Code of Conduct for Suppliers and Business Partners

At Timbro, we conduct our businesses with ethics and transparency, respecting local and international laws and rules that regulate our sector. As we understanding we represent an important link in our value chain, we present this Code of Conduct for Suppliers and Business Partners, which provides guidelines aligned with our values and best practices.

We hope that together we can continue with relationships based on trust, ethics, and transparency, inhibiting acts that violate laws, regulations, and human rights and that negatively affect businesses, the environment, and society.

Jorge José Ribeiro Coutinho Guinle

President and Director of Timbro

Timbro has three basic commitments that act as pillars for all internal rules, actions, and procedures:

• COMMITMENT TO HUMAN BEINGS: Everyone must be treated with dignity, equality, and respect.
• COMMITMENT TO DOING THE RIGHT THING: All our activities must be guided by ethics, justice, inclusion, and compliance with laws.
• COMMITMENT TO QUALITY: All our actions should be focused on excellence and appreciation of good work.

The following guidelines are minimum standards expected from Timbro’s suppliers and business partners regarding labor relationships with their direct or indirect and permanent or temporary employees. 

Freedom of Association and Collective Bargaining

• Comply with all applicable labor and social security laws, regulations, and rules at local and international levels;
• Provide clear and understandable information to employees about working, legal, and contractual conditions;
• Comply with applicable laws, regulations, and rules related to freedom of association and collective bargaining;
• Recognize the legitimacy of unions regarding their practices and initiatives and openness to dialogue;
• Facilitate and not create obstacles to the right of freedom of association and collective bargaining.

Slavery and forced labor

• Prohibit, under any circumstances, forced, slave, and involuntary labor, and ensure these practices are not adopted in the relationship with own and outsourced employees;
• Comply with local and international laws, regulations, and rules related to working hours and workplace safety, how work-related activities are performed, wages, prohibition of forced or slave labor, and respect for human rights.

Child labor

• Prohibit child labor and ensure these practices are not adopted in the relationship with own and outsourced employees;
• Hire young apprentices only to the extent permitted by local law, and adopt policies and measures that inhibit overtime, night work, and work in dangerous conditions;
• Comply with local and international laws, regulations, and rules related to child labor.

Diversity and non-discrimination

• Promote a safe and receptive work environment, valuing and encouraging diversity among own and outsourced employees;
• Not tolerate any form of discrimination in employee hire, compensation, training, promotion, employment termination, and any other activity due to physical condition, race, gender, sexual orientation, origin or age;
• Offer channels to submit discrimination complaints and ensure no retaliation to individuals that report such actions.

Harassment and abuse

• Treat own and outsourced employees with dignity, respect, and fairness;
• Fight against any type of employee harassment or abuse, including, but not limited to, moral, sexual, physical, and verbal harassment or any form of intimidation;
• Offer channels to submit harassment and abuse complaints and ensure no retaliation to individuals that report such actions.

Health and safety conditions

• Ensure a safe and clean work environment for all employees;
• Adopt measures to mitigate risks and inhibit accidents and injuries in the workplace;
• Adopt the necessary health and safety measures, according to the legislation and activity to be performed, including mandatory personal protection equipment (PPE), mandatory training, inspection of facilities, among others.

Timbro expects its suppliers and partners to conduct their businesses with ethics, transparency, and integrity, complying with all applicable local and international laws, regulations, and rules. 

In this context, illegal practices will not be tolerated in the relationship and activities involving the Timbro Group, such as bribery, fraud, corruption, terrorism, and unfair practices or actions that violate the law. Compliance with the guidelines below is required by Timbro:

Compliance with Anti-Corruption Laws

• Develop a zero tolerance policy for any form of public and private corruption, including bribery, embezzlement, extortion, and facilitation payments;
• Comply with all applicable local and international anti-corruption laws, regulations, and rules, including Brazil’s Federal Law 12846/2013 (Anti-Corruption Law), Federal Decree 11129/2022 (Regulation of the Anti-Corruption Law), Federal Decree 10889/2021, and Federal Law 12529/2011 (Defense of Competition);
• Report any act or situation regarding businesses conducted with Timbro that may constitute improper conduct;
• Provide adequate mechanisms, policies, processes, and procedures to prevent illegal acts and improper conduct internally and across its value chain.

Compliance with Anti-Money Laundering Laws

• Comply with all applicable local and international anti-money laundering laws, regulations, and rules, including Brazil’s Federal Laws 9613/1998 and 12683/2012;
• Provide adequate mechanisms, policies, processes, and procedures to mitigate risks associated with money laundering and related activities.

Fair competition

• Comply with all applicable local and international trade and antitrust laws, regulations, and rules;
• Provide adequate mechanisms, policies, processes, and procedures to mitigate risks associated with unfair competition and unethical commercial practices;
• Not defame or publish comments that may harm the business or image of competitors;

• Not disclose Timbro’s Privileged Information or information of Timbro’s interest to its competitors, unless Timbro grants express written authorization for such purpose.

Fight against terrorism

• Comply with all applicable local and international anti-terrorism laws, regulations, and rules, including, Brazil’s Federal Law 13260/2016 (Anti-Terrorism Law);

• Provide adequate mechanisms, policies, processes, and procedures to inhibit, under any circumstances, acts of terrorism, including the use or threat to use, and carrying and storage of explosives; toxic gases; poison; controlled biological, chemical or nuclear substances or materials; and sabotage or violent takeover of physical spaces or communication systems through cyber methods.

Economic sanctions and embargoes

• Fully comply with all applicable commercial and economic sanctions to which it is subject due to its location, product, suppliers, and local and international customers involved, including import and export control laws, and laws that restrict businesses with legal entities and natural persons located in countries that are subject to commercial embargoes or economic sanctions.
• Adapt its due diligence procedures to ensure international commercialization of products.

Gifts, giveaways, and other offers

• Not grant gifts, giveaways, or offers to Timbro with the intention to influence a decision;
• Not grant giveaways, gifts or any other type of offer on behalf of Timbro to p

Timbro values relationships based on trust, transparency, and ethical conduct of all parties involved, treating all partners and suppliers with respect, regardless of the business volume with the company. Timbro’s guidelines for its relationship with partners and suppliers are presented below:

Quality, compliance, and customer service

• Value ethics and good faith, compliance with applicable national and international laws and regulations, and quality and safety in the delivery of products and services;
• Ensure full and efficient compliance with signed agreements;
• Comply with the specifications and contractual obligations agreed with Timbro;
• Provide mechanisms and procedures to ensure compliance with agreed deadlines.

Conflict of interest

• Report via our Culture and Ethics Channel (https://www.compliance-office.com/timbrotrading/) any conflict of interest arising before and/or during a commercial agreement, as well as any undue advantage directly or indirectly resulting from a conflicting relationship with Timbro.

Subcontracting and responsible sourcing

• Provide adequate mechanisms, policies, processes, and procedures to ensure compliance with local and international laws and regulations that are applicable to its own chain of suppliers and partners;
• Not provide products and services from organizations linked with illegal activities, involving human rights abuses, environmental damage, corruption or terrorism;
• Ensure that similar principles and values to this Code of Conduct are included in agreements with suppliers and partners so that guidelines related to ethics, compliance, anti-corruption, labor practices, sustainability, among others, are observed across its value chain.

Preservation and proper use of Timbro’s assets and resources

• Ensure proper use of Timbro’s intellectual and material assets and resources, such as corporate name, brand, logo, industrial designs, domain names, among others.

Information and data protection

• Comply with all applicable privacy, data protection, and cybersecurity laws at local and international levels;
• Not practice or omit any situation that may result in Timbro’s violation of privacy, data protection, and cybersecurity laws;
• Adopt data privacy and security programs, with measures to mitigate data misuse, breach, loss, alteration or unauthorized disclosure, as well as acquisition or access to sensitive or confidential information.

Monitoring and reporting

• Adopt processes and policies to ensure compliance with applicable law and this Code of Conduct for Suppliers and Business Partners;
• Inform Timbro of any violation of the guidelines defined in this document;
• Answer with transparency, and whenever requested by Timbro, a questionnaire about environmental, social, and governance practices and topics related to this Code of Conduct.

In line with the best practices and in order to strengthen its sustainability governance and the value creation across its businesses, Timbro has assumed commitments, which are described in its internal rules, especially in its Sustainability Policy, with the following guidelines for its activities and value chain:

Environmental compliance

• Comply with applicable laws and regulations related to environmental protection and management of socio-environmental risks;
• Provide programs, processes, and policies to ensure environmental compliance in line with national and international standards, and value continuous improvement of environmental management;
• Seek the efficient use of natural resources and preservation of biodiversity, as well as proper disposal of waste;
• Ensure responsible control and management regarding the use of prohibited agrochemicals or agrochemicals that are not legally approved for commercial use in the country;
• Provide mechanisms to mitigate risks of non-compliance with environmental guidelines, such as intervention in UNESCO heritage sites, wetlands in the Ramsar List, fauna and flora species threatened with extinction, and illegal deforestation;
• Prioritize, whenever possible, logistics modes of lower environmental impact;
• Disclose environmental policies and processes to stakeholders in accessible language;
• Ensure clean and safe storage of goods and products to be sold, as well as raw materials and packaging;
• Preferably and whenever possible, provide monitoring and due diligence mechanisms for the value chain of goods and products, particularly commodities and products involving genetic modification;
• Ensure animal welfare and cruelty-free practices;
• Avoid the extraction, trade, or transformation of asbestos;
• Encourage certification process and use of reliable and commercially renowned seals;
• Comply with the mining legislation for the extraction, transformation, transport, and storage of mining products.

Relationship with communities

• Ensure programs, processes, and policies to prevent non-violation of human rights in the communities surrounding the operations;
• Provide programs to prevent and adequately address any negative impact of operations on the health or safety of neighboring communities;
• Provide mechanisms to ensure compliance with social aspects to operate through stakeholder engagement;
• Respect the rights of local, traditional, indigenous, and quilombola communities and their cultural heritage;
• Provide channels for the community to submit complaints;
• Hire local service providers and buy local products whenever possible. 

Concerns, complaints, and comments about any suspected or actual violation of laws or the guidelines of this Code of Conduct must be reported, in good faith, via our Culture and Ethics Channel (https://www.compliance-office.com/timbrotrading/).

Reports are analyzed by an independent individual and confidentiality is guaranteed to everyone reporting such actions.