Code of Conduct

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

1. Objective

This Code of Conduct aims to guide the behavior of all employees, interns, service providers, and partners of T.O. Services, ensuring that their actions are aligned with the Organization’s values and principles. It serves as a reference for ethical conduct and professional integrity in all internal and external relationships.

2. Fundamental Principles

2.1 Legality

All actions and decisions must be based on current legislation and internal regulations.

2.2 Impersonality

Decisions must be made based on objective criteria, avoiding favoritism or personal interests.

2.3 Morality

Conduct must be guided by ethical principles, honesty, and integrity.

2.4 Publicity

Information must be transparent and accessible, respecting confidentiality when necessary.

2.5 Efficiency

Resources must be used responsibly, aiming for quality and continuous improvement.

2.6 Transparency

Processes and decisions must be clear and open to scrutiny.

2.7 Integrity

Acting with honesty, loyalty, and responsibility in all relationships.

2.8 Respect

Treating everyone with dignity, valuing diversity and inclusion.

2.9 Accountability

Taking responsibility for actions and decisions, being open to feedback and corrections.

3. Ethical Commitments

3.1 Relationship with Employees

The Organization values the relationship with its employees, promoting a healthy, safe, and inclusive work environment. It respects labor laws and encourages professional development.

3.2 Relationship with Clients

We are committed to providing high-quality services and maintaining transparency and respect in all interactions with our clients.

3.3 Relationship with Suppliers and Partners

Our partnerships are based on ethics, transparency, and mutual respect. We select suppliers and partners based on technical and ethical criteria.

3.4 Relationship with Competitors

We respect our competitors and compete fairly, avoiding practices that may harm their image or business.

3.5 Relationship with the Government and Society

We comply with laws and regulations, contribute to social development, and act responsibly in all our interactions with public entities.

3.6 Use of Assets and Resources

Employees must use the Organization’s assets and resources responsibly, avoiding waste and misuse.

3.7 Confidentiality and Information Security

We protect confidential information and ensure the security of data entrusted to us by clients, employees, and partners.

3.8 Conflict of Interest

Employees must avoid situations that may generate conflicts between personal interests and the Organization’s interests.

3.9 Anti-Corruption and Anti-Bribery

We do not tolerate any form of corruption or bribery. All employees must act with integrity and report any suspicious activity.

3.10 Social and Environmental Responsibility

We are committed to sustainable practices and contribute to the well-being of the community and the environment.

4. Workplace Environment

T.O. Services promotes a healthy, safe, and respectful work environment, free from any form of discrimination, harassment, or abuse of power. All employees must contribute to maintaining a professional and collaborative atmosphere.

4.1 Respect in the Workplace

Employees must treat colleagues, clients, and partners with respect, courtesy, and professionalism, regardless of position, gender, race, religion, sexual orientation, or any other personal characteristic.

4.2 Harassment and Discrimination

Any form of harassment, discrimination, or intimidation is strictly prohibited. T.O. Services does not tolerate behaviors that may create a hostile or offensive work environment.

4.3 Health and Safety

Employees must comply with health and safety standards and report any conditions or behaviors that may pose risks to physical or emotional well-being.

4.4 Use of Alcohol and Drugs

The use of alcohol or illicit drugs during working hours or on company premises is prohibited. Any behavior that compromises safety or productivity due to substance use will be subject to disciplinary measures.

4.5 Freedom of Expression

T.O. Services values freedom of expression, provided it is exercised responsibly and respectfully. Offensive, discriminatory, or inappropriate comments are not tolerated.

5. Confidentiality

All information, data, and documents to which employees have access due to their role or position must be treated with absolute confidentiality and discretion.

Employees must not disclose confidential information to third parties, including other employees who do not need access to such information for their work.

The Organization’s confidential information includes, but is not limited to: business strategies, financial data, client information, internal processes, software, and any other proprietary information.

Employees must also respect the confidentiality of information from clients, suppliers, and partners, ensuring that such data is not disclosed or misused.

The obligation of confidentiality remains even after the termination of the employment relationship.

Any breach of confidentiality may result in disciplinary actions, including termination of employment and legal measures.

6. Internal Controls

The Organization adopts internal control practices to ensure the integrity of its operations and compliance with applicable laws and regulations.

Employees must follow internal procedures and policies, including those related to financial, operational, and technological controls.

It is the responsibility of all employees to report any irregularities, fraud, or violations of internal controls to the appropriate channels.

The Organization promotes transparency and accountability in all its processes, ensuring that internal controls are continuously monitored and improved.

 

7. Legal Matters, Lawsuits, and Investigations

7.1. Legal impediments

Employees, Managers, and Directors who have been arrested, accused, investigated, prosecuted, or convicted of fraud and/or corruption—or of any other offense—after joining the Organization must report the incident to the Compliance Committee, which will refer the individual to the Human Talent Cell.

The Organization values ethics and transparency, and strictly prohibits any fraudulent or unlawful behavior. At no time has it ever delivered, offered, authorized, agreed to, or promised any form of payment or benefit to any national or foreign government authority, whether to secure or maintain business or to obtain any commercial advantage.

Any employee who becomes aware of conduct related to this matter may report it immediately via email to comite_compliance@to-brasil.com.

7.2. Legal proceedings

The Legal Cell must be promptly informed if any employee, Manager, or Director receives a court summons, extrajudicial notice, subpoena, complaint, warning, or becomes aware that the Organization is involved in a legal or administrative proceeding, investigation, or government inquiry.

No employee is authorized to conduct any investigation, whether governmental or otherwise. This includes receiving subpoenas or requests for documents or information related to the Organization’s business or labor operations.
Any employee who becomes aware of conduct related to this matter may report it immediately to the Compliance Committee.

7.3. Participation in investigations

In cases where employees are involved in internal investigations, they must be honest in all interactions with investigators. They are strictly prohibited from:

Destroying, altering, or concealing documents or other potentially relevant evidence in anticipation of or in response to a request from a government or regulatory authority or a court.

Obstructing, fraudulently influencing, or interfering with an external or internal investigation or inquiry, or attempting to do so through improper means.

Allowing another employee or third party to destroy evidence, provide false or misleading information, or otherwise obstruct any investigation.

Lying or making false statements in connection with an investigation by federal, state, or municipal authorities, law enforcement agencies, or an internal investigation conducted by the Organization.

Employees must notify the Legal Cell of any legal matters they become aware of that involve the Organization.

8. General Interest Matters

To ensure compliance with Anti-Corruption Laws, employees must remain vigilant for warning signs and any situations that conflict with the principles outlined in this code.

Employees, Managers, and Directors may report any suspected violations of Anti-Corruption Law requirements. Reports should be submitted directly through the Complaints Channel or via email to comite_compliance@to-brasil.com. Whether identified or anonymous, the Organization will take steps to protect the confidentiality of any report, subject to applicable law, regulation, or legal proceedings. In case of doubt regarding these laws, the Legal Cell may provide the necessary clarification.

The Organization does not permit or tolerate any form of retaliation against individuals who report violations of this code in good faith. Any employee, Manager, or Director involved in retaliation will be subject to disciplinary action, including possible termination of employment.

Violations of Anti-Corruption Laws may result in penalties for the employees and/or representatives involved. These penalties may apply to both individuals and legal entities. In addition to legal penalties, violations of the Anti-Corruption Policy may be subject to disciplinary measures as outlined in the Human Resources Policy.

Given the potential for severe consequences, the Organization is committed to complying with Anti-Corruption Law requirements through practices that protect its interests, such as external audit processes, training programs, contractual clauses requiring compliance with Anti-Corruption Laws, and close monitoring of organizational activities.

8.1. Disciplinary measures

Details on this item are provided in [PL-TO-001-005] Human Resources Management Policy, section 10.

8.2. Omitted cases

Despite its scope, this document does not cover all laws or policies applicable to the Organization. It also does not replace the use of judgment or the pursuit of additional guidance when necessary.

Omitted cases may be submitted to the Compliance Committee through the Complaints Channel or via email to comite_compliance@to-brasil.com.

8.3. Industrial and intellectual property rights

The Organization and its employees must respect industrial and intellectual property rights, in accordance with applicable laws and regulations. The misuse of research, studies, texts, publications, software, and related works is strictly prohibited.

Work developed by colleagues, regardless of their hierarchical position, must be respected and their intellectual property recognized.

8.4. Social responsibility

Given the significant social challenges and inequalities in our country, corporate social responsibility has become increasingly relevant. Brazilian society expects organizations to play a new role in the development process—as agents of cultural transformation, drivers of social change, and builders of a better society.

For us, social responsibility contributes to the humanization of employees, Managers, and Directors, and promotes their inclusion in a productive community.

The Organization considers it essential to engage in discussions around social responsibility, ethics, and value formation, recognizing its role in the broader societal process and its ecological, social, and cultural responsibilities.

8.5. Occupational health, safety, and the environment

The Organization handles all information related to health, workplace safety, and environmental impact transparently, especially when it affects employees, communities, or the environment itself.

Everyone is expected to observe the work environment carefully and identify potential risk situations. If any signs are detected, the matter must be reported to the Compliance Committee, which will refer it to the CIPA members.

This behavior is considered a demonstration of commitment to safety issues.
For more information on this topic, please refer to our HSE Policy.

8.6. Training and awareness on proper conduct, moral and sexual harassment

Documents will be presented to new employees during their onboarding process, conducted by the Human Talent Cell. These documents are available on the intranet.

The Organization continuously conducts training sessions to ensure employees understand and take responsibility for their routines. Employees must familiarize themselves with the policies and procedures outlined in this code and in the guides on moral and sexual harassment.

Everyone is expected to observe the work environment carefully and identify potential risk situations. If any signs are detected, the matter must be reported to the Compliance Committee via email at comite_compliance@to-brasil.com.

8.7. Harassment/Abuse of power

The Organization is committed to providing a workplace free from any form of harassment or intimidation, whether verbal, written, or physical. Such practices are subject to disciplinary action and appropriate penalties.

The Organization promotes diversity and seeks to eliminate all forms of negative discrimination based on race, color, gender, sexual orientation, age, religion, political opinion, nationality, social status, or physical condition. Harassment of any kind—including sexual, economic, moral, or otherwise—as well as disrespect, intimidation, or threats in relationships among employees, regardless of hierarchical level, will not be tolerated.

Any form of sexual harassment involving the solicitation of favors or the initiation of any such approach is strictly prohibited by the Organization.

For more information on these topics, please refer to the Moral Harassment Guide and the Sexual Harassment Guide.

8.8. Clarification and management of the code of conduct

Approval of this code and its updates is the responsibility of the Organization’s Senior Management focal point and the Compliance Committee.

8.9. Complaints channel

The Organization recognizes communication as a key tool for transparent management and the effective dissemination of the values and principles described in this code.

To this end, it provides all stakeholders with access to the Complaints Channel, available at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx

We also offer the email address comite_compliance@to-brasil.com, which receives both reports and supporting evidence.

These channels operate impartially and transparently, ensuring the confidentiality of information, protecting the identity of those involved, and fostering a better environment for everyone.

Reports may be submitted anonymously, as the channel can be accessed from anywhere and from any email address. To be valid, reports must include supporting evidence or documentation.