Code of Ethics and Conduct

This Code of Ethics and Conduct does not establish new rules; it merely formalizes the conduct already accepted and used by Trucks Control employees. The company and its employees should always strive to improve and promote the Code of Ethics and Conduct applicable to them.

Trucks Control wishes to conduct all its business in accordance with this Code; however, none of the provisions contained herein should be construed as an instruction to violate any law.

This Code of Ethics and Conduct will clearly outline the expectations regarding how Trucks Control conducts its business.

Commitment to the customer: The legitimate expectations of customers must be fully met by our products and services.

The Code of Ethics and Conduct applies to the conduct of all business carried out by Trucks Control, as well as to all employees who, in any way, represent it in the market, including third parties, apprentices and interns, consultants, temporary employees and directors.

Everyone is responsible for following this Code, understanding that failure to comply may have consequences for both the employee and the company.

Any employee or partner who violates this Code may be subject to disciplinary measures, including the risk of losing their job, or even facing criminal charges, depending on the severity of the offenses. Trucks Control, meanwhile, may be fined, face legal action and investigations, or even have its reputation damaged.

This code establishes guidelines, rules, and procedures to ensure that its recipients understand and comply with applicable anti-corruption laws in all interactions with current and future clients (from the public or private sector), public officials, civil servants, national and international suppliers, service providers, subcontractors, and partners, in any location where Trucks Control operates.

This code applies, without exception, to partners, administrators, directors, managers, employees, technical and operational teams, interns, apprentices, and outsourced workers.

Trucks Control condemns and does not tolerate any act of corruption. Therefore, all those subject to this code, without exception, must comply with and ensure that our business partners comply with local laws and other regulations prohibiting corruption wherever Trucks Control conducts business, including Law No. 12.846/2013 and the United Nations Convention against Corruption, among other national and international laws related to bribery and corruption.

It is strictly forbidden for employees, directly or indirectly, to promise, offer, or give undue advantage to a public official or body or to any third parties on behalf of Trucks Control.

In addition to money and its equivalents, the following will be considered "undue advantage": donations of products, gifts, entertainment (tickets), accommodation, meals, travel expenses, or any other tangible or intangible asset.

Small payments requested by a public official with the intention of expediting or securing the completion of a non-discretionary governmental procedure or action ("facilitation payments") are strictly prohibited, even if non-payment causes losses to the company.

Trucks Control prohibits and will not tolerate any retaliation or threat of retaliatory action against any person who reports a potential violation of company law, regulations, or policy.

Similarly, any employee who discourages or prevents another person from reporting the problem, or from seeking the necessary help or assistance to report it, will be subject to disciplinary action.

All employees must strictly comply with all applicable laws, internal regulations, and policies, including this document, always observing the highest standards of ethics in business, in the performance of their duties, and in the consistency of their relationships with internal and external stakeholders

No employee has the authority to request any action that violates these regulations, and is not subject to any type of waiver or exception, whether due to position, hierarchical rank, length of service, commercial or competitive demands, industry practices, or requirements of any other nature.

Any employee who deliberately violates this policy, or authorizes or allows a subordinate to violate it, will be subject to disciplinary action, including termination.

Employees, in the performance of their duties at the company, may have access to confidential information about Trucks Control, its clients, suppliers, business partners, or shareholders. "Confidential information" includes, but is not limited to, any non-public company information, such as documents and information relating to financial models, processes and products, software, hardware, applications developed or in use by Trucks Control, even if you participated in their development, among others

Employees are prohibited from directly or indirectly using or disclosing confidential or privileged information to which they have access due to their relationship with the company, except if previously authorized by a superior or the Human Resources department, exclusively for use in Trucks Control's business matters.

It is forbidden for any former employee, directly or indirectly, to use or disclose any information to which they had access during the term of their employment contract with the company, except with the express authorization of Trucks Control.

The confidentiality of all information must be strictly maintained, even between different areas of the company, except when its disclosure is authorized. In order to preserve the confidentiality of the information, please observe the following guidelines:

Without prior authorization from management, the following is prohibited:

Trucks Control is a company committed to good business practices that do not infringe on human rights and that are aligned with various standards, including international standards of responsible business conduct, such as the Universal Declaration of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

This code establishes standards, expectations, and commitments regarding Trucks Control's responsibility to respect human rights, including the prohibition of child labor or any other form of forced labor in our operations.

Respect for diversity, authenticity, and the individual are essential pillars for Trucks Control. For this reason, it promotes and values ​​initiatives in favor of diversity and equality in the workplace, prohibiting all forms of discrimination, whether based on race, religion, gender, sexual orientation, age, political opinion, nationality, social position, origin, or other factors.

In addition to its own operations, Trucks Control is committed to upholding high standards of responsible behavior among its business partners, including its suppliers and service providers.

Decisions regarding hiring, benefits, promotions, training, disciplinary measures, and terminations are always made based on the employee's skills and performance.

The Trucks Control team works diligently to achieve a high standard of environmental, health, and safety performance throughout the company, its branches, and third-party providers, expending maximum energy to prevent any accidents, injuries, and occupational illnesses in the course of our operations, including by promoting the proper use of equipment and protective measures.

All applicable environmental, safety, and occupational health laws and regulations are duly complied with, sparing no effort in producing equipment and providing services while respecting the environment to the fullest extent, promoting the rational use of natural resources, and without neglecting the commitment to quality and efficiency.

Trucks Control respects the privacy of the people with whom it interacts, so any and all information and/or data that it controls is used legitimately, only for the purpose for which it is intended, in accordance with the authorization of the data subject, respecting applicable national and foreign laws.

The disclosure of information classified by Trucks Control as confidential is prohibited for purposes other than those exclusively serving the legitimate performance of Trucks Control's business.

Trucks Control believes in fair competition and therefore understands how competition law affects daily operations and the need to respect it. Violation of these laws can result in very serious consequences for the company and the employees involved, such as fines, reputational damage, litigation, and even imprisonment.

"Facilitation" or "kickback" payments are small payments, often made with the intention of securing or expediting government actions. The Trucks Control and Anti-Corruption Laws strongly prohibit "facilitation" or "kickback" payments.

The definition of undue advantage should be interpreted broadly, and may include tangible and intangible assets, such as:

Paying for meals can be considered bribery and should not be a practice. This rule applies to all types of government officials, public company employees, related individuals, and private agents.

The consumption of alcoholic beverages during meals with public officials and private agents is not permitted, as the ingestion of alcoholic beverages can impair judgment and the perception of our actions and intentions, in addition to not being a practice aligned with this code.

In informal events/gatherings (happy hour) where alcoholic beverages are consumed, but regardless of this, matters pertaining to work routines, projects, product development, or even personal issues such as colleagues' behavior, among other company-related matters, should not be mentioned.

Trucks Control employees may not accept anything of value (including gifts, presents, entertainment (tickets), favors, loans, services or special treatment of any kind, payment of travel or meal expenses) from individuals or organizations that do or seek to do business with the company, including suppliers, service providers, customers, public officials, or any other current or potential business partner.

Only promotional items lacking significant monetary value (pens, notepads, calendars, calculators, etc.) with a commercial value of less than R$ 100.00 (one hundred reais) will be an exception to this rule.

Any and all valuable goods (gifts, presents, entertainment, tickets, product donations, payment of travel or meal expenses) offered by employees to third parties must have a legitimate business purpose and be communicated in advance to the company's human resources department, as well as to the relevant management.

If you receive any gifts, they should preferably be returned or, if that is not possible, sent to the company's Human Resources department so that they can be raffled off or donated to a charity chosen by Human Resources.

Trucks Control is a solid, reliable company that is aware of its social and corporate responsibility. Therefore, professionals in the financial area should contribute to strengthening Trucks Control's credibility in the market. To this end, it is essential to:

Any contribution, direct or indirect, made on behalf of Trucks Control to any political party, campaign committee, or candidate for public office, may only be made with the prior approval of the company's board of directors.

No shareholder, director, advisor, administrator, employee, or third party is authorized to make political contributions or donations on behalf of Trucks Control.

Employees who wish to run for municipal, state, or national elections should inform the HR department of their intentions.

Warning signs are understood to be certain suspicious circumstances that may indicate a risk of violating anti-corruption laws, or irregular situations or situations incompatible with the ethical standard that is intended to be safeguarded.

Even if it is not a violation per se, but a situation of apparent risk, the existence of a warning sign should be immediately reported to the Human Resources manager or Legal Department of the company. This will allow the company to investigate the facts, prevent the occurrence of an infraction, and decide on the best way to handle the situation.

To facilitate the receipt of complaints, including anonymous ones, we provide the following means:

We promote a culture of prevention, whereby we receive questions and concerns about compliance with our Code of Ethics and Corporate Policies through the LGPD and Compliance Committee.