The code of ethics has the purpose of formalizing the rules and conducts that guide the company employees’ business and relations with suppliers, clients and the community. It must be followed in the daily exercise of activities, ensuring the integrity of TONON GROUP’s conduct.

Ethics

Ethics is a characteristic inherent to human action. Every human being has an ethical sense, which constantly evaluates and judges his/her actions, determining if they are good or bad, right or wrong, fair or unfair. Ethics, which aims at seeking common welfare, must be a personal and professional reference.

Ethics Committee

The Ethics Committee is composed of representatives appointed by the Group’s CEO, and the chairman is elected among the member by direct voice vote. The term of office is two (2) years, and after this period the CEO must appoint new representatives.

It is incumbent upon the Ethics Committee to accept and analyze information and ensure that actions will be taken in case of breach of the code and/or legislation in force. It also must revaluate periodically the code’s pertinence and topicality, clearing up doubts concerning its interpretation.

General Rules

TONON Group’s relations with several stakeholders must be based on respect and impartiality, avoiding conflicts of interests, non-arm’s length benefits or advantages of any nature and preserving company’s credibility.

All decisions taken must be based on ethical and technical appraisal, considering their impacts on stakeholders involved.

Human rights, sustainability, environment preservation, quality, safety and health must always be the assumptions underlying the preparation of Internal Policies and Procedures and guide the Company’s decisions and actions.

All information, actions and decisions must be based on ethics, veracity and transparence.

Community, Government and Society

All obligations with government agencies must be honored, through the payment of fees and taxes and the compliance with law in effect. The representatives of government agencies, provided that they are duly identified, must be received at TONON GROUP’s facilities professionally and honestly to discuss the matter of the visit, and the documents relating to the company’s business required by government laws must be made available whenever officially required.

Clients

Our commitment to our clients’ satisfaction must reflect not only in the respect for obligations assumed, but also in the search for solutions that meet their needs and demands.

Products must be sold in a clear and fair manner to all companies, not giving them any non-arm’s length benefits or advantages of any nature, respecting the agreements, rules and competitors.

Suppliers

The selection and engagement of suppliers are based on pre-established criteria (technical and manufacturing capacity), price, term, social responsibility practices, compliance with labor, occupational and environmental security and health laws in force. Contracting services or acquiring products made with child or forced labor are prohibited.

Tonon Bioenergia is allowed to terminate a business relation with a supplier whenever its values are disrespected and the legal, tax, environment and health and safety norms are not complied with.

Community

We must participate and contribute to the communities where we operate and monitor the impacts of our activities, contributing to their qualitative growth.

Shareholders

The shareholders’ interests must be safeguarded, keeping them informed about the company’s pertinent and relevant matters, providing them with level of dividends compatible with capital injected.

Trade Unions

Tonon Bioenergia respects free association, recognizes trade unions as legitimate representatives of professional categories and seeks to maintain a constant and open dialogue with them.

Communication

The company will provide its employees with all notices available through existing methods of communication: billboard, e-mail, internal electronic communication, payslips, leaflets and others.

Discrimination

Tonon Bioenergia does neither promote nor permit discrimination of any type, either of gender, age, race, relationship status, religion, sexual orientation, origin, political beliefs or any other prejudicial attitude.

Use of Alcohol and Drugs and Gun Possession

Narcotic or alcohol consumption is prohibited during the work time in the workplace.

Tonon Bioenergia does neither discriminate nor punish the employees who assume their addiction to alcohol and narcotics and offers help in their treatment and rehabilitation.

Guns of any type are not permitted in the company’s facilities, except for professionals expressly authorized.

Moral and Sexual Harassment

Sexual, economic and moral harassment or situations similar to pressure, intimidation or threats in relations between employees, regardless of hierarchical level, are not tolerated by the company.

The person who suffers moral or sexual harassment shall inform the ethics committee so that it can take the necessary measures.

Child and Forced Labor

Tonon Bioenergia does not tolerate or support child or forced labor under the area of its influence and will not have commercial relations with entities which have proven involvement with these matters.

Conflict of Interests

All employees must base their behavior on ethics, honesty and responsibility, avoiding getting involved in activities or matters of their personal interests, contrary to the company’s interests.

Everyone must act with transparence in order to avoid situations of conflict of interests, such as:

Use their position to benefit themselves and/or friends or relatives.

Engage third parties, including as service providers, either relatives or friends without evaluation of the ethics committee.

Omit information or forge it to comply with goals or obtain advantage for their own benefit.

Legislation and Judicial Branch

Tonon Bioenergia complies with legislation in force, following legal, tax, fiscal and labor requirements, and expects that its employees and suppliers do the same.

Any court of out-of-court notification or notice from legal authority relating to the professional activity must be immediately informed to the area’s management and the company’s legal department.

Sponsorship

Tonon Bioenergia stimulates community’s involvement with sports, culture, social initiatives and environmental awareness. For that purpose, the company makes feasible through sponsorship the initiatives it deems important and necessary to the community.

Donations

The external social investment is based on community’s actual demands and is aligned with Tonon Bioenergia’s guidelines, in order to support the projects which effectively foster social transformation. The company is committed to keep a permanent and open dialogue with the community it operates.

Gifts and Freebies

Tonon Bioenergia’s employees are not allowed to accept gifts and freebies for the commercial relationship inherent to their activities in the company. However, the employees are allowed to receive promotional materials, such as pens, personal organizers and supplies with the supplier’s logo, of low monetary value.

The employee is prohibited to make illicit payments and receive offers of money or personal advantages, either directly or indirectly, for any reason.

Nepotism

In case of hiring or promotion of employees, subordination relationship between first-degree relatives is prohibited. Exceptions must be previously approved by the management.

Company’s Assets

The company’s belongings, equipment and facilities are for exclusive use in its operations and cannot be used for personal purposes.

It is incumbent upon the employee to watch for the good use and conservation of the company’s assets under his/her responsibility. In case of termination of employment agreement, all materials must be delivered to the company in perfect condition.

Occupational Health and Safety

Occupational health and safety rules and procedures aim to provide employees with a safe and healthy work environment, through constant training, qualification and distribution of personal and collective protection equipment.

Tonon Bioenergia complies with legislation in force, and each employee is responsible to follow the health and safety rules.

Environment

The sustainable development underlies Tonon Bioenergia’s environmental policy, whose purpose is to minimize environmental impacts related to its activities and reaffirm the importance of its social-environmental and economic responsibility.

The company‘s industrial and agricultural process management policy aims to streamline the use of water, controlled fertigation, culture rotation, biologic control of pests and preservation of Areas of Permanent Preservation (in Portuguese, Áreas de Preservação Permanente, or APPs), disposing residues properly.

Information Confidentiality and Integrity

Information is also strategic for Tonon Bioenergia’s business and operations.

Showing or providing documents and information deemed commercial to persons not involved in the business is prohibited.

Use of Communication Electronic Systems

The entire procedure concerning hardware and software must be appraised by the Information Technology area (IT). The company expressly prohibits the so-called "warez software" and the execution of files of dubious or illegal origin.

Information processing must be mandatorily related to the professional activity. Accordingly, sending obscene messages and chain or fund-raising e-mails is prohibited. Any employee aware of this practice must notify the ethics committee.

Non-compliance

The employee who somehow considers that the Code of Ethics was violated must immediately inform his/her Supervisor and the Ethics Committee.

Compliance with the Code

All employees are responsible for the compliance with this code of conduct, and they must call guidelines contrary to the company’s principles and values into question, as well as inform the immediate supervisor and the committee as soon as taking cognizance of any irregularity.