About T.O. Services
For 10 years, the Organization has combined experience in Business Solutions and Information Technology.
Our portfolio includes clients from various sectors such as Telecom, Oil & Gas, Finance, Transportation, Retail, Educational Institutions, among others.
We have our own Software Engineering and Intelligent Automation Unit and specialize in budgetary, financial, and Analytics projects.
Our processes ensure maturity and efficiency to apply best practices in the development and maintenance of our solutions. We invest in training to reinforce the quality of our team.
Our partnerships with global giants in the Information Technology (IT) sector ensure recognition in EPM solutions and in our Analytics project portfolio.
Therefore, we believe that respect and trust in employees, clients, and partners are our key differentiators. It is in human capital that the Organization makes its main investment.
Perseverance defines the history of T.O. Services.
Our mission
Provide business and IT solutions with quality and profitability.
Our purpose
Deliver technological and business solutions that transform our clients’ reality.
Our values
- Competence
- Commitment to results
- Respect
- Quality
- People development
- Trust
- Perseverance
- Overcoming limits
1. Objective
This Anti-Corruption Policy aims to align with laws that address the liability of legal entities for engaging in unlawful acts, fraud, and tampering against public and private administration, and prohibits violations against economic order. It is notably based on Laws No. 12.846/2013, No. 12.529/2011, No. 8.666/1993, and No. 8.429/1992, the United Nations Convention against Corruption (UN Convention), and the Inter-American Convention against Corruption (OAS Convention), all ratified by Brazil, among others.
Specifically, Law No. 12.846/2013, commonly known as the Anti-Corruption Law, was enacted to hold legal entities and their administrators administratively and civilly liable for acts of corruption and other offenses against public administration, whether domestic or foreign, establishing severe fines and administrative sanctions.
Accordingly, Article 1 of the aforementioned law states: “This Law provides for the strict administrative and civil liability of legal entities for acts committed against domestic or foreign public administration.” This is reinforced by Article 3, which establishes: “Legal liability does not exclude the individual liability of directors, officers, or any natural person who is the author, co-author, or participant in the unlawful act.”
To ensure compliance with applicable laws, the Organization has developed this Anti-Corruption Policy to promote adherence to anti-corruption laws and the guidelines set forth herein by all employees, managers, and directors.
The Organization is committed to combating unlawful, fraudulent, corrupt, and tampering practices against public administration, as well as preventing violations against economic order. It also seeks to adopt standards of integrity, legality, and transparency in its actions and relationships with partners, managers, and directors.
It is important to note that this policy establishes the guidelines to be followed by all members of the Organization regarding ethical, honest, and corruption-free conduct. Reading, understanding, and complying with this policy is mandatory for all employees, managers, and directors at all levels of the Organization, under penalty of the sanctions provided by the laws that serve as the foundation for this document. Oversight of this policy is the responsibility of the Compliance Committee.
2. Scope of Application
This policy applies to employees, managers, and directors, whether individuals or legal entities, with or without profit motives, including but not limited to associations, suppliers, subcontractors, customs brokers, consultants, service providers, among others.
Compliance with this policy is essential to maintaining the reputation of the Organization’s business and operations. Therefore, there is zero tolerance for bribery and other acts of corruption.
The Organization expects everyone to be fully aware of the seriousness of non-compliance with this policy and to be committed to the topic, as it is vital to the success of our business.
Reports and complaints may be submitted to the Compliance Committee via email at comite_compliance@to-brasil.com or through the Complaints Channel available at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx
3. Guidelines
The following guidelines must guide the Anti-Corruption Policy:
- Lack of respect implies a lack of commitment to the Organization, impacting the direction of its growth and the sustainability of its culture.
- Failure to recognize that misconduct—whether by action, omission, or complacency—harms society, violates laws, and damages the image and reputation of our Organization.
- Do not promise, offer, or give, directly or indirectly, any undue advantage to a public official or third party.
- Do not finance, sponsor, or engage in unlawful acts as outlined in this policy.
- Do not use intermediaries—individuals or legal entities—to conceal or disguise real interests or the identity of beneficiaries of the acts committed.
- Do not incorporate or obtain any undue financial advantage or seek illicit enrichment through the exercise of a position, mandate, function, employment, or activity.
- Do not receive, for oneself or others, bribes, movable or immovable property, or any other economic advantage, directly or indirectly, in the form of commissions, percentages, gratuities, or gifts from anyone with a direct or indirect interest that may be affected or supported by actions or omissions related to the duties of a public official.
- Do not receive any economic advantage, whether direct or indirect, to facilitate the acquisition, exchange, or lease of movable or immovable property, or the contracting of services from public or private agents, as defined in the Glossary, at a price above market value.
- Do not receive any economic advantage for engaging in or facilitating gambling, prostitution, drug trafficking, smuggling, usury, or any other illicit activity, nor accept promises of such advantage.
- Do not facilitate the sale, exchange, or lease of public assets or the provision of services by state agents at prices below market value.
- Do not make false statements in any service in favor of public or private agents, as defined in the Glossary.
- Do not offer employment, commissions, or consultancy/advisory services to individuals or entities with interests in the actions or omissions of public officials.
- Do not receive economic advantage for mediating the release or allocation of public funds of any kind.
- Do not receive any economic advantage, directly or indirectly, to conceal official acts, procedures, or declarations that one is obligated to perform.
- Do not benefit from assets, income, funds, or values belonging to public or private agents, as defined in the Glossary.
4. Bidding and Contracts
Regarding the conduct of employees, managers, directors, and partners representing the Organization in bidding and contracting processes, the following actions are strictly prohibited:
- Creating, modifying, or altering any documentation fraudulently or irregularly for participation or qualification in public bidding processes.
- Undermining or defrauding, through collusion, agreement, or any other unlawful act, the competitive nature of public bidding procedures.
- Preventing, disrupting, or fraudulently interfering with any act of a public bidding procedure.
- Discouraging or attempting to eliminate a bidder through fraud or by offering any type of advantage.
- Acting in bad faith during public bidding or in the resulting contract.
- Using a legal entity to participate in public bidding or enter into administrative contracts in an unlawful or fraudulent manner.
- Seeking undue advantage or benefit, fraudulently, through modifications or extensions of contracts entered into with public administration, without legal authorization, or provisions in the bidding notice or contractual instruments.
- Manipulating or defrauding the economic-financial balance of contracts entered into with public or private administration.
- Failing to include anti-corruption clauses in all contracts signed, to ensure compliance with this policy from the date of its publication.
5. Facilitation Payments
Facilitation or expediting payments are strictly prohibited. These refer to any small or nominal payment made to a public authority, individual, or private legal entity with the intent to facilitate, expedite, accelerate, or guarantee the execution of a bureaucratic procedure.
6. Internal and Third-Party Personnel
Under its Anti-Corruption Policy, the Organization prohibits the following actions:
- Conducting business with individuals or entities lacking a solid reputation, integrity, or technical qualifications.
- Any employee acting on behalf of the Organization exerting improper influence, understood as obtaining financial or economic advantage or engaging in influence peddling, over any person, whether a public official or not.
- Hiring employees who have been recommended or informally referred by public officials, with the intent of gaining influence or favor.
- Entering into contracts that do not include anti-corruption clauses to ensure compliance with this policy from the date of its publication.
- Failing to adhere to the terms and conditions of the Code of Conduct, Anti-Corruption Policy, and Ethics and Integrity Program.
- Tolerating, under any circumstances, corrupt practices by employees (internal or third-party) acting on behalf of the Organization, even informally.
- Failing to verify protested titles in notary offices.
- Failing to verify whether the Organization has relationships with politically exposed persons.
- Failing to verify whether the Organization is being prosecuted for corruption.
- Failing to assess technical capacity for service execution.
- Failing to consult other clients regarding the quality of services provided.
7. Procurement Process
All procurement processes must be conducted in accordance with the terms and conditions outlined in document [PO-TO-006-003] Procurement Process.
The Organization rejects the acquisition of goods and services through the improper use of influence over any person, whether a public official or not.
The Organization’s Procurement and Payment Policy establishes specific guidelines and procedures for all employees (internal and third-party), who must act in accordance with this regulatory instrument.
During competitive bidding processes, no employee may receive or offer any type of gift or entertainment from any individual or legal entity, whether a public official or private organization, that could improperly influence or compensate an act or decision, or represent actual or intended compensation for any benefit to the Organization or its stakeholders.
8. Contributions / Donations
It is important to clarify that the Organization does not make any type of contribution to political parties or sponsorships.
Regarding contributions/donations made to labor unions, the Organization clarifies that these are carried out due to legal requirements and follow the standards of Labor Laws, in full compliance with this policy.
Voluntary contributions apply exclusively to nonprofit institutions and charitable causes. The Organization follows these parameters:
- Contributions/donations in exchange for favors with any individual or legal entity, whether a public official or not, are strictly prohibited—even if the beneficiary is a legitimate charitable institution.
- Contributions/donations to charitable institutions associated with public or private agents are not permitted, as such actions may violate Anti-Corruption Laws.
- All contributions/donations must be properly documented, carefully reviewed, approved, and made solely for legitimate philanthropic purposes to duly registered charitable institutions. Under no circumstances may payments be made in cash or deposited into personal bank accounts.
9. Partner Evaluation
Details on this item are provided in [PL-TO-001-004] Partner Management Policy, section 4.
10. Verification of Service Compliance
In the event of a report concerning unlawful or fraudulent acts of any kind committed by employees at any hierarchical level, including Senior Management, the employee must report the incident via email to comite_compliance@to-brasil.com or through the Complaints Channel available at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx
Reports involving partners, suppliers, or clients must also be submitted directly to the Compliance Committee, which will handle the matter internally.
11. Recordkeeping and Accurate Accounting
The Organization is committed to maintaining its supporting documentation, including general ledgers, subsidiary records, and accounting books and accounts, which must accurately, precisely, and thoroughly reflect all transactions carried out by the Organization.
The Organization recognizes that combating corruption requires transactions to be transparent, truthful, fully documented, and properly classified in accounting records that accurately reflect their nature. It is also understood that attempting to conceal a payment or any other accounting information may constitute a violation of Anti-Corruption Laws and may result in fines and penalties. Any employee, manager, or director who engages in such practices will be subject to disciplinary action, as outlined in the Human Resources Policy.
The Organization ensures that all transactions and operations are fully documented, properly approved, and classified under the correct expense or revenue description. Under no circumstances should false or misleading documents be included in the Organization’s books and records. All documentation must be available in both physical and digital formats for inspection by regulatory authorities.
The Organization further declares that it maintains internal controls that provide security, transparency, and reliable information to ensure that:
- All accounting-related operations are approved and executed by qualified professionals, duly certified and supervised by their respective regulatory bodies. These requirements are part of our Anti-Corruption Policy, Code of Conduct, and Ethics and Integrity Program.
- All accounting-related operations are recorded and documented in our files and systems to enable the preparation of financial statements in accordance with generally accepted accounting principles or any applicable standards, and to maintain accurate control of assets and liabilities.
- If anyone becomes aware of or suspects that any individual is directly or indirectly manipulating accounting books and records or attempting to conceal payments, receipts, or accounting practices at any level of the organization, such misconduct must be reported to the Compliance Committee via email at comite_compliance@to-brasil.com or through the Complaints Channel available at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx
12. Independent Audit
As determined by Senior Management, the Organization periodically engages internal audits to assess compliance with the Integrity Program in alignment with Law No. 12.846.
The audit is responsible for verifying the compliance of the Governance Committee and Special Committees, ensuring alignment with current legislation and obligations. It operates with autonomy and independence in its analysis of processes, generating factual evidence that actions are consistent with moral, ethical, and legal standards required for the Organization’s business sector.
12.1. Scope of the Independent Audit
- Conduct verification and validation audits to assess the compliance of the Ethics and Integrity Program with the standards established by stakeholders.
- Identify non-compliance issues and inconsistencies, and develop an action plan to address them.
- Measure and validate the actions completed under the action plan.
- Certify compliance.
Any irregularities or violations must be reported to the Compliance Committee.
13. Awareness and Training
The Organization maintains an Anti-Corruption Awareness and Training Program for its internal and third-party employees, as well as Senior Management.
Training sessions are conducted to present the Organization’s Policies and the Anti-Corruption Law, along with the Code of Conduct and the Ethics and Integrity Program. These materials are made available via the intranet to all interested parties, and their reading and acknowledgment are monitored.
14. Disciplinary Measures
Details regarding this item are provided in the Human Resources Management Policy, section 10.
Glossary
Compliance
A set of disciplines aimed at ensuring adherence to legal and regulatory standards, as well as the policies and guidelines established for the Organization’s business and activities. It also involves preventing, detecting, and addressing any deviation or non-compliance that may occur. The term “compliance” means acting in accordance with rules, internal instructions, directives, or requests.
Fraud
Any deceptive, misleading, or dishonest act intended to harm or deceive others, or to avoid fulfilling a duty, thereby obtaining undue advantages or benefits (monetary or otherwise) for oneself or others.
Corruption
The alteration or manipulation of something’s original characteristics to gain advantage, including the misuse of public funds for personal gain or for the benefit of a family member or friend.
Types of corruption include:
- Passive Corruption: Committed by a public official against public administration, involving soliciting or receiving, directly or indirectly, undue advantage for oneself or others, even outside the scope of their role or before assuming it, but due to it.
- Active Corruption: Committed by a private individual against public administration, involving offering or promising undue advantage to a public official to influence them to perform, omit, or delay an official act. It may also involve seduction or being seduced by money, gifts, entertainment, or any benefit that leads someone to act against the law, morality, good customs, or what is considered right.
For the purposes of this policy, any form of corruption—whether involving public entities or private parties—will not be tolerated.
Bribery
An unlawful act involving inducing someone to perform a specific action in exchange for money, material goods, or other personal benefits. Bribery includes any offer, payment, or promise made to a public authority, government official, or other professional in exchange for favors that benefit the briber.
Influence Peddling
A crime committed by a private individual against public administration. It involves soliciting, demanding, charging, or obtaining, for oneself or others, an advantage or promise of advantage under the pretense of influencing an act performed by a public official in the exercise of their duties.
Malfeasance (Prevaricação)
A functional crime committed by a public official against public administration. It occurs when the official improperly delays or fails to perform an official act, or performs it in a manner contrary to legal provisions, to satisfy personal interests.
Extortion (Concussão)
The act of demanding, for oneself or others, money or advantage due to one’s position, directly or indirectly, even outside the scope of the role or before assuming it, but because of it.
Public Official
Anyone who, even temporarily or without remuneration, exercises a public mandate, position, employment, or function through election, appointment, designation, hiring, or any other form of investiture or affiliation.
Political Agent
Individuals holding structural positions within the political organization of the country, including those who shape the State’s supreme will. Political agents include the President of the Republic, Governors, Mayors and their Deputies, Ministers, Secretaries, Senators, Federal and State Deputies, and City Council Members.
Facilitation Payment
Any payment made to expedite or guarantee the execution of a governmental or private action, service, or procedure beyond its normal conditions.
Item of Value
Includes money, gifts, travel, entertainment, job offers, meals, and work. It may also include event sponsorships, scholarships, research support, and charitable contributions.
Internal Employee
An individual who provides routine services under an employment relationship, dependent on the Organization and receiving a salary. For the purposes of this policy, internal employees also include:
- Board Members, Executives, and Directors who contribute to the Organization’s business and activities through service contracts, with or without remuneration.
- Interns, as defined by the Internship Law (Law No. 11.788/2008), and Young Apprentices, as defined by the Apprenticeship Law (Law No. 10.097/2000).
Third-Party Employee
Any service provider who delivers services as requested.
Business Partners
Entities or individuals who potentially participate in the Organization’s business, such as suppliers, clients, and service providers.