Skyone Code of Conduct

Skyone Code of Conduct.

Hello! This Code of Conduct reflects the ethical and behavioral standards that guide every Skyowner and everyone who interacts with Skyone. Use the side menu to navigate the document.

Message from the Board of Directors

The longevity of our business depends directly on how each Skyowner acts inside and outside the company, and is based on the values ​​and standards of integrity adopted at Skyone. Ethics is not bureaucracy. It's what allows us to grow rapidly without losing the trust of everyone who interacts with us.

The cloud that securely scales AI is not just a market positioning: it's a commitment to ethical principles that we renew every day in every decision, every line of business, every interaction with our customers, employees, partners, suppliers, and third parties.

Therefore, this Code of Conduct reflects who we are today and who we want to be tomorrow!

"The ultimate success of our dealings with everyone and everything depends not only on what we do, but on how we do it."

Field of Application

Hello! This Code of Conduct reflects the ethical and behavioral standards that guide every Skyowner and everyone who interacts with Skyone.

He embodies our values: trust, collaboration, a sense of prioritization, a nonconformist attitude, and tireless dedication to achieving our mission of positively impacting the productivity of 1 million people by 2028, simplifying reality to deliver the Cloud that scales AI securely.

Who We Are and Why We Exist

Purpose and Mission

Simplify reality. Impact tomorrow.

We work with what is invisible, yet essential to moving the world forward. With the integrating power of technology in our hands, we simplify today to impact tomorrow, evolving businesses, solidifying careers, and building a more prosperous society. And we do it the right way.

Vision

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

Every hour saved is a barrier broken down. Every business that scales is a step towards a more productive future for everyone. With responsibility at every step.

Positioning

Skyone is the cloud that securely scales AI.

We operate at the intersection of cloud computing, data, artificial intelligence, and cybersecurity, delivering technology that truly works, with the reliability our clients and partners deserve. Technical security and ethics: the two go hand in hand here.

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. Because trust is built on consistency, not convenience.

Collaboration

We work to delight and simplify the daily lives of our clients and partners. We contribute constructively to achieving shared goals. Effective collaboration requires mutual respect as its foundation.

Sense of Prioritization

We are decisive and assess the impact of our priorities. We are agile in decision-making. And without compromising quality and integrity.

Nonconformity

We are nonconformists. We challenge ourselves to always do better. And ethically.

Tireless

We overcome challenges to deliver what matters: impactful results. And we remain equally tireless in our principles.

To Whom Does This Code Apply?

This Code applies to all Skyowners (regardless of position) and serves as a guide to principles and best practices in relationships with business partners, suppliers, franchisees, and third parties to promote a transparent, ethical, and mutually respectful professional environment, regardless of location, language, or mode of interaction (in-person, remote, or hybrid).

Essential Terms and Definitions

Public Official: Any person who performs a public function, whether temporary or permanent, paid or unpaid.

Senior Management: Executive leaders, shareholders, board members, and directors of Skyone.

Workplace Harassment: Repeated or systematic abusive behaviors that cause harm to someone's personality, dignity, or physical or psychological integrity due to a work relationship, including virtual environments such as email, messaging, video conferencing, and social media.

Sexual Harassment: Behaviors of a sexual nature, expressed physically, verbally, through gestures, or by digital means, imposed on someone against their will, violating their sexual freedom, regardless of the position, hierarchy, or environment in which they occur.

Collaborator(s): All Skyone employees with permanent contracts, temporary contracts, interns, and apprentices.

Corruption: Abuse of power or position to obtain personal benefits or undue advantages.

DEI (Diversity, Equity and Inclusion): Principles that guide Skyone's policies and practices in recognizing and valuing differences, promoting representation, equal opportunities and a work environment free from any form of prejudice or exclusion.

Family and Relatives: Spouse, partner in a stable union, parents, children, siblings, relatives by affinity or adoption, as well as people with whom the employee maintains a publicly known affective relationship and who may influence or be influenced by their professional decisions.

GRC (Governance, Risk and Compliance): The area responsible for ensuring that Skyone operates with integrity, within the rules and with the right controls, protecting the company, the people who are part of it and those who trust us.

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

Anti-Corruption Law: Federal Law No. 12.846/2013, which deals with the administrative and civil liability of companies for acts of corruption against the public administration.

Skyowner: This is what we call every person who is part of Skyone, including executive leaders, Directors, employees, interns, and apprentices. The term is part of our culture, where everyone is responsible for the impact of their actions, and it does not change the nature of each person's professional and employment relationship with Skyone.

Operational Guidelines

Legal and Regulatory Compliance

Skyone operates in full compliance with the laws and regulations of Brazil and the countries where it operates. This includes labor, tax, data protection, anti-corruption, competition, and specific technology sector regulations.

If you identify any situation that violates our internal rules or current legislation, please report it immediately through the Ethics Channel: https://skyone.denuncia.pro.

Data Protection and Privacy

Data is a critical strategic asset, and protecting it is everyone's responsibility. Skyone operates under the principles of the LGPD (Brazilian General Data Protection Law) and international best privacy practices, including the GDPR (General Data Protection Regulation) for operations with European reach.

Every Skyowner must:

• Protecting personal and corporate data against unauthorized access, alteration, destruction, or disclosure.
• Do not share data with people without proper authorization.
• Use Skyone's resources and systems exclusively for legitimate operational purposes.
• To ensure that systems and information are protected in accordance with Information Security standards.
• Store documents in official repositories approved by Skyone, including certified cloud services.
• Immediately report any incident or suspected data breach to the Information Security and GRC departments.
• Respect data protection guidelines in remote work environments.

Cybersecurity

Cybersecurity is part of Skyone's DNA. In a context of exponential growth in digital threats, every Skyowner is a line of defense. This means:

• Never share passwords, credentials, or system access information.
• Use multi-factor authentication (MFA) whenever available.
• Immediately report any suspicious emails, links, or requests that may be phishing or social engineering attempts.
• Do not install unapproved software on company devices.
• Apply the principle of least privilege: access only what is necessary for your role.
• Follow the policies for classifying and handling sensitive data, including customer data, partner data, and intellectual property.

Company Assets and Property

Each Skyowner is responsible for the company's assets and property, including physical and digital assets, clients, and partners. This includes equipment, software, intellectual property, data, and cloud infrastructure.

• Use Skyone's resources exclusively for authorized professional purposes.
• In case of loss, theft, or misuse, immediately notify your manager and follow internal procedures.
• In case of termination, return all equipment and any items provided by Skyone within the stipulated timeframe and in good condition.
• Inventions, discoveries, and improvements made during the work period belong to Skyone.

Work Environment

Our Culture

Skyone believes that safe, inclusive, and psychologically healthy work environments generate the best results. Every Skyowner has the right and responsibility to contribute to a culture of respect, openness, and mutual growth.

Regardless of position, location, or type of work, we treat all people with courtesy, respect, and dignity. Period.

Expected Behaviors

• Acting with objectivity and clarity strengthens respect and trust in relationships.
• To encourage teamwork focused on achieving the best results for Skyone and its clients and partners.
• Respect the authorship, merit, and contributions of all.
• Be transparent and disclose any conflict of interest.
• Practice open dialogue and listen respectfully to other perspectives.
• Prioritize collective well-being in day-to-day decisions.

Unacceptable Behaviors

• Any form of discrimination: based on race, color, gender, sexual orientation, religion, origin, social class, age, physical or mental condition, marital status, or occupation.
• Moral or sexual harassment, whether in person or in digital environments.
• Use of company resources for unauthorized personal purposes.
• Engaging in personal activities during work hours in a way that jeopardizes deliverables.
• Unethical or illegal behavior, or behavior that violates this Code.
• Consuming alcohol beyond reasonable limits at Skyone social events, or using any illicit substances on Skyone premises or during professional activities.
• Carrying weapons on company premises is prohibited, except when required by the job.
• Sharing credentials or system access with unauthorized third parties.
• Filming, photographing, or recording on Skyone premises in a way that compromises its image.

Moral and Sexual Harassment

Skyone has zero tolerance for any form of harassment. We strictly follow Law 14.457/2022, which addresses the fight against sexual harassment and other forms of violence in the workplace.

Harassment, whether moral or sexual, can result in immediate disciplinary measures, including dismissal for cause, as well as civil and criminal liability.

Any such situation should be reported immediately through the Ethics Channel (https://skyone.denuncia.pro), with complete confidentiality guaranteed.

Diversity, Equity and Inclusion

Skyone values ​​diversity. We believe that diverse teams make better decisions, innovate more, and build more inclusive products. Our culture of inclusiveness is not a one-off initiative: it's an everyday practice.

Our commitments:

• To recruit, promote, and reward based on merit, ensuring equal opportunities.
• To assemble teams that reflect the diversity of our country and the world.
• To make decisions free from bias or personal preferences.
• Respect religious beliefs and political opinions, without using company spaces for proselytizing.
• Report any discriminatory behavior you witness through the Ethics Channel.
• To create an environment where everyone feels like they belong and are safe to be themselves.

Romantic Relationships

Skyone respects the personal life of each Skyowner. Romantic relationships between employees are permitted, but should not interfere with professional conduct, business decisions, or the work environment. If a relationship develops into a union (formal, informal, or stable), those involved must inform their respective managers so that the necessary adjustments to internal regulations can be made.

Health and Safety

All Skyowners are entitled to a safe and healthy work environment, both physically and psychologically. Mental health is just as important as physical health, especially in a high-performance environment.

Expected behaviors:

• Follow Skyone's health and safety rules and procedures.
• Refuse activities that pose a risk to your own safety or that of your colleagues.
• Report any unsafe conditions, accidents, or work-related illnesses to the Human Resources department.
• Only engage in activities for which you are qualified, authorized, and in good physical and mental condition.
• Comply with the requirements for periodic occupational health examinations.

Clothing and Presentation

Skyowners represent the image of Skyone. The dress code and personal presentation guidelines follow the Human Resources department's directives, consistent with the company's values ​​and culture.

External Relationships

Customers

Our customers are the reason we exist. Our relationship with them must be based on honesty, efficiency, and a genuine commitment to their needs.

What we expect from every Skyowner:

• Treat customers with respect, courtesy, and efficiency.
• To provide accurate, clear, and transparent information, never incorrect or misleading.
• To fulfill all agreements, while preserving Skyone's credibility and image.
• Never neglect customer service, regardless of the client's size or value.
• Never use illicit means, payments, undue benefits, or any form of bribery to gain or retain clients.

Suppliers and Business Partners

Skyone chooses partners who share its values. We expect the same level of integrity from our suppliers that we demand from ourselves.

What we expect from every Skyowner:

• Treat suppliers with respect and honesty.
• Hire only partners who do not exploit child labor, forced labor, or any form of human rights violation.
• Do not accept services or materials outside the scope of the signed contracts, even if they seem advantageous.
• To protect the technical, commercial, financial, and strategic information shared in partnerships.
• Avoid maintaining relationships with suppliers that create undeclared conflicts of interest.
• Do not do business with partners who violate this Code of Conduct.

Competitors

Skyone believes in healthy competition and a free market. We compete based on innovation, quality, and delivered value.

• Never speak incorrectly, misleadingly, or defamatoryly about competitors.
• Obtain market information only through legal and ethical means.
• Respect the intellectual property and confidential information of other companies.
• Report any situation that may constitute anti-competitive practice to the Ethics Hotline.

Press and Corporate Communication

Skyone's external communication is the responsibility of the Marketing department, with support from GRC where applicable. Only authorized individuals may speak on behalf of the company to the press or in public forums.

• Do not make public commitments on behalf of Skyone without authorization.
• Do not disclose privileged information, even after your relationship with Skyone has ended.
• Accounting records must comply with all tax laws and regulations, under the responsibility of the Controllership area.

Trade Unions and Labor Representation

Skyone recognizes unions and representative entities as legitimate interlocutors in labor relations. We value ongoing dialogue and freedom of association.

Anti-corruption and Integrity

Skyone has zero tolerance for corruption in any form, whether passive, active, direct, or indirect.

All Skyone business dealings are conducted within the bounds of legality and ethical principles. We strictly adhere to the Anti-Corruption Law (Law 12.846/2013) and adopt international standards such as the FCPA (USA) and the UK Bribery Act for our global operations.

Good Anti-Corruption Practices

• Do not offer, promise, or grant undue payments, gifts, or advantages to public or private officials.
• In meetings with public officials, attend accompanied by at least one Skyone colleague and do not incur any expenses during these meetings.
• To transparently record all relevant interactions with the public sector.
• Report any suspicious request or situation immediately to the GRC or Legal department.
• Include anti-corruption clauses in all relevant contracts.

Invitations, Gifts and Courtesies

Accepting gifts or courtesies is permitted only when:

• The amount cannot exceed half of the current minimum wage.
• The gift should have the giver's identification on it.
• Not to influence any business decisions.
• Respect the minimum interval of 12 months since the last gift received from the same source.

Donations, Sponsorships and Charity

Any donation, sponsorship, or act of charity on behalf of Skyone requires prior approval from the relevant departments to ensure integrity, alignment of values, and absence of conflicts of interest, and must comply with due diligence procedures and authority limits defined in the respective internal policies.

Conflict of interest

Conflict situations arise when the personal interests of a Skyowner interfere, or appear to interfere, with the interests of Skyone or its stakeholders. Transparency is our main management tool. In case of doubt, a suspicious situation, or identification of a real or potential conflict, the way forward is transparency: immediately inform the GRC team so that we can clarify and mitigate risks efficiently. Here are some examples:

Situations that require immediate declaration

• Direct family member working for Skyone's clients, suppliers, or competitors.
• Significant financial stake in companies with which Skyone has or may have a business relationship.
• A second job or self-employment that may conflict with activities at Skyone.
• Any situation in which personal interests may influence professional decisions.

The hiring of relatives requires prior and formal authorization from the Compliance Department and the Human Resources area, after analysis of the hierarchical structure, activities performed, and direct interactions between the areas.

General Limitations

The following situations are prohibited, regardless of authorization:

• Filming, photographing, or recording inside Skyone in a way that compromises its image in the market.
• Circulating raffles, petitions, distributing invitations, or conducting any type of commerce on Skyone premises is prohibited.
• Using the Skyone name or brand for personal activities or benefits.
• Conducting political campaigns or posting materials of any kind without authorization.
• To share professional knowledge and confidential information acquired at Skyone.
• Promoting external conferences or publishing articles about Skyone without authorization.

Social Networks and Digital Communication

In the digital world, every Skyowner is a brand ambassador, consciously or not. By linking your professional profile to Skyone (especially on LinkedIn), you become part of our public image.

Guidelines

• Maintain a posture aligned with Skyone's values ​​across all digital platforms.
• Do not make any commitments on behalf of Skyone without authorization.
• Do not criticize colleagues or the company on public channels; use internal channels or the Ethics Hotline.
• Do not share content that contains defamation, slander, discrimination, or intolerance.
• When accepting connections that present themselves as Skyowners, verify their authenticity to avoid fraud.
• Misuse of the Skyone brand in embarrassing situations may result in disciplinary action.

Corporate Email and Digital Tools

Skyone's corporate email and digital tools are work resources. Moderate personal use is tolerated, provided the content does not include material related to competitors, personal promotions, paid side activities, or any inappropriate content.

Social and Environmental Commitment and ESG

Skyone understands that technology and social and environmental responsibility go hand in hand. The cloud that scales AI securely also needs to scale sustainably.

Our ESG commitments include:

• Continuously reduce the consumption of electricity, water, plastics, and disposable materials.
• Encourage recycling and circular economy practices.
• Operating with energy-efficient cloud infrastructure.
• To develop and operate projects while minimizing environmental impacts.
• To contribute to a more just, inclusive, and egalitarian society, beyond our own walls.

Ethics and Whistleblowing Channel

Skyone's Ethics Hotline is the primary mechanism for reporting violations, ethical questions, and suspicious situations. All reports are handled confidentially and seriously by the Ethics Committee.

How it works:

• Any Skyowner, partner, or third party may report situations that violate this Code.
• The whistleblower's anonymity is protected — there will be no retaliation for reports made in good faith.
• The complaints are reviewed by Skyone's Ethics Committee.
• The Ethics Committee determines the appropriate measures for each case.

What should be reported:

• Violations of this Code of Conduct or Skyone's internal policies.
• Suspicions of corruption, fraud, or unethical behavior.
• Cases of workplace harassment or sexual harassment.
• Situations of discrimination or violation of rights.
• Information security incidents or data breaches.
• Any conduct that jeopardizes the integrity of Skyone or its stakeholders.

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

Handling Nonconformities and Penalties

Failure to comply with this Code or Skyone's internal policies will have consequences proportionate to the seriousness of the situation and applicable law.

Disciplinary measures include:

• Formal warning
• Suspension
• Dismissal for just cause — including for serious cases without the need for recurrence
• Civil and/or criminal liability, in accordance with current legislation

Skyone can take immediate action when the seriousness of the situation demands it, without needing to wait for recurrences.

Duties and Responsibilities

Senior Management

Lead by example. Promote, follow, and highlight the values ​​and behaviors of this Code in all decisions and interactions.

Leaders

Disseminate, model, and ensure that everyone on your teams knows and follows this Code. Ethical leadership starts at the top.

All Skyowners

To know, follow, and be an active agent in disseminating this Code. Upon joining Skyone, each employee signs the Code of Conduct Commitment Agreement.

Validity and Revision

This Code of Conduct comes into effect upon its publication on Skyone's official communication channels and will be periodically reviewed to reflect best market practices, regulatory changes, and Skyone's own evolution.

Conclusion

This Code is a set of principles to unleash the best in every Skyowner. Ethics, integrity, and trust are what allow us to grow rapidly, scale safely, and impact the lives of 1 million people by 2028. Every decision counts. Every action matters. Tomorrow starts now.

"The cloud that scales AI securely, ethically, always."

Doubts?

Contact the Governance, Risk and Compliance (GRC) area; we are here to guide you, not to judge you.

Review Participants

Renata Miziés de Barros

Legal and Compliance Director

Change and Approval History

Version	Date	Change	Responsible
1.9	27/11/2018	Finalization of the Initial Version	Lauro de Lauro
2.0	03/12/2018	Final Review for Release	Lauro de Lauro
2.1	20/03/2019	Final Version	Aila Braga
3.0	23/05/2022	Final Version	Lauro de Lauro
3.1	22/03/2024	Full review	Renata Miziés de Barros
4.0	27/03/2026	Full review	Renata Miziés de Barros