Code of Ethics and Conduct
CHAPTER I – FRAMEWORK
Article 1 – Objectives
1. This Code of Ethics and Conduct, hereinafter referred to as the Code, establishes the principles, rules, and values regarding ethics and conduct that must be observed in Takenet’s procedures, aiming to promote the adoption of good practices in corporate diligence.
2. This Code must be interpreted together with the other regulatory instruments of the company’s policies, as well as with any applicable legislation and/or regulations.
Article 2 – Scope of Application
1. This Code applies to all employees, regardless of the nature of the functions performed, their hierarchical and/or functional position, as well as the type of employment relationship, understood as all persons carrying out activities at Takenet, namely members of the management body, employees, and interns, hereinafter referred to as recipients.
2. Also covered by this Code, and therefore by the concept of recipients, are all commercial or institutional partners of the company.
CHAPTER II – PRINCIPLES AND DUTIES
Article 3 – General Principles
1. In the exercise of their professional activity, the recipients of this Code must guide their conduct in accordance with the established principles, safeguarding the interests of the company.
2. Recipients must also adhere to high standards of professional ethics and not pursue personal interests, avoiding situations that could give rise to conflicts of interest.
Article 4 – Principle of Equality and Non-Discrimination
1. Recipients must not engage in discriminatory behaviour of any kind, namely on the basis of race, gender, age, physical disability, sexual orientation, political opinions, or religious beliefs, among others, giving priority to the principle of equality.
2. Any conduct constituting sexual harassment or abuse of power by the recipients is also not permitted.
3. The company implements measures aimed at ensuring gender equality, namely in the recruitment of human resources carried out with a defined competency profile.
Article 5 – Principle of Responsibility and Diligence
1. Recipients must act responsibly and competently, performing the duties assigned to them in the course of their functions with care, efficiency, and accountability.
2. Recipients must be aware of the importance of their duties and responsibilities, considering the expectations of others regarding their conduct.
3. The company promotes measures for the implementation of social, environmental, and corporate responsibility, namely the promotion of internal sustainability practices in waste management and resource conservation with employee awareness, and recipients must act diligently to ensure these objectives are met.
Article 6 – Confidentiality and Secrecy
1. Without prejudice to legal principles, recipients must maintain absolute confidentiality regarding any third parties concerning all information they become aware of or have access to, and they must not disclose, reveal, use, or refer to it.
Article 7 – Loyalty and Impartiality
1. Recipients must commit to loyalty and cooperation among themselves and with the company, striving in all situations to contribute to the credibility, prestige, and image of the organization, and to foster a strong spirit of teamwork and collaboration.
2. In the exercise of their functions, recipients must always keep in mind the interests of the company and its stakeholders, acting impartially and refraining from behaviours that favour third parties due to their own interests or those of such third parties, and guiding their decisions by the highest standards of seriousness and integrity.
Article 8 – Legal Compliance
1. The company must respect and ensure the scrupulous compliance with the legal and regulatory standards applicable to its activities, providing a healthy and safe environment for its employees and other stakeholders interacting with it.
2. Recipients must act in accordance with the law, not violating any legal provision, recommendation, or instruction from a competent authority.
Article 9 – Conflicts of Interest
1. For the purposes of this Code, a conflict of interest is deemed to exist whenever a recipient has a personal or private interest in a matter that may influence, or appear to influence, the impartial and objective performance of their duties, or benefit from the procedures they implement.
2. Recipients of the organization who, in the exercise of their functions and responsibilities, are called to intervene in processes or decisions where a situation may constitute a conflict of interest must immediately disclose it and refrain from participating in decision-making regarding the matter.
CHAPTER III – INTERNAL RELATIONSHIPS
Article 10 – Interpersonal Relationships
1. Recipients, in their relations with one another, must foster a healthy work environment, comply with the rules regarding the use of space, and promote mutual support and team spirit, adopting conduct guided by mutual respect, professionalism, cordiality, and honesty, with actions reflecting loyalty to the company and integrity.
2. All employees must disclose and communicate to supervisors and colleagues the information essential for the progress of work; providing false, inaccurate, or exaggerated information, refusing to cooperate with colleagues, or displaying obstructive behaviour is not acceptable.
3. In the exercise of their functions, recipients must not engage in any form of psychological, professional, or sexual harassment, nor consume alcohol and/or drugs while participating in company procedures.
4. Recipients performing management and coordination functions must instruct their subordinates in a clear, objective, and understandable manner, either orally or in writing.
5. Recipients who have family or equivalent relationships among themselves must not exercise their activities in a direct hierarchical or functional relationship.
Article 11 – Resources
1. All equipment, resources, or facilities, regardless of their nature, may only be used for the performance of duties within the scope of the recipient’s activity, unless prior authorization states otherwise.
Article 12 – Environment, Health, and Safety
1. Recipients must be aware of, comply with, and ensure compliance with occupational health and safety standards, promoting good environmental management practices in order to minimise adverse effects resulting from their activities, preserving the surrounding environment and ensuring the best working and well-being conditions for all.
CHAPTER IV – EXTERNAL RELATIONSHIPS
Article 13 – Relationship with Third Parties
1. In their interactions with third parties, recipients must adopt a courteous, impartial, and fair attitude, providing the requested cooperation with due promptness and diligence.
2.The information provided by recipients must be clear, understandable, accurate, and truthful.
3. In complying with the above provisions, recipients must observe the duties of loyalty, confidentiality, professional secrecy, discretion, and the protection of personal data.
Article 14 – Selection of Partners
1. The company selects commercial and institutional partners in accordance with, and with a view to ensuring compliance with, corporate due diligence rules.
2. For the establishment of institutional relationships, entities that share the principles set out herein are chosen.
CHAPTER V – FINAL PROVISIONS
Article 15 – Disclosure and Publication
1. This Code must be disseminated by all recipients via institutional email, including, and in particular, to new employees joining the organization.
2. Likewise, the Code must be made known to commercial and institutional partners.
Article 16 – Revision
1. This Code must be reviewed annually, or whenever facts arise that justify its revision.
2. Any recipient may submit improvement suggestions deemed appropriate to strengthen the objectives of this Code.
Article 17 – Entry into Force
1. This Code shall enter into force on the day following its publication on the company’s website.
Article 18 – Reporting of Irregularities and Non-Compliance
1. Any irregularities or breaches of this Code must be reported immediately, either directly to the hierarchical superior or top management, or anonymously through the reporting channel available on the company’s website.
2. Non-compliance with the provisions of this Code, once the relevant legal conditions are verified, may give rise to liability, namely disciplinary, civil, or criminal.
