Founded on June/01/1992, Tecturbo® specializes in providing parts and services for multi-brand centrifugal compressors, leasing and sale of new and remanufactured centrifugal compressors.

Working throughout Brazil and Latin America, Tecturbo® over the years has developed partnerships with national and multinational companies. With skilled labor and immediate delivery spare parts ensure the provision of efficient and reliable services. With the aim of satisfying our customers, we have a 24-hour technical assistance system.

In tireless pursuit of perfection, in mid-1998 Tecturbo® obtained the ISO 9001/2000 certificate with merit, another guarantee of our quality.

DISCLAIMER
Tecturbo® is in no way authorized, affiliated or associated with Ingersoll Rand CENTAC ®, Atlas Copco ®, JOY ®, Cooper Turbocompressor ®, Cameron ®, or other products mentioned, which are registered trademarks of their respective companies. Names, models and numbers of OEM parts manufacturers are used only here for cross-reference and compatibility just for this purpose.

CODE OF ETHICS AND CONDUCT

Summary
I. Introduction
II. The organization
III. Mission, Vision, Values ??and Quality Policy
IV. Professional Behavior
V. Confidential and Confidential Information
SAW. Intellectual property
VII. Relationship with Governmental Agencies
VIII. Defense of Competition
IX. Homologation Suppliers and Service Providers
X. Contracting Employees
XI. Policy Donations and / or Financial Contributions
XII. Internal Policy Against Fraud and / or Corruption
XIII. Freedom of Information Policy
XIV. Disclosure Channels
XV. General Provisions

I. Introduction

This Code of Ethics and Conduct describes the principles and values ??adopted by Tecturbo Compressors Parts and Services Ltda., Together with the parties involved in the management of the services provided; as well as to establish internal controls aimed at complying with the statutory requirements and requirements applicable to the organization, eliminate conflicts of interest that may affect the impartiality of its employees in the performance of their duties, guarantee the confidentiality of information that their members have access to and enable business continuity with the domestic and foreign markets.

II. The organization

Founded on 06/01/1992 Tecturbo® Compressores Peças e Serviços Ltda. specializes in the supply of parts and services for multi-brand centrifugal compressors, leasing, sale of new and remanufactured centrifugal compressors.
Acting throughout Brazil and Latin America, Tecturbo® has developed partnerships with national and multinational companies over the years. In tireless pursuit of perfection, in mid-1998 Tecturbo® obtained the ISO 9001 certificate with merit.

III. Mission, Vision, Values ??and Quality Policy

Mission:
We exist to contribute to the productive operability of our customers through the development of the best processes for the Remanufacturing of Compressors; as well as in the provision of Technical Assistance Services for them.

View:
To be a national reference in 2020 in Remanufacturing and Technical Assistance of Compressors.

Values:
• Integrity;
• Innovation and Quality;
• Reliability;
• Partnership with clients;
• Respect to employees and service providers.

Quality policy:
"To provide the market with efficient solutions in Compressor Maintenance, through continuous improvement of processes, aiming to meet the needs of our customers, compliance with legal requirements, health and safety of our employees and preservation of the environment."
By sharing our mission, vision, values ??and quality policy with our employees, customers and suppliers, we have consolidated our position as a reference in our market.

IV. Professional Behavior

The professional relations between the organization and its internal and outsourced employees must strictly observe the compliance with the legal requirements applicable to it, established in national and foreign labor laws, taking care of the work environment of dignity and mutual respect and respecting their privacy. Relevant legislation should be observed: Brazilian Law No. 12,846 of 2013 (Anti-Corruption Law and Administrative Improbability Act), the American Foreing Corrupt Practices Act (FCPA) of 1977 and the UK UK Bribery Act of 2011.

In order to eliminate potential conflicts of interests of the organization and employees, the following guidelines are established:

• Do not wish to obtain favors that may influence the performance of their activities in conflict with the ethical, moral and professional requirements established by the organization;
• Do not participate in activities that are of conflicting interest the scope of services provided by the organization or its working hours;
• If it declares itself to be ineligible to exercise its activities when it is possible to influence decision making as a result of personal relationships with customers, suppliers, partners and competitors;
• Do not accept personal invitations for accommodations, travel and other attractions that may damage the image and / or interests of the organization, without the approval of the Senior Management;
• Not participate directly or indirectly in works that are competing or complementary to the activities of the organization;
• Be aware that any type of moral or sexual harassment and actions of a discriminatory nature, regardless of religion, race, color, ethnic origin, economic / social condition, school education, physical appearance, orientation sexual, religious belief and political ideology.
• Not to send or to e-mail any material that has discriminatory, biased, obscene, pornographic or offensive content; as well as sending or forwarding emails with opinions, comments or messages that may disclose the image and / or affect the reputation of the organization or its clients.
• In order to preserve the physical integrity of its members, it is expressly prohibited the use of any type of alcoholic beverage or illegal drugs during the work, either in the organization's or our clients' environments;
• Do not use resources owned by the organization or customers to serve particular interests.

V. Confidential and Confidential Information

The employees of the organization are permanently aware to preserve all confidential or confidential information of internal origin or belonging to clients, who are bound on a professional basis, even after the termination of employment.
They are aware that they are the direct responsible for the integrity, preservation and maintenance of their confidentiality / secrecy of this information and that failure to comply with this requirement may result in criminal and civil probation for possible damage to the information owner.
Documents that contain confidential or confidential information must be identified; as well as, information transmitted electronically must observe the policy adopted by the organization, in order to avoid access by unauthorized persons to take notice of them.
It is prohibited and issuing copies of confidential and confidential documents outside the premises of the organization or on its responsibility; as well as its withdrawal without the official consent of a legal representative of the same or the client. Employees are responsible for maintaining control over the security of information stored or made available on the equipment (hardware) that is under their responsibility.
Obsolete documents containing such information must be destroyed as systematically adopted by Tecturbo Compressors or defined by the customer.

SAW. Intellectual property

Employees are made aware of the secrecy of the operational and technological processes adopted by the organization in the execution of its activities.
Any document, file or systems describing them are Intellectual Property of Tecturbo Compressores, and any type of disclosure must express electronic or physical authorization of the Senior Management.
Every physical or electronic documentary file (corporate network or personal computers) existing at Headquarters or in Client Work Sites used by employees in the exclusive execution of their activities is the property of the organization.
The Intellectual Property Legislation clearly states that any technological invention or model of operational management belongs exclusively to Tecturbo Compressores, when they occur from work performed during the Employee's bonding period.
Therefore, this requirement must be observed even after the employee's employment relationship, being subject to civil and criminal liability.

VII. Relationship with Public and Governmental Agencies

Employees of the organization are strictly prohibited from offering any kind of benefit (monetary values, meals, travel, entertainment, gifts or gifts) to public agents (including their family members) because of their position or function; as well as facilitating payments, that is, those intended to facilitate or accelerate the actions of public servants or with a position of trust in the performance of their duties or even to ensure compliance with the established deadlines.
The ethical principles established by the organization should be the guiding vector for the relationship with public bodies and / or governmental authorities; and all financial and accounting transactions must be fully and accurately recorded in the organization's ERP system.
It is prohibited the eviction by the employees of the organization of information requested by legal means by governmental organisms in the municipal, state or federal spheres. They should reflect the truths of the facts to be analyzed and should never be tampered with.

VIII. Defense of Competition

It is forbidden to the employees of the organization who exchange information or contact competitors to deal with matters that may influence: the market, price pricing, commercial conditions offered in public or private biddings, market information, conduct a marketed sale of services or equipment and make an agreement to restrict the performance of competitors.

IX. Approval of Suppliers and Service Providers

The approval of suppliers of products and service providers to be contracted, shall be based on the technical, financial, quality, socio-environmental, ethical criteria and compliance with applicable national and foreign laws established by the organization.

The Senior Management establishes that:

• Suppliers should treat the employees of the organization and its customers with dignity and respect;
• All suppliers requesting the exchange of confidential information must sign a Confidentiality Agreement in advance;
• The exchange of confidential information is limited to what is necessary to meet the performance requirements contracted;
• Suppliers will not share intellectual property, confidential information or any other information of Tecturbo Compressors which they may acquire with respect to the business;
• The unauthorized disclosure of confidential information of Tecturbo Compressors, whether accidental or not, must be immediately communicated to it;
• Suppliers shall comply with all applicable laws and regulations, including laws prohibiting discrimination, harassment in the workplace, use of child labor, slave labor or the like and the use of forced labor; as well as to prohibit any form of sexual exploitation;
• Service providers will not use, distribute and sell illegal drugs at the premises of the organization and its clients, nor will they perform their work under the influence of alcohol or illegal drugs.

X. Hiring of Employees by the Organization

Tecturbo prohibits the hiring of employees in conditions of forced labor, slavery or similar conditions;
as well as the use of child labor or any form of sexual exploitation of children and adolescents.
Actions that inhibit the practice of moral and / or sexual harassment should be implemented and monitored periodically.

XI. Policy on Donations and / or Financial Contributions

It is prohibited to donate and / or contribute financial resources to Political Parties or Entities related to them.

Donations and / or contributions to Charity Institutions or Social Programs may only be carried out, after research on their suitability with the society and public bodies responsible for issuing Licenses / Permits and / or Authorization of operation.

XII. Internal Policy Against Fraud and / or Corruption

The adequacy, reliability and transparency of the organization's Accounting, Tax and Financial Accounts are monitored by an external contracted organization, aiming at the prevention and detection of potential fraud and / or corruption events by employees, suppliers and clients.


XIII. Freedom of Information Policy

Tecturbo Compressores develops a working environment so that its employees, suppliers or service providers feel free to denounce any kind of practices that may represent a breach or potential violation of the guidelines established in this Code of Ethics and Conduct or that are in disagreement with the applicable national and foreign laws (referred to in item IV), condemning any form of retaliation to the complainant.
The anonymity is guaranteed to the denouncer, and the same can denounce directly to the High Direction via contact through the site of the Tecturbo Compressores Parts and Services Ltda in the tab OUVIDORIA.
The deadline for the beginning of the determination of the reported facts will be up to 05 (five) business days from the receipt of the same.

XIV. Disclosure Channels

This document will be made available through:

• Internal Audience (Employees and Service Providers): Training, Lectures, Electronic Document Access (LSI Quality) and Integration Process of new collaborators.
• External Public (Customers, Suppliers, Civil Society): Website (www.tecturbo.br).

XV. General Provisions

This document is effective for an indefinite period from the date of its approval, and must be easily accessible by physical or electronic means to all Employees.
Annually, the Code of Ethics and Conduct should be analyzed at the Critical Review Meeting (January), in order to detect the need to change and / or include new topics.