Code of ethics and conduct

Version and change control

Message from the Board

Sky.One , since its foundation, seeks 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 cherish and live by as Sky.One 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 depends 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 Sky.One and must guide the actions and attitudes of all employees, partners and third parties. This Manual was developed so that it bears 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

Sky.One is based on daily behaviors and principles strongly experienced since Sky.One
foundation. That is why we follow our Mission always based on our values.

Our mission:

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

Our values:

• Innovation
• Partnership
• Resilience
• SkyOwners

Innovation

We love to think differently!

BELIEFS:

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

BEHAVIORS:

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

Partnership

Together we go further!

BELIEFS:

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

BEHAVIORS:

• 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.

Resilience

We are better every day!

BELIEFS:

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

BEHAVIORS:

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

SkyOwners

Proud to be SkyOwner!

BELIEFS:

• Enjoy the journey, do it with pleasure

BEHAVIORS:

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

Our responsibility with the Conduct Manual

The Sky.One Conduct Manual applies to all employees, without exceptions, 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 Sky.One employee must ensure compliance with the Conduct Manual and inform their immediate superior, the People Management area or the Conduct Committee through the whistleblowing channel (https://denuncias.umaempresaetica.com.br/) when you become aware 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 what is proposed in the code, being an example and living the values ​​that Sky.One believes in its day-to-day;
• 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

Sky.One provides a Whistleblowing Channel, (made possible by the Uma Empresa Ética Program in partnership with ABES Associação Brasileira das Empresas de Software ) that allows the proper treatment of communications of identified irregularities in a secure and, if desired, anonymous manner:

https://denuncias.umaempresaetica.com.br/

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 Sky.One , which has the weight and effectiveness of the Code of Ethics;

III. Employee: all people who work at Sky.One , 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 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.

Desktop

At Sky.One 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 relevant facts about the organization to our internal public, strengthening our relationships and trust.

Human rights

In our internal and external relations with Sky.One , 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, is prohibited and condemned.

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. It is the right of Sky.One employees to have their work guided following the provisions of the Employment Contract signed upon admission to the company.

Equal Opportunity and Treatment

All actions and behaviors at Sky.One must be based on equal opportunities and treatment. Any decision made regarding Sky.One 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 Collaborators 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 are formalized in writing and contain an anti-corruption clause and explicit mention of this Conduct Manual.

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

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 an image for commercial purposes must be previously and formally authorized. All Sky.One employees are invited to sign, at the time of their admission, the Term of Authorization for the Use of Image and Voice.

Affective Relationship

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

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 Sky.One any manifestation of violence, whether physical, verbal, psychological or any other, is 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 allowed to carry out professional activities inherent to the position held or remain in Sky.One 's corporate environments in a state of drunkenness or under the influence of any type of illicit drug. The consumption of alcoholic beverages is allowed at social events related to Sky.One , provided that it is consumed in moderation and that it does not encourage behavior that violates the Conduct Manual and outside working hours.

Reimbursement of Corporate Expenses

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

Under no circumstances will Sky.One reimburse the personal expenses of its Collaborators 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.

Relationship with Suppliers and Customers

Activities and personal relationships that conflict with the interests of the company must be avoided. Third parties must also act and make decisions with Sky.One '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 the individual employment contract of each employee and after express authorization from the Conduct Committee, taking into account working hours, functions performed at Sky.One , security of corporate information and evaluated possible conflicts of interest.

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.

It is forbidden for members of Sky.One to offer or receive gifts or gifts, 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 Conduct Committee.

Responsibilities with information, assets and corporate image

Conduct in relation to the media and the press

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.

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 People Management area, as well as the Marketing area.

Conduct in relation to property and 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 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 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, according to the "Secrecy, Confidentiality and Copyright Policy ” signed by all employees upon admission to Sky.One .

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 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 in relation to the Company

Sky.One seeks to 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.

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 on behalf of Sky.One must be validated by the Conduct Committee in partnership with the Marketing, Legal and People Management areas in order to assess the background, mission and actions of the entities recipients, avoid conflicts of interest and benefit entities that are not in line with current legislation.

anti-corruption provisions

Sky.One Collaborators and Third Parties may not offer, promise, make, authorize or provide (directly or indirectly) any undue advantage, payments (including facilitation payments), gifts or the transfer of anything of value to anyone, 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, 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 entered into with Sky.One must contain an anti-corruption clause, referring to this Conduct Manual. Whenever possible, Sky.One Collaborators and Third Parties must be made aware of the sanctions that may arise from non-compliance with the aforementioned Laws, always emphasizing the provision of strict liability based on current legislation. In addition to the general principles already mentioned, all interactions between collaborators or Third Parties and Public Agents, on behalf of or for the benefit of Sky.One , 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.), in order for them to perform official acts more quickly or more beneficial to Sky.One will violate applicable law. 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.

sensitive interactions

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

Code Violations

Any violations of this Conduct Manual by Employees and Third Parties of Sky.One must be communicated to the Conduct Committee, through the People Management area or the Denouncement Channel (https://denuncias.umaempresaetica.com.br), which will carry out the first assessment of the release.

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, Sky.One Sky.One 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.