Compliance Policy

Introduction

Our company established, through this compliance policy, the principles, guidelines and functions of compliance at all levels of TFX, as well as all our products, services and supported projects, in addition to disseminating the culture and practice of compliance, demonstrating the importance to know and comply with legal, regulatory, normative and procedural determinations, both external and internal.

Our commitment is to have full corporate responsibility and integrity that defines the work of our ethics and compliance program (referred to as “Legal compliance“). Our entire commitment as a company that offers products, services and projects to the world is expressed in our code of conduct, which is organized around building trust with our customers, investors who accompany the company and commercial representatives. Company norms reflect our culture and our values, describe the principles that guide our behavior as a company (of a legal nature) helps each member to make good choices and seek guidance when necessary.

Legal Definitions

Being in compliance means being in compliance with the laws, regulations, standards and procedures, external and internal, and with the corporate principles that guarantee the best market and corporate practices. Corporate Governance, seeking to mitigate the risk of “Non-compliance”. Non-Compliance Risk is defined as the risk of compromising the integrity of TFX, due to non-compliance with the applicable national and foreign laws and regulations, external or internal rules, which may lead to legal and / or regulatory sanctions, or even , financial losses and reputational and / or image damage.

Our Compliance Program it is an internal sector that aims to prevent and / or in specific cases identify behaviors that do not comply with established rules, such as, for example, legislation, regulations, standards and procedures, external or internal, identifying the real risks and / or causes and acting preventively and / or corrective, also promoting a culture that encourages compliance with established rules and ethical conduct, guided by the principle that “doing it right is the best”.

Any TFX employee identified for being involved in any type of retaliation or report that has not been made in good faith may be subject to disciplinary measures, including termination of employment. We remind you that all of our internal operations are duly registered in the TFX-E (TFX Extranet), including daily reports with all operations. In the event of fraud, the company, following compliance rules, will take the appropriate measures applicable to each case on time.

Compliance Guidelines

Disseminate the principles, guidelines and conduct established in the TFX Code of Ethics;
Disseminate high standards of integrity and ethical values, through the dissemination of a culture that addresses the importance of compliance in TFX;
Protect TFX's reputation, maintaining the trust of stakeholders, associates and / or partners, customers, employees and society in general;
Establish and implement a “complete compliance structure”Which will be responsible for managing the TFX Compliance Program;
Ensure “complete compliance structure”An independent and autonomous management, as a segregated function, in order to guarantee impartiality and impartiality in all its activities;
Ensure full access to any information, provoking or accompanying investigations when the “complete compliance structure”Consider it necessary;
Ensure that the members of “complete compliance structure”, Confidentiality in the exercise of the function;
Provide “complete compliance structure”With the minimum resources (material and human) necessary for the good performance of its function.

Guidelines for the Compliance Framework

Guarantee free and immediate access to senior management and to regulatory and / or supervisory bodies, to the effective management of risks and irregularities or violations detected for non-compliance;
Manage the implementation of the TFX Compliance Program, as well as its maintenance and continuous improvement, considering the pillars of the program;
Ensure the implementation, execution and compliance with the rules and procedures of compliance by TFX;
Guide and assist in the identification of risks (TFX internal and external risk analysis), as well as in the definition and implementation of actions to eliminate and / or mitigate these risks;
Guide and assist in the identification of real causes and also in countermeasures, as well as monitor their implementation to correct non-conformities and / or improvements identified in the mentioned Compliance Program;
Guarantee and guide on good governance practices.

Applicability of our Compliance Policy

Our compliance has the most important and consistent pillars, such as: principles of people, processes and the highest technology in the world. It is essential to create a collective conscience, through increasingly effective compliance and risk management programs, aligning the importance of following our regulations in the short, medium and long term. This awareness occurs from above, that is, from the top management of TFX, to then spread as a solid organizational culture.

In addition, TFX has not only properly mapped guidelines, tools and processes, but also state-of-the-art technological resources linked to our artificial intelligence, to use these methods for good risk management. All this in search of making our company more and more safer and healthier, thus bringing an improvement in productivity and profitability.

Technical Variables of our Compliance Policy

In order for our compliance to work correctly in all of our products, services and projects that we support, it is very important to list some very important categories that we use internally within the company, not only to make our processes efficient, but also to ensure that all policies, regulations and laws in force in each country we serve are met. In practice, we use the control, established policies, risks of all calculated nature, current internal and external rules, elaboration and constant updating of strategies, standards (known as “Default”) established for security and functionality, requirements and audit that is generated, accredited and validated by our artificial intelligence, which gathers all the necessary information in a complex report for human analysis and audit. In summary: control, policies, risks, rules, strategies, standards, requirements and audit.