Skyone Code of Conduct

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

Message from the Board of Directors

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

In this regard, Skyone expects and believes that all its employees, business partners, suppliers, and third parties will conduct themselves in accordance with the highest standards of personal and professional integrity.

This Code of Conduct has the primary objective of contributing to the building of a healthy, dignified and harmonious business environment, through a high level of trust, respect and transparency in interactions in any area of ​​operation, promoting Skyone's unique vision that the ultimate success of our dealings with everything and everyone depends not only on what we do, but mainly on how we do it.

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.

Since we deal with many different people and companies every day, it's difficult to predict every situation that might arise. Therefore, this document presents principles and best practices to promote a transparent, ethical, and mutually respectful environment.

Terms and Definitions

Public Official: Any person who performs a public function, whether temporary or permanent, paid or unpaid, by election, appointment, designation, or any other type of investiture or link with the public service.

Senior Management: These are the leaders of Skyone, including executives, shareholders, advisors, and directors.

Workplace harassment: These are abusive behaviors that can cause harm to a person's personality, dignity, or physical or psychological integrity, threaten their job, or damage 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.

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

Corruption: Abuse of power to obtain personal benefits.

Family members: People who are part of the employee's family, including spouse (husband or wife), brothers or sisters, parents, relatives by marriage, children, partner or companion.

LGPD (General Data Protection Law): Law No. 13.709/2018 that establishes guidelines for the protection of personal data.

Anti-Corruption Law (Law 12.846/2013): Federal law that addresses the administrative and civil liability of companies for acts of corruption against the public administration.

Skyone's target audience: Customers, business partners, suppliers (service providers), and third parties.

Relatives: A person connected to another by the same blood tie, affinity, or adoption.

Purpose, Mission and Values

Our Purpose and Mission

Simplify reality. Impact tomorrow.

We work with what is invisible, yet essential to moving the world forward. And, if it depends on us, not even the sky is the limit for this movement, because we are already there. Skyone breathes innovation to deliver much more than just productivity.

With the integrating power of technology in our hands, we simplify today to impact tomorrow. In 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 peace of mind for our clients and partners: that's how we earn their trust.

Our Vision

To positively impact the productivity of 1 million people by 2028.

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

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

Our Values

Trust

We build relationships of trust. We consider the impact of our words and actions. We care about the beginning, middle, and end of everything we do.

Expected Behaviors:

• We treat people the way they would like to be treated.
• Everyone can trust that we are doing our part for the safety of everyone, our business, and our customers.
• Everyone can trust that we are committed to the sustainability and long-term viability of the business.

Collaboration

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

Expected Behaviors:

• We understand the realities of each area of ​​the company and contribute to ensuring that everyone achieves the best possible results.
• We show openness to doing things in different ways and we see multiple perspectives.
• We understand the other departments, including their services, results, and goals, and we 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 equal society, beyond our own walls.

Sense of Prioritization

We are decisive and assess the impact of our priorities. We are agile in our decision-making.

Expected Behaviors:

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

Nonconformity

We are restless. We challenge ourselves to always do better.

Expected Behaviors:

• We practice "finishing," nothing stays unfinished in our hands. We deliver what we commit to with combined excellence. We adapt methods to achieve solutions and results in dynamic situations.
• We have identified areas for improvement in all situations.
• We are constantly developing ourselves to become better professionals.
• We share our learnings and best practices, contributing to everyone's development.

Tireless

We overcome the challenges to deliver what matters: impactful results.

Expected Behaviors:

• We are tireless in our pursuit of customer and partner satisfaction: we seek to improve and develop new ways to surprise them.

Guidelines

Legislation, Regulations and Internal Norms

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 anything that violates these rules, it is important to report it to the Ethics Hotline.

Data and Information Protection

All employees have a responsibility to protect company information.

To help you with this task, 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 assets, such as computers, data, copyrights, and other information. To do this, we must follow the rules of the Information Security Policy and Standards, which are based on industry best practices.

It is very important to keep information confidential, ensure that it is not altered without authorization, and that it is always available when needed. Failure to do so constitutes a violation of 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 handle daily. Here are some important tips:

• Protect data against unauthorized access, alteration, destruction, or disclosure.
• Do not share personal data with unauthorized individuals.
• Use the resources that Skyone makes available to you only for operational purposes.
• Ensure that the systems, data, and information you manage are accessible and protected in accordance with security standards.
• Ensure the continuity of processing data essential to the business.
• Keep the resources provided to you in good working order, operating according to specifications.
• Follow Skyone's guidelines on where to store documents and information, especially in cloud storage services.
• Respect Skyone's guidelines and Code of Conduct to maintain information security while working remotely, avoiding the exposure of confidential information or personal data.
• Immediately report any questions or incidents to Skyone's Information Security and Governance, Risk and Compliance areas, in accordance with the Information Security Policy.

Assets and Property

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

Misappropriation/misuse

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

Communication in case of loss, theft or misuse

If you notice or become aware of any loss, theft, or misuse of these items, you must immediately notify your manager and follow the established internal procedures for such cases. Upon termination of employment, you must return the cell phones, laptops, and other items provided by Skyone within the stipulated timeframe and in good condition.

Work Environment

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 the behavior of each individual does not harm the image or assets of Skyone.

Regardless of position, we expect everyone to be treated with courtesy and respect. We do not tolerate any type of discrimination, intimidation, or harassment, 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.
• Performing personal tasks during work hours.
• Unethical or illegal conduct.
• Violation of external laws and regulations.
• Hiring relatives without formal authorization from the Board of Directors and Human Resources department, or influencing their hiring without the knowledge of the person responsible for recruitment.
• Using company resources for personal purposes.
• Accepting corrupt practices (bribes, kickbacks, influence peddling for undue favors) and other illegal behaviors.
• Prioritization of personal interests or a specific area over those of Skyone.
• Consuming alcohol or illicit drugs on Skyone premises is prohibited. WARNING: Moderate alcohol consumption is permitted at Skyone social events, provided it does not affect behavior or violate the Code of Conduct during or outside of work hours.
• Carrying weapons inside Skyone is prohibited, except if required by your position.
• Share passwords and usernames for Skyone systems.

Expected Behaviors

• Acting with objectivity and clarity strengthens respect and trust in relationships.
• To encourage teamwork and focus on achieving the best results for Skyone.
• Respect the authorship and merit of all activities, ideas, and completed works.
• Being transparent in relationships and communicating any type of conflict of interest.
• Practice open dialogue and listen respectfully to other opinions.

Romantic Relationships

At Skyone, it's important that employees behave in a way that is compatible with the work environment, ensuring the smooth running of activities.

Therefore, we have established that no romantic relationship between employees should compromise their professional conduct.

Moral and Sexual Harassment

At Skyone, we do not tolerate 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 complies with Law 14.457/2022, which combats sexual harassment and other forms of violence in the workplace.

Inclusive and diverse work environment

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

Our commitment is to create a welcoming and open-minded environment where everyone feels included.

Expected Behaviors:

• Respect the qualities, characteristics, and rights of all.
• Working together, accepting different ideas and having constructive conversations.
• To recruit, promote, and reward based on merit, providing equal opportunities for all.
• Promote diversity when building the team.
• Making decisions without prejudice or personal preferences.
• To create a work environment that reflects the appreciation of diversity.
• Report any discriminatory behavior you witness to the Ethics Hotline.
• Respect everyone's religious beliefs, as well as their right not to participate in religious demonstrations.
• Respect everyone's political opinions and refrain from engaging in political campaigning on Skyone 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 implement 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 perform tasks, putting one's own life and the lives of others at risk.
• To carry out activities or expose colleagues to situations that pose risks to their physical safety.
• Forcing colleagues to perform activities that jeopardize their health and safety due to the position they hold.

Expected Behaviors:

• Refuse to perform activities or participate in situations that pose risks to health and safety.
• Immediately report to the Human Resources department any situation that puts someone's safety at risk.
• Understand and follow legal requirements and internal health and safety standards.
• Perform activities only if you are qualified, authorized, have the appropriate tools, and are in good physical and mental condition.
• To contribute to a safe and healthy work environment, both physically and mentally.
• Comply with Skyone's rules regarding the completion of periodic occupational health examinations.
• Report any unsafe acts or conditions in the workplace, as well as work-related accidents and illnesses, to the Human Resources department.

Social and Environmental Commitment

At Skyone, we strive to minimize our impact on the environment.

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

Expected Behaviors:

• To develop and operate projects while minimizing impacts and avoiding environmental damage.
• To meet Skyone's goals for the sustainable consumption of resources such as water, electricity, and others.

Social media

Access

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

Improper disclosure

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 content disseminated by Skyone.

It is important to avoid sharing any posts that contain defamation, slander, libel, harassment, discrimination, or intolerant opinions of a political or religious nature, as this may harm your image and that of Skyone itself.

The misuse of the company's brand or name in embarrassing situations will subject offenders to disciplinary action or even dismissal.

On professional social networks, such as LinkedIn, by linking your profile to Skyone, you become a brand representative.

Therefore, when accepting connections that present themselves as Skyone collaborators, verify the authenticity of the information to avoid fraud.

Corporate Email

Corporate email is a work tool used primarily for exchanging professional messages.

You can use your work 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 offensive content.

Mobile devices

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

External Relationship

Customers

Our relationship with customers should be:

Unacceptable Behaviors:

• Disseminating and providing incorrect or inaccurate information.
• Neglecting to serve any customer, regardless of value or size.
• Using illicit means to acquire or retain clients, such as payments or any type of undue benefit, constitutes corruption, as it can be understood as bribery or kickbacks.

Expected Behaviors:

• We remain committed to ensuring customer satisfaction.
• Treat customers politely and efficiently, always providing accurate, clear, and transparent information.
• To fulfill the agreement with the client, 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 actions, such as bribery or illegal favors that could harm Skyone, its employees, or society, are strictly prohibited by both Skyone and the Anti-Corruption Law, which regulates these practices.

Unacceptable Behaviors:

• Having relationships with suppliers that could create conflicts of interest.
• To offer, promise, induce, or give undue gifts or advantages to influence decisions in favor of Skyone or for one's 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 included in the purchase documents (contracts, for example), even if they seem advantageous to Skyone.
• To protect the information used in our partnerships with suppliers and clients (technical, commercial, strategic, financial, registration information, among others), whether it is ours or that 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 honest competition, acting transparently and respecting all competition and antitrust laws. We follow the free enterprise system.

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

Press and Corporate Information

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

• Only the Marketing team is authorized to speak to the press on behalf of Skyone, either in writing or verbally.
• Each employee is responsible for protecting the information they possess. If anything seems strange or inconsistent with Skyone's values, it is important to immediately inform your manager.
• Accounting records must be prepared and monitored by those directly responsible, following all laws, tax regulations, and 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 leaving the company. Misuse of this information can result in serious labor and criminal consequences.

Trade unions

We recognize the category's union(s) and employers' unions as legitimate representatives of the parties involved in labor and union relations, respecting freedom of association and ongoing dialogue in building productive and harmonious labor relations.

Anti-corruption

Ethical principles: All Skyone business dealings must be conducted within the bounds of legality and corporate ethical principles. We do not tolerate any form of corruption, whether passive or active.

Transparency and Exemplary Conduct: Our relationship with external stakeholders, both from the public and private sectors, must be transparent and exemplary, preserving the reputation of Skyone and all those involved.

Offers and Payments: We do not authorize practices involving offering payments or benefits to government or private authorities to obtain commercial advantages. If you encounter such a situation, immediately inform the GRC or Legal department.

Legal Compliance: Although we follow Law 12.846/2013, which deals with acts of corruption within the public administration, we adopt practices to curb any corrupt behavior, regardless of the type of business.

Best Practices: We recommend that when holding meetings with public officials, you be 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 Updates: We are always up-to-date with the best market practices on this topic, including anti-corruption clauses in our contracts and dissemination of this Code, Policies and Standards through available internal channels.

Invitations, Giveaways, Gifts and Complimentary Items

At Skyone, we have clear guidelines regarding invitations, gifts, presents, and courtesies. If someone offers you a gift, you may only accept it if:

• The value of the gift must not exceed half the current minimum wage (small value).
• The gift must have the giver's mark (identification of the gift giver).
• It should not influence any business decision-making (anti-corruption).
• Respect a 12-month interval since the last gift/present 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 relevant authorities.

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

Clothing and Personal Presentation

The employees represent the image of Skyone.

Therefore, they must follow the guidelines of the Human Resources department regarding attire 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 their employment will be the property of Skyone and may not be used for personal purposes or transferred to third parties.

Employees must classify information according to Skyone's Information Classification Standard.

The leak of information could cause reputational and financial damage to Skyone, as well as 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, as well as harm third parties and partners. Therefore, they must be reported quickly to the relevant departments and handled with transparency and efficiency.

Family members

If a family member of yours works for Skyone's suppliers, clients, or competitors, or holds significant financial stakes in those companies, be aware of a potential conflict of interest.

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

It is essential to document this approval, should it be granted.

Limitations

Any external activity must be completely separate from work at Skyone, whether it's a second job or freelance work. We should not use Skyone work time or involve other employees in external activities without specific and clear authorization from the manager.

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

Prohibited situations, regardless of authorization:

• Filming or taking photos inside Skyone that could compromise its image in the market is prohibited.
• Entering Skyone with alcoholic beverages, a radio, entertainment material, and animals.
• Circulating raffles, lotteries, lists, petitions, distributing or selling invitations, tickets or similar items, or engaging in any type of commerce within Skyone is prohibited.
• Using the Skyone name for personal activities.
• Conducting political campaigns and/or posting notices about them within Skyone.
• Placing notices, invitations, posters of any kind inside Skyone.
• To share professional and confidential knowledge acquired at Skyone with other people.
• To promote external conferences, publish articles, or use other means of dissemination regarding matters related to Skyone.

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

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

Duties and Responsibilities

Senior Management

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

Leaders

Leaders have the responsibility to disseminate and ensure that everyone follows this Code of Conduct.

Collaborators

They must be familiar with and follow the rules of this Code of Conduct. To demonstrate this commitment, they must sign the Skyone Code of Conduct Commitment Agreement.

Handling 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, repeated non-compliance can result in dismissal for cause, based on insubordination.

It's important to know that Skyone can take immediate action, without waiting for repeat offenses to apply penalties, 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 reviewed by Skyone's Ethics Committee.

Validity

This Code of Conduct becomes effective from the day it is published in Skyone's media outlets and may be revised from time to time.

Final Considerations

If you have any questions, simply contact the Governance, Risk and Compliance Area by email:

Review Participants

Renata Miziés de Barros

Legal and Compliance Director – Finance

Approval and Change History

Complaints Portal

Confidential space for reporting misconduct. Access it via the link.

Written by devpeak