Code of Ethics and Conduct

1. PRINCIPLES GUIDING TRINITON

Triniton Industrial Engineering and Equipment Ltd. stands out in its sector as an ethical company and a reference in quality and innovation. Since its founding, the company has been guided by fundamental principles, such as transparency and commitment to employees, clients, and partners. Beyond being a business entity, Triniton’s products and services represent a brand recognized for trust and reliability.

Throughout its history, Triniton has built a solid reputation, inspiring confidence and becoming a benchmark in management practices. Conducting business with integrity, in accordance with laws and regulations governing our activities, is the foundation of this company’s operations. Respect for people is part of Triniton’s values, and this CODE OF ETHICS AND CONDUCT was created to emphasize the principles by which the company conducts its relationships. The guidelines, rules, and policies of this Code must be observed in the daily activities of all who are part of Triniton. It is everyone’s responsibility to ensure compliance. We hope it reinforces the corporate culture with ethical behavior consistent with the business environment and encourages the practice of these same principles in personal life, contributing to building a fairer and more responsible society.

Triniton’s philosophy is summarized in its mission, vision, and corporate values, which are fundamental to the company’s sustainability.

1.1 MISSION

To inspire people’s daily lives by pursuing technological innovation with the aim of generating efficiency, productivity, and operational excellence for our clients through high-performance solutions.

1.2 VISION

To be an industry leader in market solutions, adding value to our clients’ businesses.

1.3 VALUES

Interactive Leadership; Teamwork; Proactivity; Quality; Ethics; Respect.

2. OBJECTIVES

Considering transparency a crucial element in our procedures, we commit, through Triniton’s Code of Ethics and Conduct, to consolidating the main guidelines for the company’s management. Our purpose is to clearly establish the values guiding the organization’s actions in the institutional context, encompassing our employees, clients, suppliers, and partners, while explicitly highlighting our Mission, Vision, and Values.

The Triniton Code of Ethics and Conduct is a set of guidelines that all employees must follow to ensure the maintenance of its reputation as an ethical and integral organization. This document gathers the principles and policies of transparency and integrity that guide our actions, as well as establishing expectations regarding appropriate employee conduct.

WHO DOES THIS CODE APPLY TO?

Managers/Directors

Advisors

Employees

Interns

Temporary Staff

Apprentices

Suppliers (Triniton understands that suppliers and service providers have autonomy to establish their own rules, provided they are compatible with Triniton’s Code of Ethics and Conduct and fully observed).

3. COMPLIANCE

This Code is mandatory. It is of utmost importance that everyone understands and adheres to the philosophy that guides the behavior of the members of this organization.

Non-compliance may lead to disciplinary measures. Following the law is everyone’s duty, as well as acting with integrity and honesty in all matters, taking responsibility for our actions.

3.1 EXPECTATIONS FOR LEADERS

Triniton expects its leaders to disseminate and promote a culture of ethics and compliance. They must always set an example for their teams.

Managers and supervisors, due to the nature of their roles, must act as models for their teams, following the principles established in this Code. Leaders are responsible for guiding, motivating, and monitoring employees under their supervision regarding compliance with the Code. They must also provide support to employees who have questions or concerns regarding professional conduct.

As a leader, you must:

Ensure that people under your supervision understand their responsibilities regarding the Code and all relevant procedures;

Create a safe environment where employees feel comfortable raising questions or concerns;

Act to prevent violations of the Code or the Law by your team;

Consider employee behavior and compliance with the Code or other company policies when evaluating performance.

3.2 EXPECTATIONS FOR EMPLOYEES

Triniton expects all team members to understand and comply with the guidelines described in this Code, using common sense and honesty in their actions. If in doubt about any conduct, employees should ask themselves:

Does this align with the rules described in the Code?

Is it ethical and correct?

Is it legal?

Will it reflect well on me and the company?

If unsure, refrain from the action and seek guidance from management, HR, or the Legal Department.

3.3 FUNDAMENTAL CONDUCT RULES

Employees must:

Always act with integrity and honesty;

Treat colleagues with mutual respect, ensuring privacy, equality, and dignity;

Avoid conflicts of interest, real or apparent, between personal and professional matters;

Ensure all public communications made on behalf of the company are clear, accurate, truthful, complete, fair, and timely;

Strictly comply with laws, regulations, and government standards, as well as contracts establishing higher ethical standards;

Respect Triniton’s internal policies and regulations;

Encourage ethical and honest practices in the workplace;

Firmly reject any improper requests from criminal organizations or individuals engaged in illegal activities;

Promptly report any violations or suspected breaches of this Code to a supervisor, the Legal Department, or via the whistleblowing channel (email: aloetica.triniton@gmail.com
).

In uncertain situations, employees should ask themselves questions such as:

Is this action legal?

Does it comply with the Code and company policies?

Is my supervisor aware?

Have I consulted the appropriate expert?

Can I justify this action to my manager and the Board?

Would it withstand external investigation?

Could I explain this decision to my family or friends?

How would clients react?

Watch for expressions like:

“Just this once…”

“No one needs to know…”

“Everyone does it…”

“Better not to mention it…”

“Sometimes it’s easier to pretend we didn’t see it…”

3.4 RESPONSIBILITY

The Code of Conduct and the responsibilities assigned to leaders do not replace the personal commitment of each employee or the need to apply common sense. It provides guidelines to help employees understand Triniton’s expectations but does not cover every possible ethical dilemma. Employees remain responsible for their actions and should seek guidance when in doubt.

4. TRINITON’S ETHICAL COMMITMENTS
4.1 CORPORATE ETHICS

Triniton aims to operate with transparency and integrity, building credibility with partners, employees, suppliers, clients, regulators, and society, while seeking sustainable growth and profitability.

The company commits to:

Accurate reporting and transparency in documentation;

Honest and fair negotiations;

Clear and accessible communication;

Fair competition with integrity;

Protecting confidentiality and institutional guarantees;

Ensuring compliance with this Code.

4.2 SAFETY FIRST

Health and safety are everyone’s responsibility. Triniton invests in equipment, resources, standards, and training, while employees must comply with all safety laws and practices.

Employees must:

Report unsafe situations;

Use personal protective equipment (PPE) properly;

Avoid alcohol, drugs, or impairment at work;

Follow all safety procedures;

Participate in mandatory training;

Perform only tasks they are trained and authorized for.

4.3 ENVIRONMENT

Triniton acts to preserve the environment, promoting sustainability and quality of life. Practices include reducing pollution, recycling, and responsible resource use.

The company commits to:

Conduct environmental diagnostics;

Use resources responsibly;

Set and achieve environmental goals;

Minimize negative environmental impact;

Apply the “3Rs” plus a fourth “R” – Rethink consumption and impacts.

Employees commit to:

Acting with environmental awareness;

Reporting environmental hazards;

Ensuring suppliers comply with environmental and human rights laws;

Participating in sustainability initiatives.

4.4 INTEGRITY WITH ALL STAKEHOLDERS

Triniton adopts integrity as a core principle, ensuring respect, dignity, and fairness.

4.4.1 RESPECT AND DIGNITY

No sexual or other harassment;

No hostile work environment;

No forced or child labor;

Fair compensation and benefits;

Open and transparent communication.

4.4.2 PERSONAL DATA PRIVACY

Employee personal data is collected and used lawfully and only as necessary for business management.

4.4.3 SUPPLIERS AND SERVICE PROVIDERS

Honest and fair relationships;

Safe working conditions;

Selection based on professional criteria;

Compliance with ethical commitments.

4.4.4 CLIENT RELATIONS

Honest product offering;

Quality and transparency;

Timely resolution of damages;

Meeting agreed deadlines.

4.4.5 COMPETITOR RELATIONS

Honest and fair competition;

Avoid anti-competitive practices (price fixing, market division, refusal to sell);

Limit competitor interactions to legitimate business reasons;

Report any suspected illegal practices immediately.

4.4.6 GOVERNMENT RELATIONS AND BRIBERY

Comply with laws;

No bribery or illegal payments;

Use formal procedures for contracts;

Contribute to national development responsibly.

4.4.7 POLITICAL RELATIONS

Political contributions require prior Board approval;

Transparency in all political activities.

5. CONFLICTS OF INTEREST

Avoid situations where personal interests interfere with company decisions;

Disclose any personal interest in company transactions;

Obtain approval before proceeding with actions that may present conflicts.

6. INTEGRITY WITH THE COMPANY

6.1 CARE AND PROPER USE OF COMPANY ASSETS

Employees must safeguard company assets, using them responsibly and only for business purposes.

Examples:

Facilities, equipment, machinery, computers, software,

6.2. USE OF INFORMATION

Improper disclosure of information may put the company at a disadvantage, causing financial loss or damage to its reputation.

Employees must protect the company's information, which includes contracts, pricing information, business strategies, technical specifications, employee information, and financial data, as outlined in the Confidentiality Agreement that all employees sign upon hiring.

Triniton employees commit to:

Not disclosing non-public information to anyone outside the company, including family and friends.

Disclosure of Triniton's confidential or proprietary information may only occur with prior authorization from the company. This obligation remains even after the termination of employment.

Not discussing company business and processes in public;

Not sharing system access passwords;

Destroying documents before disposal.

6.3. CONCISENESS IN RECORDS

All company documentation and transactions must be recorded accurately and in a timely manner so that Triniton complies with legal obligations and maintains its reputation for integrity. Records must be complete, precise, and reliable, reinforcing our policy of transparency in all processes.

Triniton employees commit to:

Never falsifying any type of document;

Never misrepresenting the true nature of any transaction;

Always recording and classifying transactions in the appropriate accounting period and cost centers;

Ensuring budgets are supported by appropriate documentation and based on principles of honesty and transparency;

Ensuring all reports and documents submitted to regulatory authorities are complete and accurate;

Never engaging in illegal acts, tax evasion, or circumventing monetary laws;

Employees should strive for accuracy when preparing any information for the company. Honest mistakes may occasionally occur, but intentional misrepresentation or falsification of company records constitutes a violation of this Code.

6.4. WORKPLACE ATTIRE

Triniton values seriousness and common sense to ensure smooth operations and maintain the company’s reputation. All members of Triniton are considered the “business card” of the company, and their attire influences the professional image of both themselves and the organization.

All members of the company must dress appropriately and soberly to represent the company to all audiences. Sensibility is a competency demonstrating maturity, which is extremely important to Triniton. Adapting attire to the type of work and environment reflects a successful professional.

6.5. INTELLECTUAL PROPERTY

Intellectual Property includes a variety of assets: trademarks, industrial designs, domain names, copyrights, innovations, inventions, processes, products, projects, prototypes, ideas, financial, commercial, or market information, or any other non-material activity developed or contracted by Triniton. All proprietary rights to intellectual property created directly or indirectly by employees, temporary workers, interns, and apprentices—even if their roles are unrelated to research or inventions—are exclusively owned by Triniton, which may use them in whole or in part, with or without modifications, and may register them with official authorities in Brazil or abroad.

To protect Intellectual Property, employees, temporary workers, interns, and apprentices are prohibited from providing services to companies considered competitors during their relationship with Triniton.

All employees, contractors, suppliers, and clients must pay attention to protecting Triniton's intellectual property, particularly regarding the disclosure of images, videos, or any content related to the company’s equipment. Sharing or publishing materials about products, facilities, production processes, or other assets on social media or digital platforms is strictly prohibited without prior authorization. The Legal Department should be consulted whenever in doubt, as prior legal guidance is essential to evaluate potential legal implications and ensure confidentiality and protection of the company’s intellectual property rights.

6.6. FINANCES

All commercial decisions regarding Triniton’s future development must be based on accurate data, documents, and reliable reports. Dissemination of information and documents must be authentic, precise, and complete. Correct and truthful information disclosure is not only legally required but also essential for management, the Board, and other stakeholders, contributing directly to the company's reputation and credibility.

Integrity and transparency are core values at Triniton. All data must accurately reflect company transactions and events. This applies across all areas of the organization, particularly in financial and accounting matters. Triniton and its employees are responsible for:

Ensuring all transactions are properly authorized and recorded immediately, legitimately, and accurately;

Never misrepresenting the true content of any transaction;

Ensuring accounting follows current laws, regulations, and accounting standards;

Avoiding exaggerations, assumptions, or derogatory remarks in commercial records or other documents;

Not falsifying records or adopting creative accounting practices;

Demonstrating financial integrity when submitting or approving expense reports;

Ensuring all documents are securely stored, complying with internal and legal requirements.

7.0. SUSTAINABILITY

Triniton values sustainability and is committed to being a responsible organization, considering the interests of all members and stakeholders, promoting sustainability at economic, environmental, and social levels. Our goal is sustainable results, aiming for long-term growth based on honest and transparent practices.

7.1. TRANSPARENCY

Triniton ensures accurate, clear, and precise communication to all stakeholders through reports and documentation submitted to public authorities and internal communications. Those involved in preparing this information are responsible for ensuring its truthfulness and compliance with laws and internal controls.

7.2. COMPLIANCE WITH LAWS AND REGULATIONS

Triniton seeks to comply with all laws and regulations applicable to its business. Everyone must be familiar with regulations relevant to their professional activities, including internal policies and work instructions, and act accordingly.

If in doubt about compliance with legal obligations or internal policies, employees should seek guidance from their manager.

7.3. HUMANE WORKING CONDITIONS

Triniton prioritizes life above all else. Inhumane working conditions, as well as violations of integrity such as child labor or slave labor, are unacceptable.

8.0. RESPONSIBILITY IN BUSINESS CONDUCT

8.1. ILLEGAL PRACTICES, ANTI-BRIBERY, AND ANTI-CORRUPTION

Triniton strictly observes and complies with all applicable anti-illegal, anti-bribery, and anti-corruption laws and regulations. The company, directly or indirectly, does not receive, offer, donate, pay, promise, or authorize payment in cash or any other financial means that constitute conflicts of interest, illegal conduct, or corruption under Brazilian or any foreign law. Likewise, it does not agree to give or receive benefits from any person or entity and does not support any illicit business advantage for itself or third parties.

Triniton does not hire or maintain relationships with individuals or entities involved in criminal activities, corruption, money laundering, drug trafficking, or terrorism.

Triniton is committed to promoting ethical and transparent business practices and does not tolerate any form of bribery.

Bribery consists of offering, promising, granting, accepting, or soliciting any advantage in exchange for an illegal, unethical, or trust-abusing action. This “advantage” does not need to be financial and may include gifts, loans, commissions, fees, rewards, or other monetary or non-monetary benefits, such as charitable donations, services, trips, entertainment, hospitality, or employment opportunities. Even a mere promise or informal agreement to grant such benefits in the future may be considered bribery.

Laws related to corruption and bribery are constantly evolving, and violations are serious crimes that may result in severe fines or imprisonment for individuals, the company, and its directors. Triniton employees are strictly prohibited from participating in any bribery, directly or indirectly, with government officials or private companies.

Preventive measures include:

Conducting due diligence on third parties to verify their integrity, reputation, and honesty;

Including appropriate clauses in contracts with third parties to ensure ethical behavior;

Ensuring all fees and expenses paid to third parties are justifiable and correspond to legitimate services;

Maintaining detailed and accurate financial records of all payments to third parties.

If any employee is asked to offer or receive a bribe or identifies a suspicious request, they must immediately report it to their supervisor or via the whistleblowing channel (email: aloetica.triniton@gmail.com
), with follow-up to the HR and Legal Departments.

8.2. GIFTS AND PRESENTS

Special care must be taken regarding the receipt of gifts, as accepting them for personal gain is unethical and undermines credibility. Gifts should reflect impartiality and not influence the company’s decisions. Employees must exercise good judgment when receiving gifts. Monetary gifts from suppliers, third parties, or service providers are strictly prohibited.

8.3. RELATIONS WITH GOVERNMENT AGENCIES

Triniton complies with all applicable laws in Brazil and other countries where it operates, promoting open and constructive dialogue and improvements within its area of activity. Employees responsible for audits or inspections must cooperate fully with public officials, maintaining ethical conduct and avoiding any undue advantage or privilege.

8.4. RELATIONS WITH LABOR UNIONS

Triniton respects freedom of association, recognizes unions as legal representatives of employees, and maintains ongoing dialogue on labor and union matters.

8.5. RELATIONS WITH CLIENTS/CONSUMERS

Triniton invests in and dedicates its teams to producing high-quality products that generate value and satisfaction for clients and consumers. Relationships must be based on integrity, honesty, and mutual respect. The company strives to meet all legal rights of clients and consumers, aiming to exceed expectations for products and services.

8.6. RELATIONS WITH SUPPLIERS OF MATERIALS AND SERVICES

Suppliers must be selected carefully, considering the best cost-benefit ratio, and must comply with Triniton’s standards. All negotiations must be based on trust and transparency.

8.7. RELATIONS WITH COMPETITORS

Fair competition enables market development and social benefits. Triniton must make its own commercial decisions based on loyalty and fairness, strictly complying with laws and regulations.

9.0. COMMUNITY ENGAGEMENT

9.1. POLITICAL PARTICIPATION IN ENTITIES

Political affiliation is an individual choice. Triniton maintains a neutral stance and encourages employees to remain impartial at work. Company time, resources, name, brand, or assets must not be used for political purposes.

9.2. VIOLATION OF THE CODE OF ETHICS AND CONDUCT

Employees are encouraged to report potential or actual violations of the Code of Conduct. Violations should be reported to a direct supervisor, another administrative representative, the Legal Department, or the whistleblowing channel (email: aloetica.triniton@gmail.com
).

Triniton treats all reports seriously, conducting confidential investigations and applying corrective measures as appropriate. Cooperation from employees is required, and retaliation against good-faith whistleblowers is strictly prohibited. Legal action may be taken for violations that also constitute criminal offenses.

9.3. MANAGEMENT OF THE CODE OF ETHICS AND CONDUCT

Leadership ensures understanding of the Code and manages non-compliance reports. Every employee is responsible for supporting Triniton’s principles. The Code is published to reaffirm commitment and provide guidance, ensuring values are reflected in all activities.

10. COMPLIANCE WITH LAW No. 13.709/2018 (LGPD)

As a data controller, Triniton is committed to the security, privacy, and integrity of personal data collected and processed under the Brazilian General Data Protection Law (LGPD), Law No. 13.709/2018. This ensures ethical, transparent, and secure data handling, fostering trust with data subjects.

10.1. DATA PROTECTION STANDARDS AND BEST PRACTICES

Triniton implements standards to ensure LGPD compliance, including:

Clean Desk Policy: Employees must keep work areas organized, preventing exposure of sensitive documents;

Screen Lock Activation: Mandatory when away from the workstation to prevent unauthorized access.

10.2. PERSONAL DATA PROCESSING: PRINCIPLES AND OBJECTIVES

Data processing adheres to LGPD principles:

Purpose: Data collected and processed only for legitimate, specific, and informed purposes;

Necessity: Only strictly necessary data is collected;

Transparency: Clear and accessible information for data subjects;

Security and Prevention: Technical and organizational measures protect against unauthorized access, destruction, loss, or alteration.

Data subjects have the right to participate and report potential violations via email or a form on Triniton’s website.

10.3. DATA STORAGE AND RETENTION

Personal data is stored on company servers with no unauthorized third-party access. Data is retained as long as necessary to fulfill its purpose or until the data subject revokes consent.

10.4. INCIDENT RESPONSE AND REMEDIATION PLAN

In case of a data breach, Triniton activates its Incident Response Plan, which includes:

Investigation by the Ethics Committee;

Containment measures and notification to affected data subjects.

10.5. IMPLEMENTED SECURITY MEASURES

Security measures include:

Access Control: Only authorized employees may access personal data;

Updated Antivirus: Protection against digital threats;

Regular Backups: Ensuring data integrity and recovery;

Firewall and Anti-spam: Defense against cyberattacks and phishing attempts.

10.6. EMPLOYEE CONDUCT REQUIREMENTS

Employees must ensure:

Confidentiality: Access only with authorization;

Integrity: Data remains correct and unaltered;

Availability: Information is accessible when needed.

10.7. LGPD OBJECTIVES AT TRINITON

Protect data subject rights;

Strengthen trust through transparency;

Ensure secure data processing and compliance.

11. WHISTLEBLOWING – COMMITMENT TO TRANSPARENCY AND ETHICS

Triniton provides a whistleblowing channel via email (aloetica.triniton@gmail.com
) and a form on its website, enabling employees, partners, and stakeholders to report unethical conduct, misconduct, or fraud. Reports can be anonymous or identified.

11.1. TRUST AND CONFIDENTIALITY

The Ethics Committee manages reports, ensuring impartiality, confidentiality, and integrity. Only committee members access information, maintaining whistleblower protection.

11.2. RESPONSIBILITY TO REPORT

All employees must report violations, misconduct, or potential fraud. Silence may imply complicity. Reports should be made even in case of doubt.

11.3. INVESTIGATION PROCESS

Upon receiving a report, the Ethics Committee analyzes, collects evidence, conducts interviews, and issues a final opinion, including recommendations for sanctions.

11.4. POLICY OF CONSEQUENCES

Sanctions may include:

Warning;

Suspension;

Termination;

Criminal reporting.

11.5. INCENTIVE TO IMPROVE THE WORK ENVIRONMENT

Triniton promotes ethical awareness through training and lectures to prevent misconduct.

11.6. COMMITMENT TO SERIOUSNESS AND CONFIDENTIALITY

Employees are encouraged to report suspicious conduct to maintain an ethical, safe, and transparent environment.

12. NON-RETALIATION POLICY

Triniton ensures all whistleblowers are protected from retaliation. Retaliation includes dismissal, salary reduction, change of duties, threats, or discrimination.

12.1. DEFINITION AND COMMITMENT

Retaliation in any form is strictly prohibited.

12.2. WHISTLEBLOWER PROTECTION

Good-faith reports are protected, including anonymity if requested.

12.3. CONSEQUENCES FOR RETALIATORS

Sanctions for retaliation: warning, suspension, termination, or legal action.

12.4. POLICY APPLICATION CONDITIONS

Applies to all employees, contractors, and partners, covering all reporting channels. Protection does not extend to malicious or false reports.

12.5. INCENTIVE TO CONSCIOUS REPORTING

Reports should be honest, detailed, and in good faith.

12.6. CONCLUSION

Non-retaliation ensures ethical conduct, safety, and transparency, strengthening trust in the whistleblowing system.

13. REVIEW OF THE CODE OF CONDUCT AND COMPLIANCE MANAGEMENT SYSTEM

Triniton is committed to continuous improvement of ethics and compliance. The Code is reviewed annually or as needed, with audits verifying effectiveness and identifying gaps.