Integrity Policy Timbro

Objective

The Integrity Policy (“Policy”) complements the TIMBRO Code of Ethics – and together they define the essential guidelines of the Compliance Program of all companies that make up the TIMBRO Group, referred to in this Policy simply as “TIMBRO ”

The Policy establishes corporate standards on the following topics:

  • Prevention and Combat of Illicit Acts
  • Courtesies
  • Contributions
  • Relations with the Public Administration and its Agents
  • Relationships with Competitors and Business Partners
  • Relationships with Third Parties
  • Conflict of Interest
  • Complaints Channel
  • Disciplinary Measures

These themes summarize the requirements of the following regulations:

  • Federal Law No. 12,846/2013 (Anti-Corruption)
  • Federal Decree nº 8.420/2015 (Regulates the Anti-Corruption Law)
  • Federal Law No. 12,529/2011 (Defense of Competition)
  • Federal Laws No. 9,613/1998 and No. 12,683/2012 (Money Laundering)
  • Federal Law No. 13,260/2016 (Anti-Terrorism Law)

Audiences

The Guidelines of this Policy must be practiced by Directors, Officers, Employees and Third Parties in their decisions and acts on behalf of or directly or indirectly involving TIMBRO.

Definitions

    • Agreement: An association between two or more people or companies aiming at the achievement of some purpose of mutual interest – the agreement can take verbal or written forms.
    • Public Administration: Set of federal, state or municipal public bodies, as well as public law organizations: municipalities, public foundations, public schools and universities, public research institutes, public hospitals, public companies, mixed capital companies, regulatory agencies etc.
    • Intermediary Agent: Third party that acts, directly or indirectly, on behalf of TIMBRO with the Public Administration.
    • Political Agent: Person holding or candidate for elective office, political party and political party cadres and Politically Exposed Person (PEP).
    • Public Agent: Person who, even if temporarily or without remuneration, holds a position, job or public function in bodies or entities of the Union, Federal District, state or municipality, as well as in legal entities controlled, directly or indirectly, by the Union , Federal District, state or municipality. Includes Political Agents.
    • Unlawful Act: Voluntary act or omission (willful misconduct), reckless, imperfect or negligent (guilt), prohibited or unacceptable by law.
    • Examples: Corruption. Courtesy or Improper Contribution. Financing of terrorism. cartel formation. Fraud. Frustration of public or private bids. Infringement against free competition. Money laundry. Bribery and Facilitation Payment. Exchange of personal or financial favors. Influence trafficking. Use of the position to obtain undue advantages for oneself or for third parties. Misuse or leakage of confidential or privileged information.
    • Gift: Object of small unit value and, usually, personalized with the brand of the company that offers it.
    • Elective office: Public office held by a person elected by popular vote during elections. Positions in the executive power: president, governors and mayors. Positions in the legislative power: senators, federal deputies, state deputies and councilors.
    • Cartel: Explicit or implicit agreement by companies for the purpose of obtaining profits through illicit or unethical (dishonest) means. Cartel companies usually achieve their goals by frustrating bids, eliminating competition, agreeing prices, setting production quotas, exchanging confidential information, etc.
    • Thing of Value: Amount of money, goods with economic value (which can be converted into cash. Examples: objects (pens, alcoholic beverages, leather briefcases and bags, clothes, watches, cell phones, electronic devices, household appliances, etc.) ), travel, accommodation, meals, registration for congresses or seminars, invitations or tickets for cultural, sports or entertainment activities, etc.
      Also considered Things of Value: privileged or confidential information, exchange of favors, gratuities, special discounts on products or services, etc.
    • Conflict of Interest: Situation in which someone prioritizes personal interests (their own interests or those of people or companies with whom they relate) to the detriment of the legitimate interests of TIMBRO and/or its stakeholders.
    • Actual Conflict of Interest: when there is in fact a clear conflict of interest.
    • Potential Conflict of Interest: When there is a situation that could evolve into an actual conflict of interest in the future.
    • Spouses: spouse; companion.
    • Degrees of kinship up to 2nd degree:

By consanguinity or legal adoption:

    • Father, mother, children (1st degree)
    • Siblings, grandparents and grandchildren (2nd grade)

By affinity:

    • Father-in-law, mother-in-law, son-in-law and daughter-in-law (1st degree)
    • Stepfather, Stepmother and Stepchildren (1st Degree)
    • Brothers-in-law (2nd degree)
    • Contribution: Donation, sponsorship, support, financial contribution, etc. made or received by TIMBRO.
    • Internal Controls (or Control Activities): Monitoring actions that help ensure compliance with the TIMBRO Guidelines.
    • Corruption: the act, process or effect of offering or accepting a bribe.
    • Active Corruption: The act of corrupting (bribing) someone.
    • Passive Corruption: The act of corrupting (taking a bribe) from someone.
    • Courtesy: Things of Value given or received in the form of a gift, treat, etc.
    • Diligence: Set of investigations that must be carried out: (i) before contracting a Third Party (due diligence, in English:

due diligences) to assess its competence and suitability; (ii) during the term of the contract to monitor compliance with contractual clauses on the subjects of this Policy.

    • Fraud: The act of deceiving and harming people or companies to obtain undue Things of Value or fail to fulfill obligations or duties. In addition to lying, fraudsters often falsify documents, identities, brands, products, etc.
    • Money laundering: Act that consists of carrying out illicit commercial or financial schemes with the aim of incorporating goods, services or money linked to illicit acts into the licit economy, in order to give them the appearance of regularity. It is one of the main means of financing terrorism.
    • Corporate Transactions: These are transactions between legal entities, such as: merger, acquisition, incorporation, joint venture, purchase of equity interests or assets, as well as partnerships, associations (eg for product or service distribution).

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  • Facilitation Payment: Payment made to a Public Agent to initiate, accelerate or close bureaucratic processes.
  • Politically Exposed Person (PEP) or Politically Exposed Person (PPE): Public Agent who performs or has performed, in the previous five years, in Brazil or abroad, in relevant public positions, jobs or functions, as well as their representatives, family members and others in your close relationship.
  • Bribery: The act of paying, offering or promising Things of Value to someone to influence (“buy”) the decision or action of one or more persons to obtain an unlawful or unethical advantage for the company, oneself or others .
  • Third party: individual or legal entity providing services, supplier or business partner of TIMBRO; examples: lawyer, advisor, consultant, contractor or subcontractor, forwarding agent, carrier, warehouse, agents, sales representatives, distributor, contractor, manufacturer, intermediary, laboratory, representative, reseller, etc.
  • Influence trafficking: The act of using one’s position in a TIMBRO, or relationships with people in authority, to improperly obtain a Thing of Value for oneself or others.
  • Undue Advantage: A thing of value obtained not by right or merit, but by means of an illicit act aimed at benefiting oneself, the company or third parties.

Prevention and Combating Illicit Acts

  • It is prohibited to directly or indirectly perform any Illegal Act in TIMBRO’s activities, business and operations.
  • You are prohibited from colluding (accomplice, complacent, participant, etc.) in any Illicit Act involving TIMBRO.
  • Every member of the target audience of this Policy has, in the course of their daily activities, the duty to prevent, identify and communicate to their managers and to the Ethics and Compliance area any weaknesses in the processes and systems that may be used as means for carrying out Illicit Acts of any nature involving TIMBRO.

Corruption

  • TIMBRO prohibits in its activities, business and operations any act or omission that may constitute corruption involving the Public Administration and/or Public or Private Agents in Brazil and abroad.
  • Also configures act of corruption:

  • Hamper investigations or inspections by public bodies, entities or agents, or intervene in their performance, including within the scope of regulatory agencies
  • Practicing any act harmful to the national or foreign Public Administration or that violates the international commitments assumed by Brazil regarding the fight against corruption.
  • Offering Contributions and Courtesies with the intent to bribe someone.

Fraud

TIMBRO prohibits in its activitieses, businesses and operations any act that may constitute fraud; examples:

  • Tamper payee.
  • To tamper with results or processes (sales, purchases, administrative…) in order to, for example, fulfill goals of any nature.
  • Increase spending amounts or invent them to divert company money or use any other means for that purpose.
  • Forgery of signatures on checks, documents, etc.
  • Forgery or tampering with documents, reports or records of any kind.
  • Forgery or tampering with payroll, commissions, compensation, etc.
  • Forgery or making fictitious contracts, sales, purchases, transfers.
  • Getting benefit, help or contribution through lies.
  • Making duplicate, unauthorized payments or incurring expenses that are not supported by formal documents or backed by TIMBRO’s Policies.
  • Subtracting or abusing TIMBRO’s assets and assets.
  • Subtract or misuse resources, financial or non-financial.
  • Use or disclose confidential or privileged information.
  • Using procedures contrary to the law in order to suppress or reduce taxes or contributions or their accessories.
  • Use company resources to purchase products or services for yourself or others.

Money Laundering

TIMBRO prohibits in its activities and business any act that may constitute concealment or concealment of the nature, origin, location, disposition, movement or ownership of goods, rights or values ​​arising, directly or indirectly, from a criminal offense.

To this end, we have adopted the following practices:

  • Risk assessment and monitoring of fundraising, intermediation and investment activities of own or third-party funds, in national or foreign currency, in order to avoid that they originate from or feed into illegal transactions.
  • Preventing and Combating Tax Evasion or Misappropriation of Funds.
  • Preventing and Combating Fraud.
  • We do not use the services of financial institutions that can be characterized as “shell banks” or “nested financial institutions”.
  • Prior and regular due diligence by our main Third Parties – special care must be taken in real estate and foreign exchange transactions.
  • Prior due diligence in Mergers and Acquisitions processes.

Terrorist Financing

TIMBRO prohibits in its activities and business any act that may support or finance terrorist actions in Brazil or abroad.

Acts of terrorism are those characterized by the use of violence, physical or psychological, through attacks on people or facilities, with the aim of instilling a feeling of fear in society. It is used by various groups: political organizations, separatist or revolutionary groups and even governments in power.

Courtesy

Courtesies can only be offered/received in accordance with the Laws and Regulatory Frameworks in force in the locations where we operate.

We do not offer/receive Courtesy as a form of bribe or that could give scope for the act of offering/receiving to be interpreted as such.

We do not ask or suggest the receipt of Courtesy for any person or institution. Nor do we accept requests or suggestions in this regard.

We do not offer Courtesies to Public Officials.

Amounts eventually received in cash must be reported to COAF in accordance with current legislation. The maximum amount suggested for offering or receiving a Courtesy is equivalent to R$500.00.
Note: Values ​​higher than this can be practiced as long as they are approved by the Ethics and Compliance Deliberative Committee.

In case of doubt about the offer/receipt of Courtesy, contact the Ethics and Compliance Executive Committee.

In the name of transparency:

  • We only receive Courtesies sent to our workplace.
  • The Courtesies offered by TIMBRO must be recorded in the accounting books.

What to do with Courtesies that must be declined?

Courtesies that, for whatever reason, cannot be received by administrators, employees and service providers must be kindly refused and returned using the model letter in Annex 1. In situations where it is not really possible to return a Courtesy, that who received it must send an e-mail notifying the offeror that the Courtesy will be drawn among TIMBRO employees – the standardized text of the e-mail is in Annex 2.
The Executive Ethics and Compliance Committee should receive a copy of this email to register Courtesy in Compliance controls.

Contributions

Purpose and natureContributions

  • No Contribution shall be made or received due to any type of pressure or for illicit purposes; nor should it leave room for it to be interpreted as such.
  • Contributions made or received must be duly recorded in the accounting books.
  • Actions benefiting from Contributions must be approved by [NAME OF BODY / POSITION] based on transparent criteria, such as:
    • To be aligned with TIMBRO’s purposes.
    • Be demonstrably relevant to those involved.
    • Be compatible with the resources invested.
    • Compliant with laws, regulatory frameworks and best practices recognized by the market.
  • Due diligence must be carried out before the granting of Contributions in order to verify the competence and suitability of the institutions and persons responsible for the benefited action.

Contributions to Public Officials

  • It is forbidden to make a Contribution of any value to Public Agents – including Political Agents here.
  • Contributions to Public Administration bodies must be previously approved by the Ethics and Compliance Deliberative Committee and clearly benefit the common good; examples:
    • Actions of cultural, social (education, health, public safety, human development…) or humanitarian support to communities.
    • Actions for the preservation or recovery of the environment.
    • Construction, preservation or renovation of public spaces and properties: community centers, sports centers, police stations, schools, hospitals, museums, squares, theaters, etc. Note: these projects may include equipment, machinery and furniture.
  • Contribution to judicial bodies, regulatory bodies or supervisory bodies is prohibited.
  • Contributions to Public Agents’ organizations are prohibited.

Note: Any contributions prohibited in the form of this item may be made if approved by the Ethics and Compliance Deliberative Committee and provided that they do not characterize non-compliance with the law and/or conflict of interest.

Contributions to the Third Sector

  • Contributions to Third Sector institutions must be previously approved by the Ethics and Compliance Deliberative Committee.
  • The conversion of tax incentives into Contributions to Third Sector organizations – for example, sponsorship of actions approved under the Rouanet Law – must be previously approved by the Ethics and Compliance Deliberative Committee.

Contributions to Employee Unions

  • Contributions from TIMBRO to Employee Unions are prohibited; examples: union headquarters renovation, events, purchase of equipment, etc.

Relationships with the Public Administration and its Agents

  • The practice and direct or indirect participation in acts against the national or foreign public administration as defined in Federal Law No. 12.846/2013 (Anti-Corruption Law) is prohibited.
  • The Facilitation Payment to any Public Agent in Brazil or abroad is prohibited.
  • The interactions of TIMBRO employees, directors and service providers with Public Agents that are not part of the regular exercise of TIMBRO’s corporate purpose must be:
    • Linked to matters of legitimate interest to TIMBRO or society.
    • Approved by the Board of Directors or by the Ethics and Compliance Deliberative Committee.

The hiring by TIMBRO of an Agent or former Public Agent to carry out consultancy work, issue opinions, lectures, courses, training etc., must:

  • Be expressly permitted by law.
  • Must respect quarantine periods related to the position held by the Agent or former Public Agent.
  • The work to be performed by the Agent or former Public Agent cannot constitute a real conflict of interest.
  • Have a justifiable and transparent reason for him – and not another professional in the private sector – to be hired.
  • Must be authorized by TIMBRO’s Ethics and Compliance Deliberative Committee.

Relationships with Competitors and Business Partners

We understand that when competition for consumers/customers is not limited by illicit arrangements between competitors or any market participants or by their abusive practices, society tends to benefit from the offer of better prices, more innovation and other effects positive. Therefore:

  • The practice or direct or indirect participation in acts against the economic order, freedom of initiative, free competition, the social function of property, consumer protection and repression of the abuse of economic power, as defined in Federal Law No. 2011 (Competition Defense Law); examples:
    • Limit, falsify or in any way impair free competition or free enterprise.
    • Dominate the relevant market for goods or services in an illegal manner.
    • Illicitly increase profits.
    • Abusively exercising a dominant position in the market.

Relationships with Competitors and Business Partners

We understand that when competition for consumers/customers is not limited by illicit arrangements between competitors or any market participants or by their abusive practices, society tends to benefit from the offer of better prices, more innovation and other effects positive. Therefore:

  • The practice or direct or indirect participation in acts against the economic order, freedom of initiative, free competition, the social function of property, consumer protection and repression of the abuse of economic power, as defined in Federal Law No. 2011 (Competition Defense Law); examples:
    • Limit, falsify or in any way impair free competition or free enterprise.
    • Dominate the relevant market for goods or services in an illegal manner.
    • Illicitly increase profits.
    • Abusively exercising a dominant position in the market.

TIMBRO’s information, communications or correspondence with competitors must be properly filed, protected and handled by administrators and Employees, in order to comply with the Competition Defense Law and to prevent them from being used illegally.

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Sources of information on competition and the market must be treated with transparency.

Large Corporate Transactions (mergers, acquisitions, associations, etc.) must be submitted to CADE (Administrative Council for Economic Defense), a federal agency linked to the Ministry of Justice, before proceeding with the acts for their consummation, in the form defined by law.
During operations subject to CADE:

  • No person or company linked to TIMBRO can provide, receive or exchange strategic and commercial information about the business with anyone without the express authorization of TIMBRO’s Deliberative Ethics and Compliance Committee.
  • You must avoid payments or initiate any type of integration of teams, services or products, before final approval by CADE, as defined by law.

Interactions with Competitors:

  • TIMBRO’s relationship with competitors must have the exclusive purpose of developing the sector and the market.
  • It is forbidden to exchange information with competitors that may, to any extent, harm free competition, TIMBRO, its companies, its customers and its consumers.
  • TIMBRO only participates in associations that have clear and well-defined rules.
  • The following are the main guidelines for the participation of administrators and Employees in class associations (federations, unions…).
    • The conduct must be guided by impartiality and transparency in the conduct of matters.
    • To adopt extreme caution in providing information requested by the association for the execution of projects of common interest, including for the purpose of market diagnosis or response to the competent authorities.
    • Do not adopt or encourage any type of initiative to:
    • Price pricing, even if indicative or suggestive, including when related to the payment of commissions to agents working in other links in the production chain.
    • Boycott suppliers or customers.
    • Exclusion of competitor, supplier or customer.

Interactions with Business Partners:

  • Commercial and contractual relationships with business partners (suppliers, customers, representatives, etc.) must strive for the broad defense of free competition, always aiming at preventing competition risks such as, for example, abuse of market power.< /li>

In this sense, TIMBRO’s administrators and Employees should avoid situations such as, for example:

  • Unjustified price, supplier or consumer discrimination.
  • Blocking input sources or distribution channels.
  • Market Closing.
  • Exchange of information between competitors.

Relationships with Third Parties

  • The selection and contracting processes of Third Parties must follow fair and impartial criteria, always bearing in mind the legitimate interests of TIMBRO.
  • We avoid having commercial or personal relationships with our Third Parties that constitute real conflicts of interest
  • Payments made to agents who act as intermediaries (lawyers, accountants, brokers, consultants) between TIMBRO and the Public Administration must be specified in service provision contracts and ifr properly identified in the accounting.
  • TIMBRO will adopt the embargo measures or sanctions provided for in Brazilian and international legislation against Third Parties included in lists published by national or international bodies to combat money laundering and terrorist financing.
  • Through contracts, due diligence or audits, we seek TIMBRO to ensure that Third Parties have a good reputation and, whenever possible, contracts with Third Parties that adopt a solid corporate integrity program aimed at preventing and combating illegal acts or unethical, such as:
    • Breach of labor, environmental, occupational health and safety legislation, etc.
    • Disrespect for human rights and diversity, tolerance of moral or sexual harassment, child, forced or slave labor, etc.
    • Corruption, fraud, money laundering, cartel, terrorist financing, etc.
    • Trafficking of influence and improper relationships with Public Agents.

Conflict of Interest

Conflict of Interest should be avoided, mainly because:

  • Puts the company’s reputation at risk.
  • It jeopardizes the personal credibility of those involved.
  • It compromises impartiality and a sense of fairness in decision-making processes.
  • It harms professional performance when we carry out parallel activities that interfere with our work.
  • We act in accordance with TIMBRO’s Culture, with ethics and transparency, aiming to promote relationships of trust.

Use of Position

  • It is forbidden to use your position at TIMBRO for your own benefit or that of third parties.

Information Security

  • The use of privileged or confidential information for personal benefit or that of third parties is prohibited.

Kinship Relations

  • It is allowed to nominate a spouse (spouse, partner) and relatives to work at TIMBRO.
  • It is forbidden to authorize the hiring of spouses (spouse, partner) and relatives up to the 2nd degree.
  • It is forbidden to work with spouses (spouse, partner), relatives or boyfriends/girlfriends in situations that constitute real or perceived conflicts of interest.
    • The hiring of employees and external service providers who are spouses or have a degree of kinship is allowed as long as it is approved by the Deliberative Council.

Personal Relations with Clients and Third Parties

  • It is permissible to indicate the hiring of companies owned or managed by relatives, former employees of the company or someone with a personal relationship.
  • It is forbidden to enter into or manage negotiations with companies of Clients or Third Parties managed by relatives up to the 2nd degree.
  • It is forbidden to unduly favor Clients or Third Parties.
  • It is prohibited to mediate or facilitate personal business on behalf of Clients or Third Parties
  • It is forbidden to assume, directly or through a company of which one is a partner, an activity in companies of Clients, Suppliers or Competitors unless such situation is submitted and approved by the Deliberate Committee.
  • It is forbidden to exchange or ask for personal favors for companies that are Customers, Suppliers and Competitors;

Shareholding in other Organizations

  • It is forbidden to assume equity interest in companies with the same lines of business as TIMBRO without the prior approval of the Deliberative Committee.
  • It is necessary to obtain the approval of the Deliberative Committee before assuming equity interests in Mixed Capital Organizations.
  • It is necessary to obtain approval from the Ethics and Compliance Committee before assuming equity interests in Customer, Supplier and Competitor Organizations.

Activities in other Organizations

  • It is forbidden to have a 2nd job in Organizations with the same fields of activity as the company, as well as in customers and suppliers of Timbro.
  • It is necessary to obtain the approval of the Deliberative Committee before undertaking remunerated or unpaid activities in Public Sector Organizations – including mixed capital companies.
  • It is allowed to have a 2nd job in Organizations with different areas of activity from the company.
  • It is necessary to obtain the approval of the Deliberative Committee before taking on a 2nd job in Customer and Supplier Organizations.

COMPLAINT CHANNEL

The COMPLAINT CHANNEL is available to any person or company who wants to:

  • Report violations – or suspected violations – of legislation or TIMBRO’s Integrity guidelines (Code of Ethics and Conduct, Corporate Policies).
  • Request support to resolve ethical issues, request guidance, resolve doubts, suggest improvements to Integrity System guidelines and practices, etc.
  • The main means of accessing the COMPLAINT CHANNEL are:
    • Phone: 0800 878 4094
    • Email: timbrotrading@compliance-office.com
    • Website: www.compliance-office.com/timbrotrading/
    • Others: Avenida Paulista, 171, Bela Vista, São Paulo, CEP 01310-000
    • The anonymity and confidentiality of the case are guaranteed and TIMBRO does not accept any act of retaliation or punishment against an employee or third party who makes complaints.

Disciplinary and Administrative Measures

  • This section establishes the main criteria and procedures for applying Disciplinary Measures in cases of misconduct (unethical or illegal acts) by TIMBRO’s Managers and Employees and contracted Third Parties.

Audience of the Disciplinary Measures section

  • TIMBRO Members (Administrators and Employees) and Contracted Third Parties.

Definition of misconduct for the target audience

  • The act of failing to comply is called misconduct:
    • Employment or service contract
    • TIMBRO Code of Ethics.
    • Policies and other normative instruments of TIMBRO.
    • Laws and Regulations (Unlawful Acts).

Disciplinary Measures

  • The main objectives of a Disciplinary Measure are:
    • Improve the work environment and organizational culture.
    • Reinforce the value of laws and regulations and, consequently, the need for all TIMBRO Professionals to comply with them. This means that Disciplinary Measures have, above all, a pedagogical purpose and, therefore, must be practiced with attention focused more on the future than on the past. When this happens, it is no longer seen as a mere “punishment” and is understood as a necessary instrument to prevent someone from benefiting from a fault that harmed their co-workers, TIMBRO or its stakeholders. Disciplinary Measures must be applied in a timely manner, with respect, good faith and impartiality.

Types of Disciplinary Measures

  • 1: Guidance – Conversation between the manager and the author of the misconduct in order to alert him and advise him on how to proceed so as not to repeat the fault. Note: This sanction is not applicable to illegal acts.
  • 2: Term of commitment – Document through which the author of the crime or misconduct commits not to repeat the behavior.
  • 3: Warning – Document in which the author of the crime or misconduct is warned of his fault.
  • 4: Suspension – Act of suspension, without pay, of the author of the crime or misconduct. Period: one to three days.
  • 5: Termination without just cause – Termination of contract – without just cause.
  • 6: Termination for just cause – Termination of contract – with just cause.

Cycle of application of disciplinary measures

It is recommended that Disciplinary Measures be applied as follows.

    • 1st Occurrence – Guidance, Term of Commitment or Warning – depending on the severity of the fault
    • 2nd Occurrence – Warning, Suspension or Termination without just cause – depending on the severity of the faults
    • 3rd Occurrence – Suspension, Termination without or for just cause – depending on the severity of the faults
    • 4th Occurrence – Termination for Cause.

Notes: Depending on the seriousness of the fault, the manager may decide to apply more severe sanctions than those suggested, that is, without the obligation to follow the cycle suggested above.

Disciplinary Measures Application Procedures

  • Before applying a Disciplinary Measure, the manager must assess the nature and seriousness of the misconduct committed. In addition, he must study the history of the professional at TIMBRO in order to verify if the author is a repeat offender and establish mitigating or aggravating circumstances for the application of the sanction.
  • When applying a Disciplinary Measure, the manager must:
  • Avoid any moral judgment of the person who will receive the sanction (avoid stigmatizing the person).
  • Act with transparency and objectivity.
  • Ensure the privacy and confidentiality of the procedure.
  • To make the author of the deviation aware of the harm he has caused, or could have caused, to the company, his colleagues and himself.
  • Alert the author about the sanctions that may be applied in case of recidivism.
  • Wherever possible, determine, in a collaborative process with the author, the best way to repair the damage caused.

Formalization of the application of Disciplinary Measures

  • Before meeting with the author, the manager must complete, print and sign two copies of the form corresponding to the type of Disciplinary Measures applied.
  • After notifying the author, the manager must give him a copy and onlybid him sign the other way.
  • The 2nd copy must be forwarded to Timbro’s Human Resources Department.
  • If the author refuses to sign the copies, the manager must turn to two witnesses (2 other managers) and ask them to sign both copies, after manually noting the date, time and the following text: “We witness the refusal of the addressee of this letter to receive/sign it”.

Typification of Deviations of Conduct

PERSONAL CONDUCT

  • Aggressions: physical aggression, verbal aggression, act of prejudice or discrimination, practice of moral harassment and practice of sexual harassment;
  • Dishonest Conduct: unauthorized access to documents, unauthorized access to building facilities, loan sharking, espionage and bad faith;
  • Irresponsible Conduct: act of indiscipline or incitement to indiscipline, misuse of alcoholic beverages and misuse of chemical substances;
  • Disrespect: Misconduct in relationships with co-workers.

PROFESSIONAL CONDUCT

  • Conflicts of Interest: preposition of personal interests to those of TIMBRO and breach of trust due to unfair practice;
  • Non-compliance with Rules (Laws, Regulations, Code of Ethics, Corporate Policies, Agreements, etc.): non-compliance with legal rules, non-compliance with TIMBRO’s guidelines and policies, non-compliance with contracts, terms of adhesion/commitment and etc;
  • Irresponsibility: act of irresponsibility in the exercise of functions, abuse of position and carelessness in the use of information;
  • Unlawful Uses: misuse of information for one’s own benefit, misuse of information for the benefit of others, misuse of benefits (health plan, etc.), misuse of equipment, systems, vehicles (owned or rented), misuse of misuse of building facilities, misuse of TIMBRO materials, misuse of corporate email and misuse of the Internet in the work environment;

CONDUCT IN RELATIONSHIP WITH STAKEHOLDERS

  • Relationships with stakeholders: misconduct in customer relationships, misconduct in relationships with suppliers, misconduct in relationships with competitors, misconduct in relationships with the media, misconduct in relationships with the public sector and misconduct in relationships with third parties sector

OFFENSES

  • Judicial convictions: conviction in the 2nd instance in criminal proceedings;
  • Corruption: practices of corruption, bribery or bribery;
  • Fraud (Tampers, Scams, Misrepresentation): Identity forgery, signature forgery, document (paper) forgery, Internet application fraud, bank card fraud, credit card fraud, debit card fraud , current account fraud, fraud in documents or electronic files and practice of embezzlement;
  • Theft (broad sense): embezzlement, embezzlement, theft and robbery (strict sense);
  • Information Security: breach of secrecy, confidentiality, privacy, information leakage and misuse of information;
  • Vandals: vandalism in documents, vandalism in equipment and systems and vandalism in building facilities