CODE OF ETHICS AND CONDUCT 

DEAR MEMBERS, 

This Code of Ethics and Conduct aims to inform you about expected conduct, values, duties and sanctions.

It is everyone’s responsibility to understand the policies and procedures we present here. This document should serve as a constant reference to guide individual and collective actions and decisions in our relationships with our employees, service providers, customers, and the general public.

Reading and adhering to the Code of Conduct is mandatory. Furthermore, it’s also an opportunity to learn more about our guidelines.

1) The actions that TM Tecnologia, Consultoria e Sistemas Ltda. ‘s management takes to manage its business are absolutely transparent with our employees, service providers, customers, and the general public and must be observed in its internal and external actions. These are:

1.1 – Ethics : Be honest and transparent with all stakeholders.

1.2 – Respect : Diversity is our wealth.

1.3 – Relationship: Be cordial, respectful and inclusive.

1.4 – Commitment: Seek excellence in all stages of work, trying to do more and better with fewer resources and procedures, seeking partnership and collaboration with all sectors of the company.

1.5 – Continuous improvement: Promote internal and external learning and disseminate knowledge.

1.6 – Communication: Be clear, objective, respectful with all employees

1.7 – Valuing members: Encouraging professional growth based on individual merit.

1.8 – Social Responsibility: Conduct the company sustainably and aim for ethical profit in order to guarantee the company’s longevity.

1.9 – Environmental Responsibility: Reduce consumption at all stages and prioritize the use of recycled materials.

2) PROTECTION OF CONFIDENTIAL DATA AND INFORMATION. 

2.1 – Information Security : Ensure the confidentiality and security of information obtained as a result of work, whether in the internal or external environment, of clients and partners and share information only with duly authorized people.

2.2 – Sharing personal passwords to access company or third-party devices is strictly prohibited. Confidentiality must be maintained even after the services provided to TM Tecnologia, Consultoria e Sistemas Ltda. have ended.

2.3 – Our designs, know-how, trade secrets, copyrights, and confidential business-related information are valuable company assets. Therefore, we are committed to keeping them confidential and protecting them from loss, theft, or other misuse.

3) OF WORK ENVIRONMENT. 

3.1 – TM Tecnologia, Consultoria e Sistemas Ltda. strives to provide a safe, healthy, respectful work environment with minimal impact on the environment.

3.2 – Personal Safety: Prioritize people’s safety and properly use the PPE provided.

3.3 – Maintenance: Must be carried out by trained members using PPE when necessary.

3.4 – Relationship : Maintain a cordial, transparent and respectful relationship with everyone.

3.5 – Training and supervision: The Hierarchical Superior must train his/her team, demand excellence in the execution of tasks and punish acts of insubordination, indiscipline, negligence, or violation of the Code of Ethics and Conduct.

3.6 – Sexual and Moral Harassment: Sexual and/or moral harassment, whether vertical or horizontal, is strictly prohibited. If a member is a victim of or is aware of harassment, they may report it by email at encarregadodedados@tminformatica.com.br or through the reporting channel on our Website.

3.7 – Discrimination at work: Members must be careful not to allow discrimination in employment , child labor, forced labor or labor in degrading conditions, even if it involves business partners, and must inform their Line Manager or use the reporting channel via email encarregadodedados@tminformatica.com.br or the reporting channel on our Website.

3.8 – In cases of reporting, it is essential that it is done in good faith and we guarantee anonymity.

3.9 – Recreation and rest room: The company provides a recreation and rest room that must be used with common sense, moderation, respect and without causing delays in services.

3.10 – Conflict of Interest: The personal interests of members must not interfere with or override the interests of TM Tecnologia, Consultoria e Sistemas Ltda., even if such conflicts do not directly involve them, but rather their family members or close associates. If a direct or indirect conflict is unavoidable, you must immediately notify your supervisor.

3.11 – Equipment: Care for, maintain and preserve the company’s furniture, tools and equipment so that they reach their useful life.

3.12 – Consumable Items: Do not leave lights on or faucets running. In case of a problem, report it to the maintenance team. Do not print unnecessary documents and prioritize the use of disposable materials and utensils.

3.13 – Working Hours : Correctly record working hours on the time clock and, when working externally, via the app. Working overtime without prior authorization from your supervisor is prohibited.

3.14 – External Services: Complete Service Orders accurately, including the start and end times of the work, and obtain the customer’s signature. Treat customers courteously and respectfully.

3.15 – Contracts: Members must be aware of the contracts or projects they are working on and must not make commercial, technical, financial commitments or deadlines without the knowledge of their Hierarchical Superior. Any changes must be formalized and communicated to those involved.

4) THE FOLLOWING CONDUCT BY MEMBERS OF TM Tecnologia, Consultoria e Sistemas Ltda. WILL NOT BE TOLERATED. 

4.1 – Any type of discrimination based on race, sexual orientation, philosophical, partisan, religious, ethnic, physical characteristics, age, disability or illness.

4.2 – Any type of moral or sexual harassment, offenses, humiliation, coercion, threats or creation of an environment hostile to work performance.

4.3 – Perform work outside the scope of the activity during working hours, including overtime.

4.4 – Arriving late for work or missing work without justification. Medical certificates must contain the ICD (International Classification of Diseases).

4.5 – Carry out activities, work, consultancy, provide free or paid information to any competitor, business partner, client or supplier without prior approval from the hierarchical superior and endorsed in writing by the Legal Department.

4.6 – Receiving gifts, freebies, courtesies, or facilities that may interfere with the evaluation process or that may result in the employee feeling compelled to reciprocate. Gifts, courtesies, or facilities worth up to R$50.00 will be tolerated, provided they are immediately reported to the Supervisor.

4.7 – Request gifts, freebies, courtesies, facilities for yourself or third parties, conduct business for your own benefit or for people you have a relationship with on behalf of TM Tecnologia, Consultoria e Sistemas Ltda. 

4.8 – Offering customers, suppliers, service providers or potential customers, service providers or people related to them, benefits, gifts, advantages or compensation that are contrary to this Code of Ethics and Conduct or contrary to the law.

4.9 – Promising, offering or giving, directly or indirectly, undue advantage to a public or private agent or third parties related to them.

4.10 – Use the activities carried out at TM Tecnologia , Consultoria e Sistemas Ltda to appropriate for yourself or people in your relationship business benefits, advantages, facilities or opportunities without the authorization of your Hierarchical Superior and endorsed in writing by the Legal Department.

 4.11 – Demonstrably facilitating, financing, funding, sponsoring or in any way subsidizing the practice of illegal acts of any nature, whether in relation to a public or private agent or third parties related to them.

4.12 – Prevent, disrupt or defraud the performance of any public bidding process, frustrate or defraud through adjustment, combination or any other expedient, the competitive nature of a public bidding process.

4.13 – Fraud in a public tender or contract arising therefrom.

4.14 – Dismiss or attempt to dissuade a bidder through fraud or offering advantages of any kind.

5) VIOLATIONS. 

5.1 – TM Tecnologia , Consultoria e Sistemas Ltda. expects all members to comply with the established rules in all circumstances.

5.2 – Any member who violates the vision, mission, values or policy or who allows a subordinate to do so will be subject to disciplinary action and may even be dismissed for cause.

5.3 – Any member who becomes aware of any violation must immediately notify their Line Manager, the Legal Department or use the reporting channel.

6) GENERAL PROVISIONS. 

6.1- No member may claim ignorance of the vision, mission and values or the standards established in this Code of Ethics and Conduct.

6.2 – Everyone must be committed to strictly complying with this Code of Ethics and Conduct and, to achieve this goal, it is necessary to read it carefully and, in case of doubts or suggestions, you must contact the Legal Department by email at encarregadodedados@tminformatica.com.br.

6.3 – This Code of Ethics and Conduct may be updated, in which case it will be widely publicized.

This second version of the Code of Ethics and Conduct comes into force on November 8, 2024.