Compliance Policy

Introduction

Through this compliance policy, our company established the compliance principles, guidelines, and functions at all levels of TFX, as well as all our supported products, services, and 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 to full corporate responsibility and integrity 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 follow the company, and commercial representatives. Company standards reflect our culture and values, describe the principles that guide our behavior as a company (of a legal nature) help each member make good choices, and seek guidance when needed.

Legal Definitions

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

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

Any TFX employee identified as engaging in any form of retaliation or reporting that was not made in good faith may be subject to disciplinary action, including termination of employment. We remind you that all our internal operations are duly registered in the TFX-MC (TFX Management Console), including daily reports with all operations. In the event of fraud, the company, in accordance with compliance regulations, will promptly take the appropriate measures for each case.

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” that will manage the TFX Compliance Program;
Assure the “complete compliance structure” independent and autonomous management, as a segregated function, in order to guarantee impartiality and impartiality in all its actions;
Ensuring full access to any information, provoking or accompanying investigations when the “complete compliance structure” deems it necessary;
Ensure, to the members of the “complete compliance structure”, the confidentiality in the exercise of the function;
Provide the “complete compliance structure” with the minimum resources (material and human) necessary for the proper performance of its function.

Guidelines for the Compliance Structure

Ensure free and immediate access to senior management and regulatory and/or supervisory bodies, for the effective management of risks and irregularities or violations detected due to 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 compliance rules and procedures by TFX;
Guiding and assisting in the identification of risks (analysis of internal and external risks of the TFX), as well as in the definition and implementation of actions to eliminate and/or mitigate these risks;
Guide and assist in identifying the real causes and also in countermeasures, as well as monitoring their implementation to correct nonconformities and/or improvements identified in the aforementioned Compliance Program;
Ensure and provide guidance 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 that we 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 comes from above, that is, from the top management of TFX, and then spreads out as a solid organizational culture.

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

Technical Variables of our Compliance Policy

For our compliance to work correctly in all our products, services, and projects that we support, it is very important to list some extremely important categories that we use internally within the company, not only to make our processes efficient but also to guarantee that all policies, regulations, and laws in effect in each country we serve are adhered to. In practice, we use the control, established policies, calculated risks of all kinds, current internal and external rules, constant elaboration and updating of strategies, established standards for security and functionalities, requirements, and auditing that is generated, accredited, and validated by our artificial intelligence, which gathers all the necessary information into a complex report for human analysis and auditing. In summary: control, policies, risks, rules, strategies, standards, requirements, and auditing.