INTRODUCTION

TECNISA, aware of the relevance of ethics in professional relationships in the communities where it operates, and of the actual benefits derived from the commitment and execution of the principles and guidelines of ethical conduct, sets forth and releases this document.

Taking into account the prominent position that TECNISA holds in the Brazilian market, within the principles of market segmentation, as well as the current transformations imposed by the globalization process as a result of the economic opening and the technological development, it became necessary to formalize the principles and guidelines of ethical conduct applicable to all collaborators of the organization to guide their actions, professional conduct and social attitude towards all those with whom they have a relationship.

This present code of ethics contains the principles and guidelines that must be observed by TECNISA´s collaborators, so that we may reach high operational and ethical standards in the performance of our activities.

BASIC PRINCIPLES

This present code of ethics systematizes the essential values practiced in TECNISA´s relationships with clients, accredited suppliers and employees.

TECNISA values the ethical thought and expects its collaborators to guide their actions by the values contained in this code, as follows:

Article 1 - This Code of practices and ethics regulates the employees´ duties and rights in their reciprocal relationships and their relationships with TECNISA´s clients, suppliers, and collaborators.

Article 2 - The employee will act according to the precepts of this Code and to the Internal Rules related to the ethics and information security.

Article 3 - The employees who infringe this present Code will be subject to the disciplinary penalties provided for herein;

COLLABORATORS´ DUTIES

Article 4. All collaborators must:

• Ensure TECNISA´s reputation, avoiding public criticism in inadequate forums as to its performance, as well as its policies and Internal Rules;
• Respect also the Code of Ethics in what concerns their academic education;
• Engage permanently in their personal and professional improvement, observing all the guidelines as to the proper use of resources and information;
• Keep the confidentiality of the information and details of TECNISA´s clients and of the organization itself, as if it were confidential information of their own individual interest;
• Never express their opinions or suggest measures to TECNISA´s clients, before obtaining an endorsement from the department in charge and without having technical security and reliance in the data they possess;
• Whenever possible, suggest the best solutions to TECNISA´s clients, and indicate TECNISA´s products and services as a first alternative;
• When detecting a failure in Information Technologies, never censure it before the client, but inform this to the IT department, for assessment and measures to be taken;
• Act with absolute impartiality and not take any personal considerations into account;
• Respect and accurately applying the methodologies and rules disseminated by TECNISA;
• Use the information technology tools (Desktop, Notebooks, Laptops, printers, etc.), which contain information about TECNISA or about clients based on the security rules set forth;
• Do their best to maintain a friendly and respectful relationship with TECNISA´s employees and collaborators, avoiding to expressing personal opinions concerning the technical and administrative staff;
• In the event of removal from the post or discharge from professional duties at the organization, transfer to their deputies or appointed persons all the information and materials related to the works in progress, keeping the data and works duly updated in TECNISA´s Network Servers;
• Perform their professional activities with competency and diligence, seeking technical improvement and permanent updating in what concerns the legal rules, regulations, internal rules, circulars and other instructions provided for by TECNISA´s Security Policy, pertinent to the activity performed;
• Perform the functional attributions that are assigned and trusted to them with strict moderation, conducting their work with honesty, loyalty and efficiency, abstaining from doing it in a manner that is contrary to TECNISA´s interests;
• Ensure the maintenance of TECNISA´s equity and image, preserving the materials, the working tools, the security of facilities, furnishings, equipment and software available for use;
• Maintain a friendly and respectful relationship with the group of collaborators, avoiding expressing personal opinions about the performance and technical qualification of their colleagues before TECNISA´s internal and external public;
• Maintain the confidentiality of any information, whether in writing, orally or digitally about TECNISA or its clients and suppliers, in what concerns businesses, records, operations and results, or any other information which is not the purpose of public awareness, adopting the appropriate measures so that only authorized persons have access to such information, aiming at preserving the confidential information;
• Wear appropriate clothes and use appropriate language when serving clients, making use of common sense and always taking into account the type of occurrence;
• Promptly apply all the recommendations of the Internal Rules or published as TECNISA´s specific procedures Handbooks, paying special attention to the ones concerning information security, always adopting the clean-screen policy when stepping away from their work station and keeping their tables clean at the end of their working hours;
• Disclose and inform all employees, including goods suppliers, service providers, and outsourced employees about the existence of the guidelines for ethical conduct and security contained in this code, encouraging its full compliance;

RESPONSIBILITIES

Article 5. The collaborators´ responsibilities are:

• Contribute to the harmony of the partnerships executed by TECNISA, seeking to keep a conciliatory attitude, and not inciting disagreements between partners, clients, suppliers, and others involved;
• Fill in correctly system screens, documents, reports, and supply data, such as those required by TECNISA´s methodologies and Rules;
• Provide a courteous and efficient client service, offering clear, precise and transparent information about all the Information security processes applied to their particular data;
• Keep their personal finances compatible with their income, avoiding situations that may affect negatively TECNISA´s image, or their own personal or professional image;
• Act in a socially responsible manner, maintaining a high community spirit, and endeavor efforts towards preserving the environment;
• Ensure the application of the Information Technology tools and provide clients with the necessary information so that they are convinced of the Security Policy adopted by TECNISA, as well as of the means through which their anonymity and privacy are kept;
• Return to TECNISA the resources and materials provided fully or partially by TECNISA for use in their activities, whenever requested;
• Honestly acknowledge the mistakes made and communicate them immediately to TECNISA;
• Refuse, from TECNISA´s clients and suppliers, any goods or payment on any account in an amount higher than fifty reais (R$50.00), whether or not on an occasional basis, as a way to express gratitude or supposedly obtain an advantage;
• Inform their immediate superior of any situations that may typify as an infringement to the ethics and security guidelines contained in this Code, and, if necessary, take the issue to TECNISA´s Ethics and Security Committee;

PROHIBITIONS

Article 6. TECNISA´s employees are forbidden to:

• Make use of any illegal procedure or stratagem, aiming at obtaining an advantage for TECNISA, for themselves or for others;
• Deliver promotional material and/or advertise products that compete with those of TECNISA;
• Charge any private fees from TECNISA´s clients;
• Use for private purposes, reproduce and commercialize any of TECNISA´s documents, methodologies, resources, or software, without the organization´s express authorization;
• Inform via private email or on the telephone, or publish on the Internet, information about TECNISA or its clients, including quoting names, without the organization´s previous authorization;
• Make use of inside information, i.e., information obtained by virtue of their job position, performance of duties or otherwise, to carry out any market operation, by themselves or by third parties under their instruction, aiming at obtaining an advantage for themselves or for third parties;
• Subject other employees to intimidations, sexual or moral harassment, or embarrassment of any nature;
• Accumulate private activities that conflict, or develop private activities or businesses that compete with TECNISA or that interfere in the working hours devoted to TECNISA, including, but not limited to, service rendering, advisory services or businesses with clients and suppliers;
• Pressure, incite, discredit, for any reason, TECNISA´s clients, suppliers, service providers, employees or partners through any means of communication (oral, printed, internet, optical or magnetic media, etc.);
• Use for private purposes resources, software, technologies, methodologies, know-how and other information developed, obtained or owned by TECNISA;
• Express themselves orally, in writing, on the Internet or through any other media, or sign any documents on TECNISA´s behalf without the Board of Executive Officers´ authorization;
• Convey or transfer to third parties any information, documents, financial reports, accounting records, strategies, clients´ records, and/or advertising containing secret, confidential data, or data that regards exclusively TECNISA´s professional interests, through any means, as set forth in TECNISA´s Security Policy.

RIGHTS

Article 7. The employees´ rights are:

• Identify themselves to clients as TECNISA´s employees, whether or not showing their business card;
• Point out to TECNISA´s technical groups, faults, improprieties or the need of expansions, changes or adaptations in information technology tools and in the methodologies to be applied;
• Receive payment for the work executed as established by TECNISA;
• Inform TECNISA immediately in case they are not given the minimum conditions to perform their work well;
• Defend themselves before TECNISA, whenever they feel they have suffered some kind of damage or injustice due to the application of inappropriate resources;
• Use tools made available by the information technology department for researches (browsing on the Internet) and use of emails, in compliance with the Internal Rules;
• Receive follow-up and the necessary technical support for performing their activities well;
• Possess identification, security password and cryptographic code that ensure their privacy and exclusive identification on TECNISA´s Local Network;

DISCIPLINARY SANCTIONS

Article 8. When TECNISA is aware of procedures, on the part of employees, representing infringement to the Internal Rules and of this Code, the issue will be forwarded to TECNISA´s Ethics and Security Committee, which will analyze the case and take the appropriate disciplinary measures.

Article 9. The employee will be formally notified by TECNISA to present his/her defense, under the penalty of the imputed facts being considered as true.

Article 10. The procedures adopted in cases of infringement to this Code will be conducted by the Ethics and Security Committee, which will also be responsible for the final recommendation of the respective sanctions for approval by the Board of Executive Officers.

Article 11. The penalties applicable to the employees may be summarized in warnings, temporary suspension, definitive removal from the post and civil or criminal liability, if this is the case, as follows:

Penalties:

Fault: The infringement to any article of this Code will be deemed as fault, which at the discretion of TECNISA´s Ethics and Security Committee, even though it has occurred, it did not cause great financial losses or damages to the company´s image.

Penalty: Formal warning of temporary suspension at the Committee´s discretion and with the authorization of the Board of Executive Officers.

Serious Fault :  The infringement to any article of this Code will be deemed as serious fault, which, at the discretion of TECNISA´s Ethics and Security Committee, causes small financial losses or damages to the company´s image, or should occur again any fault committed previously.

Penalty: Temporary suspension with the Board of Executive Officers´ authorization.

Very serious fault:  The infringement to any article of this Code will be deemed as very serious fault, which, at the discretion of TECNISA´s Ethics and Security Committee, causes great financial losses or damages to the company´s image, or should occur again any serious fault committed previously.

Penalty: definitive removal from the post with the Board of Executive Officers´ authorization.

ETHICS AND SECURITY COMMITTEE

Article 12 – The Ethics and Security Committee shall be notified by employees, suppliers, service providers, clients or any other third parties subject to a relationship with TECNISA of any fact that may typify as an infringement to the guidelines of this Code or for analysis and resolution on the occurrences. Every notice must be forwarded by email at eticaesegura@tecnisa.com.br .

This Code is open for collaborations to supplement its wording. Make your suggestions to the IT.

Last Update: April 08, 2010