Human Resources Management Policy

1. RELATIONSHIP WITH EMPLOYEES

The Organization’s most valuable asset is its team of employees. Therefore, the Organization does not limit itself to respecting the rights of employees as established by labor legislation. It goes further, investing in the personal and professional development of its talents, and in improving working conditions and interpersonal relationships. To this end, it adopts the following principles:

2. EMPLOYMENT RELATIONS

Employment relations are governed by a labor contract that follows the Consolidation of Labor Laws – CLT. This contract stipulates the rights and obligations of both parties. Accordingly, the Organization adopts the following principles to build a sustainable relationship with its employees:

3. PROFESSIONAL CONDUCT

The role of the employee in performing their duties includes:

Not removing, copying, reproducing, or disclosing any Organization information, in any form, that is proprietary and/or confidential.4. DRESS CODE

While performing their professional duties, employees represent the Organization’s image. For this reason, everyone should be mindful of wearing clothing and accessories that preserve this image, avoiding unnecessary exposure. We expect all employees to pay special attention to their attire when inside the Organization, at any of its offices, always using common sense and basic corporate dress code guidelines.

It is the responsibility of each Immediate Manager to assess whether the employee is appropriately dressed for the work environment. Employees assigned to client locations must follow the dress code standards adopted by the Organization where they will perform their duties. The Organization makes the following considerations regarding attire for men and women:

Any questions or concerns regarding the Organization’s dress code standards may be directed to the Human Talent Cell, which is responsible for clarifying doubts and taking appropriate action when necessary.

4. DRESS CODE

While performing their professional duties, employees represent the Organization’s image. For this reason, everyone should be mindful of wearing clothing and accessories that preserve this image, avoiding unnecessary exposure. We expect all employees to pay special attention to their attire when inside the Organization, at any of its offices, always using common sense and basic corporate dress code guidelines.

It is the responsibility of each Immediate Manager to assess whether the employee is appropriately dressed for the work environment. Employees assigned to client locations must follow the dress code standards adopted by the Organization where they will perform their duties. The Organization makes the following considerations regarding attire for men and women:

Any questions or concerns regarding the Organization’s dress code standards may be directed to the Human Talent Cell, which is responsible for clarifying doubts and taking appropriate action when necessary.

 

5. CONDUCT OUTSIDE THE ORGANIZATION

As a member of the Organization, the employee must be mindful of their conduct in public settings, whether in professional or personal circumstances, acting with prudence and care, and avoiding exposing the Organization or their own career to risk. The disclosure of privileged information is not authorized, including:

Employee values must align with those of the Organization, thereby contributing to the recognition of the Organization’s positive corporate image.

The Organization fosters an environment of respect for dignity, diversity, and human rights, and adopts policies and practices that actively contribute to the prevention, combat, and eradication of degrading forms of labor (child, forced, and slave labor). It prohibits discrimination, harassment, disrespect, exploitation, and prejudice of any kind—whether based on race, religion, age, gender, political beliefs, nationality, marital status, sexual orientation, physical condition, or any other factor—and expects employees to behave in accordance with these standards and all others described in this code.

6. RELATIONSHIP WITH UNIONS AND CIPA – INTERNAL ACCIDENT PREVENTION COMMITTEE

As a socially responsible Organization, we value the labor interests of our employees. Therefore, regarding unions and the CIPA – Internal Accident Prevention Committee, the Organization:

7. WORKPLACE DISCRIMINATION AND MORAL OR SEXUAL HARASSMENT PRACTICES

The Organization is committed to providing its employees with an environment free from any type of harassment or intimidation, whether verbal, written, or physical. Such practices are subject to disciplinary measures 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. This Organization does not tolerate harassment—whether sexual, economic, moral, or of any other nature—nor situations that constitute disrespect, intimidation, or threats in relationships among employees, regardless of hierarchical level.

Likewise, Employees, Managers, and Directors of the Organization must not engage in any form of discrimination that compromises the work environment or restricts opportunities based on non-professional criteria. This policy applies to all aspects of employment, from hiring to compensation, training, promotions, and terminations. Candidates must be evaluated solely on their ability to meet and adapt to the expectations of the role.

The Organization values diversity in workplace relationships. Therefore, respectful, courteous, and fair treatment must be given to all, regardless of position or role.

Any form of sexual harassment involving the mention of favors or the initiation of any such approach by an Employee, Manager, or Director is not tolerated by the Organization. Such behavior may include unwanted advances, jokes of a sexual nature, subtle or explicit pressure for favors, offensive insinuations, and proposals.

Employees, Managers, and Directors are required to immediately report any complaints or allegations of harassment via the email address comite_compliance@to-brasil.com or through the Complaints Channel available at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx

The Organization fosters an environment of respect for dignity, diversity, and human rights and seeks to eradicate all discriminatory practices or those characterized as moral or sexual harassment, punishing those who engage in such behavior.

Therefore, the Organization does not tolerate any act of prejudice, discrimination, threat, blackmail, false testimony, moral harassment, sexual harassment, or any other act contrary to the principles and commitments of this code, and has a duty to report offenders immediately.

Any employee who feels discriminated against, humiliated, pressured, subjected to abusive practices, or disrespected—and feels uncomfortable addressing the issue—should report the incident via the email address comite_compliance@to-brasil.com or through the Complaints Channel available at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx

8. USE OF ALCOHOL, DRUGS, WEAPONS, AND MERCHANDISE SALES IN THE WORKPLACE

Every employee must take care of their image. The use of drugs or alcohol during working hours—or being under their influence—is strictly prohibited, as it may affect the safety and performance of Employees, Managers, and Directors, as well as their colleagues.

Additionally, carrying weapons of any kind and selling personal merchandise that could in any way damage the Organization’s image within its premises is also prohibited.

While in the workplace, employees must not sell, distribute, purchase, process, or consume any substance considered illegal, nor indiscriminately consume legally prescribed medications. Employees whose behavior or attitude indicates they are under the influence of drugs or alcohol are not permitted to enter or remain on the Organization’s premises.

Failure to comply with these guidelines is considered a serious offense and will result in disciplinary action by the Organization, including termination for cause. Any employee who witnesses such conduct may report the matter immediately via the email address comite_compliance@to-brasil.com or through the complaints channel available at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx

9. WORKPLACE VIOLENCE

Workplace safety is essential. Violence of any kind, threats, threatening behavior, intimidation, or any similar conduct by Employees, Managers, or Directors must be reported directly through the complaints channel.

Once such reports are verified, appropriate disciplinary measures will be taken against those responsible. Any concern or threat regarding personal safety must be immediately reported through the complaints channel at:
https://connecta.to-brasil.com/sistemas/ouvidoria/Pages/Form.aspx

10. DISCIPLINARY MEASURES

Disciplinary measures refer to the application of a warning, suspension, or termination for cause of an employee due to conduct that violates the Internal Regulations, the Code of Conduct, and/or any other written or verbal guidance, provided it aligns with the law and good practices. These measures are applied by the Immediate Managers and the Personnel Department Cell.

10.1 PURPOSE OF THE DISCIPLINARY MEASURE

It is the responsibility of all Employees, Managers, and Directors to report any violation or suspected violation of the Anti-Corruption Policy, Ethics and Integrity Program, and the Code of Conduct. They are responsible for maintaining and complying with the guidelines set forth in this policy and are committed to sharing this responsibility.

The Organization reserves the right to review the procedures contained in this document to include, amend, or remove principles, and will communicate any changes to all employees through its official communication channels.

10.2 TERMINATION FOR CAUSE

Termination for cause refers to the termination of the employment contract without payment of certain severance entitlements, as provided by law, due to a serious offense committed by the employee or repeated minor offenses that make it impossible to maintain the employment relationship. It is the most severe measure in the employment relationship and must be used as a last resort, with due caution to avoid reversal in court or claims for moral damages.

    1. An employee may be terminated for cause if they commit any of the acts listed in Article 482 of the CLT.
    2. Essential elements for applying termination for cause:

a) Timeliness: The incident must be recent or known for no more than 30 days (or within 30 days after the conclusion of an internal investigation).
b) Evidence: Proof must be strong, clear, and unequivocal. There must be no doubt about the incident or its perpetrator. Evidence may be documentary, expert, or testimonial. Even if the employee confesses, additional evidence is recommended.
c) Severity: The offense must be serious enough to prevent the continuation of the employment relationship. In case of doubt, a disciplinary suspension is preferable before applying termination for cause.
d) Non bis in idem: No prior punishment must have been applied for the same incident. For example, if an employee damages equipment and receives a 3-day suspension, this cannot later be replaced with termination for cause.

    1. Examples of offenses that may justify termination for cause (non-exhaustive):

a) Dishonesty: Damage to the Organization’s assets, such as theft, embezzlement, document forgery for personal or third-party gain.
b) Indecent conduct: Behavior incompatible with sexual morality, e.g., accessing pornographic material on Organization equipment.
c) Misconduct: Unethical behavior, e.g., drug trafficking or frequent use of profanity in the workplace.
d) Unauthorized business activity: Engaging in personal or third-party business during work hours, even if not directly competing with the Organization.
e) Criminal conviction: If final and unappealable, and the sentence is not suspended. E.g., if the employee is convicted and detained, termination for cause may apply. If the sentence is converted to community service, termination for cause is not applicable.
f) Negligence in duties: Includes carelessness, recklessness, or incompetence, as well as repeated minor offenses. E.g., damaging expensive equipment due to negligence, frequent tardiness, or unjustified absences.
g) Habitual intoxication outside work: May justify termination for cause if it affects job performance.
1. Intoxication during work does not require habituality and may justify termination on the first occurrence if it poses a risk.
2. Intoxication may result from alcohol or drug use. Refusal to undergo treatment offered by the Organization may also justify termination.
h) Breach of confidentiality: Disclosure of information that may harm the Organization or is expressly prohibited. E.g., sharing sales strategies with competitors.
i) Indiscipline: Violation of general rules (regulations, circulars, policies). Insubordination refers to refusal to follow direct orders from a superior.
j) Job abandonment: 30 consecutive days of absence without justification. Formal notice (e.g., registered letter or telegram) must be sent requesting the employee’s return. Newspaper notices are no longer accepted and may result in moral damages.
k) Harmful acts to honor or reputation: Includes slander, defamation, or physical aggression against any person in the workplace, except in cases of legitimate defense.
l) Harmful acts against employer or superiors: Includes slander, defamation, or physical aggression, except in cases of legitimate defense.
m) Gambling: Regular participation in illegal gambling activities, e.g., unauthorized raffles or “jogo do bicho.”
n) Acts against national security: Proven through administrative inquiry, though rarely applied.

10.3 IMPLIED FORGIVENESS

Implied forgiveness refers to the absence of disciplinary action for a misconduct committed by the employee within 30 days of the occurrence, discovery, or investigation of the incident. In such cases, it is presumed that the Organization has forgiven the misconduct, and it may not be cited in the future, especially in court. As stated in legal doctrine and jurisprudence: “an unpunished offense is a forgiven offense.” For example, if an employee fails to use PPE while performing a task, and the Manager is aware of the incident but does not apply any disciplinary action within 30 days, any punishment applied afterward risks being declared null and void.

10.4 PREREQUISITES FOR APPLYING DISCIPLINARY MEASURES

10.5 PENALTIES THAT MAY BE APPLIED TO THE EMPLOYEE

a) Written warning via formal letter;
b) Suspension;
c) Termination for cause.

Note: Verbal warnings, although not legally binding, may be issued by the employee’s supervisor as a guidance measure for minor offenses, especially for employees with exemplary conduct and strong performance. In case of recurrence, the written warning may mention that the employee had previously received a verbal warning. Employees must never be warned or punished in the presence of another employee.

10.6 FACTORS TO CONSIDER WHEN DECIDING WHICH MEASURE TO APPLY

a) Severity of the offense;
b) Previous penalties, even of a different nature. For minor offenses, it is advisable to follow a sequence (verbal warning, 1-day suspension, 3-day suspension, 5-day suspension, termination for cause), provided the intervals between them are not excessive (e.g., less than 2 years);
c) Reason(s) that led the employee to commit the offense;
d) Length of service with the Organization — for example, if an employee has 10 years of service with no prior penalties and strong performance, a written warning for an unjustified delay may not be appropriate (a verbal warning would be preferable);
e) Employment history: previous penalties, commendations, performance, collaboration with the Organization and colleagues, among others.

Hiring of individuals with family ties is permitted, provided it is authorized by the directors. In cases of romantic relationships between employees, the principles of this code must be respected and followed. Although such relationships are discouraged, the situation will be evaluated by the area Manager.

Employees, Managers, and Directors must not use their position within the Organization to obtain personal advantages or create conditions conducive to actions that conflict with the Organization’s interests or the ethical standards established in this code. The policies outlined in this section apply to everyone without exception.

11. CONFLICTS OF INTEREST

Hiring of individuals with family ties is permitted, provided it is authorized by the directors. In cases of romantic relationships between employees, the principles of this code must be respected and followed. Although such relationships are discouraged, the situation will be evaluated by the Manager of the Cell.

Employees, Managers, and Directors must not use their position within the Organization to obtain personal advantages or create conditions conducive to actions that conflict with the Organization’s interests or the ethical standards established in this code. The policies outlined in this section apply to everyone without exception.

12. VERIFICATION OF SERVICE COMPLIANCE

After hiring, it is the responsibility of the Manager in charge of the recruitment to monitor the employee’s activities, remaining attentive to any warning signs or violations of Anti-Corruption Laws and compliance with the Code of Conduct and the Ethics and Integrity Program.

GLOSSARY

Harassment: Persistent pursuit, generally with the intent to obtain something.
Efficiency: The quality of being competent and performing functions correctly.
Eradicate: To eliminate, cause disappearance, or completely destroy.
Meritocracy: A system or model of hierarchy and reward based on individual merit.
Prudence: The trait of behaving in a way that avoids danger or negative consequences; caution.
Diligence: To care for something or someone, showing consideration. A person who is diligent is called zealous, showing great affection for those they care about.