Código de Conduta Ética

Purpose

This purpose of this Code of Ethical Conduct is to guide the personal and professional conduct of Trisul’s employees. This code provides guidance on the conduct of business and on the behavior of employees in all our professional relationships.

Scope

This code addresses different issues that are part of Trisul’s everyday activities, the way the company acts and how it conducts its business. The Code applies to service providers, interns, employees, executive officers, members of the Board of Directors and the Fiscal Council of Trisul and its subsidiaries..

People

We expect our employees to behave with ethics and dignity. Therefore, employees should:

  • Promote an atmosphere of mutual respect, regardless of their position or responsibility;
  • Act transparently and responsibly and never use our positions for our own benefit or that of third parties;
  • Neither engage in nor cooperate with discriminatory practices of any nature (against race, color, age, gender, sexual orientation, social and financial condition, religion, physical disability and/or mental disorder, nationality and/or marital status), moral or sexual harassment, and misuse of power;
  • Neither consume nor be under the influence of alcoholic beverages during working hours;
  • Make correct and appropriate use of the assets provided by Trisul in their everyday activities;
  • Ensure the supply of suitable material to employees for the performance of their activities, either in the administrative offices or on construction sites.
  • Provide all employees with opportunities for professional growth, based on their professional performance evidenced by measuring results;
  • Protect and guarantee the confidentiality of the employees’ information;
Conflicts of interest

Our basic professional principle should dictate that Trisul’s interests are above the personal interests of each individual employee. A conflict of interest may arise when an employee’s personal interest directly or indirectly confronts Trisul’s interests.

A conflict of interest is characterized by any material advantage for the employee or third parties with whom we maintain or maintained in the past personal, business or political relations. In the event of a conflict, the employee involved should inform his or her superior so that he/she can made the appropriate decision, in order to protect Trisul’s properties, its clients, shareholders, investors and other related parties.

Some of the basic principles to be followed by the employees are:

  • No employee may benefit from inside information to sell or purchase shares, either directly or through third parties;
  • Removing and using any type of material pertaining to Trisul for personal purposes is strictly forbidden;
  • Maintaining personal business or activities that divert the employee from performing the work he/she was hired to is not allowed;
Information security

Any information regarding Trisul, its employees, shareholders, controlling shareholders and/or subsidiaries, clients and partners is extremely important to Trisul and, therefore, must be protected. Information misuse and irregular disclosure may jeopardize Trisul’s image and results. Accordingly, any type of information must be protected and handled carefully.

Our employees agree:

  • Not to disclose confidential information of any nature to other employees or third parties who do not need said information to perform their activities;
  • To ensure the confidentiality of clients’ information, which is every employee’s responsibility. Information must not be disclosed to third parties without authorization from the responsible area;
  • Partner companies must agree to maintain the confidentiality and the security of clients’ information, protecting it from unauthorized access, use or data disclosure, limiting the use of information to the purposes agreed with Trisul;
  • Mitigate the risks inherent to information assets by implementing actions to raise the awareness about Information Security, targeted at all those included in this Code
Clients

In order to guarantee a true, lasting relationship between Trisul and its clients, we should always ensure the following foundations on which to build the company’s relationships:

  • Transparency in the information provided and in the relationships with clients;
  • A timely and efficient response to all requests;
  • Confidentiality of the information received as a result of business relationships.
  • Listen to suggestions, criticism and questions, valuing clients’ opinions;
  • No client should be considered special or be treated differently, regardless of his or her position on the market or by influence of our employees;

Não existe um cliente especial ou sujeito a condições de atendimento diferenciado independente da sua posição no mercado ou por influência dos nossos colaboradores;

Suppliers

Our suppliers are key elements of Trisul’s business and should participate actively in the company’s everyday activities, thus helping us to fully implement the policies presented in this code. Therefore, the relationship with suppliers should be based on respect, transparency and impartiality. Below are some of the basic principles underpinning the process of purchasing materials and services that formalize ethical commitments in the relationships with suppliers:

  • Suppliers are chosen and hired based on legal, technical and professional criteria;
  • Practices related to purchasing materials and services and engaging suppliers should be conducted ethically and involve decisions based on price, quality, quantity, delivery and assistance;
  • Trisul’s employees are not allowed to influence the process of selecting suppliers if they have financial interests or have invested in those suppliers;
  • Trisul respects and complies strictly with Brazil’s legislation in all the areas covered by its operations. Consequently, we only engage suppliers that comply with the legislation applicable to their activities. We do not engage companies that make use of child and/or slave labor;
  • It is strictly forbidden for our employees to use contract terms or other types of misleading communication to gain advantage over the other party;
  • We should engage suppliers and establish business relationships with partners operating with ethical standards compatible with ours, by means of a rigorous selection process, and should not conduct transactions with suppliers that are proven to disrespect the provisions of our Code.
Shareholders and investors

In our relationship with shareholders and investors, we are committed to fully complying with the guidelines of Trisul’s material information disclosure policy and policy on trading in securities issued by Trisul, both of which have been approved by the Board of Directors.

Both for profit sharing and information disclosure purposes, Trisul agrees to act symmetrically, impartially, without granting privileges to anyone. The company’s actions are based on the following criteria:

  • Adopting good Corporate Governance practices – transparency, accountability and equal treatment of all those involved, maintaining the market informed about its performance;
  • Announce its main actions or decisions immediately and through the responsible department, aiming at constantly updating all stakeholders about Trisul’s main activities;
  • No employee may benefit from inside information to sell or purchase shares, directly or through third parties;;
  • Misused information is illegal and may result in civil, administrative and criminal penalties.
Community and the environment

Our activities must be conducted under this code and in line with the highest ethical and moral values. To measure impacts, we should take into consideration the economic, social and environmental dimensions, on which to base our decisions referring to the development of real estate projects.

That is why we should always remember to:

  • Consider the possible impacts that the implementation of our projects may have on the environment and the community;
  • Contribute materially to the development of the communities where we operate;
  • Encourage socially and environmentally responsible actions and measures from our clients, employees and third parties;
  • Reconcile the generation of value to shareholders with the development of the communities where we operate;
  • Fully comply with the prevailing legislation regarding environmental, labor and civilized relationship aspects;

Trisul is committed to preserving the ecosystems, mainly non-renewable ones, by optimizing the use of natural resources in the company’s daily activities.

Press

Trisul recognizes the important role played by the press in disclosing impartial, independent and truthful information to the public opinion in general, especially to Trisul’s shareholders, employees, clients and suppliers.

In line with that, Trisul agrees not to mix the transparency of information and the commitment to disclosing information with marketing and advertising campaigns.

Our relationship with the press is based on transparency, reliability and trust, always in compliance with the values established in this code.

Trade Unions and professional associations

Trisul recognizes the important role played by trade unions and professional associations legally constituted to represent its employees, respecting collective negotiations, recognizing their legitimacy and complying with the collective bargaining agreements.

Competitor

Trisul is not engaged in any practice that may be regarded as anti-competitive, monopolistic, or in any way contrary to the international, domestic or local laws that regulate the market’s competitive practices. For this reason we should:

  • Respect our competitors;
  • Comply with the principles of free competition, by being honest and respecting our competitors’ reputation and opinion.
Government and regulatory agencies and public authorities

Trisul’s employees should fight against any type of advantage or privilege granted to public agents acting at all levels of authority.

We should continuously seek a good relationship with municipal, state and federal authorities: municipal governments, urban and environmental licensing agencies, specialized departments, regulatory agencies, government entities, public administration agents and third parties directly or indirectly involved in the development of our activities, respecting the laws, standards and rules and fulfilling our duties.

Last update: October 11, 2018