as Skyone employees. 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 everything and everyone depend not only on what we do, but mainly on how we do it.

What is the Conduct Manual

The Conduct Manual describes the postures and positions adopted by Skyone and must guide the actions and attitudes of all employees, partners and third parties. This Manual was developed to have the weight of a Code of Ethics with the following objectives:

  • 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 corporate values ​​are respected inside and outside the company, having a differentiated look at society;
  • Facilitate the development of healthy competitiveness among competitors;
  • Add value and strengthen the company's image.

All employees, in Brazil or abroad, must act with integrity and efficiency in the search for results, incorporating the values ​​expressed in this code and obeying the internal regulations and established policies.

To facilitate its understanding and reading, the Conduct Manual is divided into 4 blocks:

1. Responsibility in the Work Environment

2. Responsibility in the Relationship with Suppliers and Customers

3. Responsibility for information, assets and corporate image

4. Responsibility and Conduct in Relation to Society

Our essence: Mission, Vision and Values

Skyone is based on daily behaviors and principles that have been strongly experienced since
its foundation. That's why we follow our Mission, always guided by our values.

Our mission:

Transform the way companies consume technology by adding intelligence and
agility with tools that modernize the software and allow the reinvention of the
business model.

Our values:

  • Innovation
  • Partnership
  • Resilience
  • SkyOwners


We love to think differently!


  • Make mistakes without fear, tolerance for mistakes
  • There is always a way to do better
  • learn from the mistake


  • Proposing different ways of doing things every time
  • We learn from mistakes by proposing efficient solutions
  • We respect differences, of any nature


Together we go further!


  • Success depends on everyone. Together we go further
  • Here everyone wins or everyone loses
  • We are all responsible for the success of the team


  • We propose positive solutions for both sides
  • We take care of the impact that our actions cause on others
  • We treat each other as others would like to be treated.


We are better every day!


  • Believe in the power of SkyOwners
  • Engaged people can more


  • We breathe smart
  • We constantly overcome obstacles and results
  • We act with focus and in this way, talent wins over effort


Proud to be SkyOwner!


  • Enjoy the journey, do it with pleasure


  • We defend and apply the company's values ​​in practice
  • We practice what we say
  • We use Skyone resources consciously and sustainably

Our responsibility with the Conduct Manual

The Skyone Conduct Manual applies to all employees, without exception, and must guide the relationships they 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 at large

Each Skyone employee must ensure compliance with the Conduct Manual and inform their immediate superior, the People Management area or the Conduct Committee through the reporting channel ( when they know of any violation of the rules

Leadership Responsibilities

It is the role of all leadership:

  • 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 Personnel Management area;
  • Adopt behaviors and attitudes that correspond to those proposed in the code, being an example and living the values ​​that Skyone believes in its daily life;
  • Disclose the company's values ​​and the definitions established in this code to teams, partners and customers, guiding them on how to proceed;
  • 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;

The Conduct Committee

Overall responsibility for the Conduct Manual rests with the Conduct Committee, made up of at least one representative from the People Management, Governance, Legal areas and two other invited employees. It is part of the Committee's responsibilities:

  • Receive violations of the Conduct Manual reported through the Reporting Channel;
  • Treat the information received confidentially and respectfully, whether anonymous or not;
  • Deliberate on proposed actions and sanctions for each breach of the Conduct Manual;
  • Safeguard the constant updating of the Conduct Manual.

Reporting Channel

Skyone provides a Reporting Channel (made possible by the An Ethical Company Program in partnership with ABES Associação Brasileira das Empresas de Software ) that allows the appropriate treatment of communications of identified irregularities in a secure and, if desired, anonymous manner:

All complaints will be forwarded automatically and directly to the Personnel Management area, which will carry out the first analysis and take the matter to the Conduct Committee, keeping the whistleblower 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.

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:

I. Public Agent: any agent, representative, collaborator, employee, director, counselor or any person exercising, even if temporarily and without remuneration, a position, function or employment, 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;

II. Manual: this Skyone Conduct Manual, which has the weight and effectiveness of a Code of Ethics;

III. Collaborator: all people who work at Skyone, including directors, employees, interns and apprentices;

IV. Anti-Corruption Law: Law No. 12,846, of August 1, 2013, and respective regulations;

V. Bidding Law: Law No. 8666, of July 21, 1993, and respective Decrees;

SAW. Administrative Improbity Law: Law No. 8429, of June 2, 1992;

VII. Money Laundering Law: Law. No. 9613, of March 3, 1998; and VIII. Penal Code: Decree Law No. 2,848, of December 7, 1940, especially Articles 215-A and 216-A;

IX. State Law No. 12,250, of February 9, 2006, on Moral Harassment;

X. Third parties: means any person, individual or legal, acting on behalf, interest or Skyone benefit, provide services or provide other goods, as well as business partners, including, without limitation, agents, consultants, suppliers, dealers or other service providers.


At Skyone we are committed to promoting a productive, safe, fair, respectful and inclusive work environment for everyone. We value transparency and integrity in all our actions, always communicating the organization's relevant facts to our internal public, reinforcing our relationships and trust.

Human rights

In our internal and external relationships with Skyone, compliance with Human Rights guidelines must be respected, protected and encouraged. Any use of child, forced or compulsory labor, as well as any form of slavery, whether modern or not, are prohibited and condemned.

Fundamental Rights of Employees

Every Skyone employee, regardless of their role, position, title or salary, will be treated with respect and attention, being able to develop professionally and personally. It is the right of Skyone employees to have their work guided in accordance with the provisions of the Employment Contract signed upon admission to the company.

Equal Opportunity and Treatment

All actions and behaviors at Skyone must be guided by equal opportunities and treatment. Any decision-making regarding Skyone employees must be based solely on their respective qualifications and capabilities.

Diversity must be lived and celebrated, practicing inclusion by encouraging the individuality of each being. Accordingly, any type of discrimination based on ethnicity, nationality, gender, religion, worldview, age, disability, sexual orientation, skin color, political position, socioeconomic origin or other characteristics protected by law is not tolerated.

Recruitment and selection

The hiring of Employees and Third Parties by Skyone must be based on its best interests, and the technical capacity of these professionals to occupy functions, positions or provide services to Skyone must be verified.

Skyone will not hire people or companies related to public agents as employees or service providers to carry out its activities.

The contracts signed by Skyone with employees and Third Parties are formalized in writing and contain an anti-corruption clause and explicit mention of this Conduct Manual.

Prior to being hired by Skyone, all employees and Third Parties must be made aware of the provisions of this Manual and other Skyone policies, and are encouraged to comply with them for the duration of their relationship with Skyone.

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.

People's Image

The image of employees, third parties, customers and partners must be preserved. The use of images for commercial purposes must be previously and formally authorized. All Skyone employees are invited to sign, upon admission, the Image and Voice Use Authorization Term.

Affective Relationship

Skyone is not against emotional relationships or kinship between employees, as long as there are no conflicts of interest under the terms of this Conduct Manual and the company's relevant policies. Private and intimate issues should not interfere with the work routine, whether they are public displays of affection or discussions.

The affective relationship between employees in a direct hierarchical situation is not recommended, in order to preserve the rights of equal treatment and opportunities. In case the affective relationship begins after the beginning of the employment contract, it is recommended to change the area or function, without prejudice to the salary or employment of those involved, in order to avoid conflicts of interest.

Violence, Moral and Sexual Harassment

At Skyone, any manifestations of violence, whether physical, verbal, psychological or any other, are not tolerated. Whether this violence is committed against direct employees, service providers, customers or business partners.

Any type of moral, sexual harassment, sexual harassment, under the terms of the laws mentioned in the “Terms and Expressions Used” chapter of this Conduct Manual, as well as conduct considered inappropriate such as verbal, gestural or physical sexual proposals or insinuations that affect dignity or create a hostile, intimidating or offensive work environment.

Any attitude or behavior that affects these terms must be communicated to the People Management area or anonymously through the Reporting Channel available at the link, made possible by the Uma Empresa Etica Program in partnership with ABES (Brazilian Association of Software Companies).

Illicit and licit drugs

It is not permitted to carry out professional activities inherent to the position held or remain in Skyone's corporate environments while drunk or under the influence of any type of illicit drug. The consumption of alcoholic beverages is permitted at social events related to Skyone, as long as it is moderate and does not encourage behavior that violates the Conduct Manual and outside working hours.

Reimbursement of Corporate Expenses

Corporate expenses, that is, those incurred in the performance of activities or acquisition of goods for the benefit of Skyone, by any of its Employees, will be reimbursed exclusively upon presentation of a receipt and approval from direct leadership and with the respective support provided in the budget.

Under no circumstances will Skyone reimburse personal expenses of its Employees or Third Parties or, even if not personal, amounts to exorbitant amounts, not consistent with the market value for carrying out a certain activity or acquiring a certain asset, or that are not accompanied by supporting documentation.

Relationship with Suppliers and Customers

Activities and personal relationships that conflict with the company's interests must be avoided. Third parties must also act and make their decisions with Skyone's best interests in mind, avoiding conflicts.

In case of doubts about the existence of conflicts of interest, consult your immediate superior and the Personnel Management area. 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 that could influence their impartiality.

Work for different companies and clients:

The exercise of functions in other companies can only occur if permitted by each employee's individual employment contract and after express authorization from the Conduct Committee, taking into account working hours, functions performed at Skyone, security of corporate information and evaluating possible interest conflicts.

Suppliers and Service Providers

Inform your director in advance, who should consult the People Management area, when any company owned by you, family members or people close to your relationship is qualifying or is contracted to provide services or supply products to the company.

Gifts, courtesies and giveaways:

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 1⁄2 (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.

The offering or receiving of gifts or gifts by Skyone members, the purpose of which is to obtain an advantage or favor in return for the good offered or received, is prohibited.

Invitations to events, trips and others must be informed to the People Management area, for joint evaluation with the Conduct Committee.

Responsibilities with information, assets and corporate image

Conduct in relation to the media and the press

Skyone considers the role of the press and other media outlets to be fundamental in shaping the organizational image and seeks to provide information and always respond to requests, but considers its right not to speak out on issues that go against its interests or to maintain confidentiality regarding information considered strategic .

Only employees appointed to act as spokespersons are authorized to speak on behalf of Skyone. If any employee is approached to provide information, write articles or give interviews on behalf of the company, they must inform their immediate superior, the People Management area, as well as the Marketing area.

Conduct in relation to property and assets

Each Skyone 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 the assets of 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 company'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.

Responsibility and rights over the innovations developed

The innovations developed by professionals through their work in 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 company, in accordance with the “Secrecy, Confidentiality and Copyright Policy ” signed by all employees upon joining Skyone.

Use of corporate equipment and communication channels for personal purposes

The use of the group's equipment and means of communication (telephone, e-mail, internet 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, pornographic, political, religious or other information. Likewise, any and all content conveyed by the company's media can be checked and analyzed by the People Management and Marketing area, if necessary.

Conduct in relation to corporate information

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 the custody of the information they have and must inform their immediate manager of any fact that may seem strange or incompatible with Skyone's values. False, slanderous or malicious statements about colleagues, the company, business, 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 in relation to the Company

Skyone seeks to live harmoniously with its surroundings, respecting people, traditions, values ​​and the environment. Likewise, through social actions, it seeks to actively contribute to the development of society as a whole, improving the quality of life of needy communities and reducing 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.

Skyone supports and carries out activities that help develop children in nearby communities and, whenever possible, offers learning programs to these young people.

It also seeks to maintain a relationship of respect with union entities and does not practice any type of discrimination against unionized professionals.

Donations, Sponsorships and Charities

Any and all donations, sponsorships and charities to be made in the name of Skyone must be validated by the Conduct Committee in partnership with the Marketing, Legal and People Management areas in order to evaluate the background, mission and actions of the recipient entities, avoid conflicts of interest and the benefit of entities that are not in line with current legislation.

anti-corruption provisions

Skyone Employees 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 an agent public or otherwise, to influence or reward any official action or decision of such person for the benefit of themselves or Skyone.

In addition to the acts mentioned in the caput, all other conduct, action or omission, that may constitute a violation of Skyone's principles and values, current legislation, in particular the Anti-Corruption Law, Administrative Improbity Law, Tender Law and Law of Money Laundering, in addition to the Penal Code in force in the country and other Laws, Decrees and Regulations that may exist on the subject.

All contracts signed with Skyone must contain an anti-corruption clause, mentioning this Conduct Manual. Whenever possible, Skyone Employees and Third Parties must be made aware of the sanctions that may arise from non-compliance with the aforementioned Laws, with the provision of objective liability based on current legislation always being highlighted. In addition to the general principles already mentioned, all interactions between employees or Third Parties and Public Agents, on behalf or for the benefit of Skyone, must be guided by the following specific principles:

I. Probity: Acts aimed at circumventing or improperly influencing Public Agents to act or remain silent contrary to the public interest must not be practiced.

II. 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.

III. 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 current legislation:

I. Promising, offering or giving, directly or indirectly, an undue advantage to a Public Agent, or a third person related to him.

II. Proven to finance, fund, sponsor or in any way subsidize the practice of unlawful acts provided for in current legislation.

III. 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.

IV. With regard to tenders 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;

g) manipulate or defraud the economic-financial balance of contracts entered into with the public administration.

V. Hindering the investigation or inspection activity of bodies, entities or Public Agents, or intervening 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. In this way, all persons covered by this Policy must be aware that none of their acts may generate liability based on current legislation.

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.), with the aim of enabling them to carry out official acts more quickly or more beneficial to Skyone will violate current legislation. There will be no need to deliver the promised or offered benefit, whether due to refusal or not by the Public Agent himself, for the infraction in question to be established.

sensitive interactions

The interaction of Skyone Employees and Third Parties, especially those who carry out government relations activities, with public agents or politicians must always be guided by the guidelines of this Manual and other Skyone policies. Interactions between Employees or Third Parties and public agents, in the performance of their activities that they provide to Skyone, must be recorded and reported to Skyone's Executive Board and Compliance Officer.

Code Violations

Any violations of this Conduct Manual by Skyone Employees and Third Parties must be reported to the Conduct Committee, through the People Management area or Reporting Channel (, which will carry out the first evaluation of the statement.

Collaborators and Third Parties who commit the violations mentioned in this Conduct Manual may be subject to:

  • Warnings;
  • Resignation;
  • Contract termination;

In addition to the sanctions provided for in this Manual, in the event that the infractions mentioned in this Conduct Manual constitute a crime, Skyone will notify the
competent authorities and adopt the appropriate administrative or judicial measures.

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.

São Paulo, May 23, 2022.

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