Code of Ethics and Conduct

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

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

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

Commitment to the customer: Our products and services must fully meet customers’ legitimate expectations.

The Code of Ethics and Conduct applies to all business conducted by Trucks Control, as well as to all employees who, in any way, represent the company in the marketplace, including third parties, apprentices and interns, consultants, temporary employees, and executives.

Everyone is responsible for complying with this Code, knowing that failure to do so may result in consequences for both the employee and the company.

Any employee or partner who violates this Code may face disciplinary action, including the risk of losing their job, or even criminal prosecution, depending on the severity of the actions. Meanwhile, Trucks Control may be fined, face legal proceedings and investigations, or suffer damage to its reputation.

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 customers (in the public or private sector), public officials, government employees, domestic 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 staff, interns, minor apprentices, and contractors.

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 in all locations where 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.

Employees are strictly prohibited from, directly or indirectly, promising, offering, or giving an undue advantage to a public official, a government agency, or any third party on behalf of Trucks Control.

In addition to cash and cash equivalents, the following will be considered “undue advantages”: donations of goods, gifts, entertainment (tickets), lodging, meals, travel expenses, or any other asset of tangible or intangible value.

Small payments requested by a public official for the purpose of expediting or ensuring the completion of a non-discretionary government procedure or action (“facilitation payments”) are strictly prohibited, even if failure to pay results in losses for the company.

Trucks Control prohibits and will not tolerate any retaliation or threat of retaliation against anyone who reports a possible violation of the law, a regulation, or a company policy.

Similarly, any employee who discourages or prevents another person from either making a report or seeking the help or assistance needed to report the problem will be subject to disciplinary action.

All employees must strictly comply with all applicable laws, internal regulations, and policies, including this document, while always upholding the highest standards of business ethics in the performance of their duties and in their dealings with internal and external parties.

No employee has the authority to request any action that violates this policy, and no waiver or exception is permitted, regardless of job title, hierarchical position, length of service, commercial or competitive demands, industry practices, or requirements of any other nature.

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

Employees, in the course of their duties at the company, may have access to confidential information about Trucks Control, its customers, suppliers, business partners, or shareholders. “Confidential information” includes, but is not limited to, any non-public company information, such as documents and information related to financial models, processes, and products; software; hardware; and applications developed or in use by Trucks Control—even if you were involved in their development—among other things.

Employees are prohibited from directly or indirectly using or disclosing confidential or privileged information to which they have access through their employment with the company, unless previously authorized by a supervisor or the Human Resources department, exclusively for matters related to Trucks Control.

No former employee may, directly or indirectly, use or disclose any information to which they had access during the term of their employment contract with the company, unless expressly authorized by Trucks Control.

The confidentiality of all information must be strictly maintained even among different departments within the company; except when its disclosure is authorized, in order to preserve the confidentiality of the information, please follow these guidelines:

Without prior authorization from management, the following is prohibited:

Trucks Control is a company committed to sound business practices that do not violate human rights and are aligned with various standards, including international standards for responsible business conduct, such as the Universal Declaration of Human Rights and the International Labor 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, and for this reason, it promotes and values initiatives that foster diversity and equality in the workplace, prohibiting all forms of discrimination, whether based on race, religion, gender, sexual orientation, age, political opinion, nationality, social status, origin, or other factors.

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

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

The Trucks Control team works diligently to achieve high standards of environmental, as well as in health and safety across the entire company, its subsidiaries, and third-party contractors, making every effort 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 strictly adhered to, and we spare no effort to manufacture equipment and provide services while showing the utmost respect for the environment and promoting the rational use of natural resources, without compromising our commitment to quality and efficiency.

Trucks Control respects the privacy of the individuals with whom it has a relationship, ensuring that any and all information and/or data for which it is the data controller is used lawfully, solely for its intended purpose, in accordance with the data subject’s authorization and in compliance with applicable domestic and foreign laws.

The disclosure of information classified by Trucks Control as confidential for purposes other than the legitimate conduct of Trucks Control’s business is prohibited.

Trucks Control believes in fair competition and, therefore, understands how competition laws affect day-to-day operations and the need to comply with them. Violating these laws can result in extremely serious consequences for the company and the employees involved, such as fines, reputational damage, litigation, and even imprisonment.

“Facilitation” or “slush fund” payments are small payments, often made with the intention of ensuring or expediting the processing of government actions. Trucks Control and anti-corruption laws strictly prohibit “facilitation” or “slush fund” payments.

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

Paying for meals may be considered a bribe and should not be practiced. This rule applies to all types of government officials, employees of public companies, related individuals, and private agents.

The consumption of alcoholic beverages is not permitted during meals with public officials and private entities, as drinking alcohol can impair our judgment and perception of our actions and intentions, and is not a practice consistent with this code.

At informal events or gatherings (such as happy hour) where alcoholic beverages are consumed—but regardless of whether they are—topics related to work routines, projects, product development, or even personal matters, such as colleagues’ behavior, among other company-related issues, should not be discussed.

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

Only gifts of no significant monetary value (pens, notepads, calendars, calculators, etc.) with a retail value of less than R$ 100.00 (one hundred reais) will be exempt from this rule.

Any and all items of value (gifts, entertainment, tickets, product donations, reimbursement of travel or meal expenses) offered by employees to third parties must serve a legitimate business purpose and be reported in advance to the company’s human resources department, as well as to the appropriate executive committee.

If you receive a gift, you should preferably return it; if that is not possible, forward it to the company’s Human Resources department so that it can be raffled off or donated to a charity chosen by the Human Resources department.

Trucks Control is a solid, reliable company that is mindful of its social and corporate responsibilities. Therefore, professionals in the finance department must help reinforce Trucks Control’s credibility in the market. To that end, it is essential to:

Any contribution, whether 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, officer, director, manager, employee, or third party is authorized to make political contributions or donations on behalf of Trucks Control.

Employees who wish to run for office in municipal, state, or national elections must notify the HR department of their intentions.

Red flags are defined as certain suspicious circumstances that may indicate a risk of violating anti-corruption laws, or situations that are irregular or inconsistent with the ethical standards we seek to uphold.

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

To make it easier to submit reports, including anonymous ones, we have made the following channels available:

We promote a culture of prevention, through which we address questions and concerns regarding compliance with our Code of Ethics and Corporate Policies via the LGPD and Compliance Committee.