A set of rules on Ethics and Compliance conducts the corporate integrity of Trilha Gold Capital, ensuring the fulfillment of laws, regulations, policies and procedures by the companies and individuals that make up the Group, partners and investors.

Trilha Gold Conduct Code

Application of the Conduct Code

The Conduct Code is intended to act as a compass, pointing the right direction as to what it means to be a Trilha Gold employee and, in this way, promoting behavior in accordance with the laws and regulations that govern our company. It is the foundation for a harmonic compliance approach, provides information about our main business activities and describes our individual responsibilities. It applies to all employees, regardless of home country and position held. Each company in the Trilha Gold group must implement and apply this Code in their day-to-day operations.

The Code provides guidance: it does not have the right answers for all situations, nor does it provide all the rules for an Employee to follow. The Code does not replace individual responsibility to exercise good judgment and common sense. In case of applicable laws that are stricter than this Code, the stricter standard will apply.

The Code represents our collective and individual commitment to conducting our business across the country in accordance with our values and relevant laws and regulations.

Your Responsibility

As an Employee

Corporate compliance means much more than adhering to internal and external rules; it means becoming an active agent of integrity, setting an example and respecting and living the values that guide our business. Each employee is individually responsible for compliance with the Code, in addition to applicable laws, regulations, policies and procedures. Trilha Gold places its trust in each of us to act towards reliable results.

As a Leader

If you are the manager of other people, you are expected to be an example to them. You must ensure that the individuals who report to you receive the necessary guidance, resources and training to enable them to do the job accordingly. Managers are personally responsible for creating an environment of trust in which people will feel safe to ask questions, raise concerns and report suspected violations without fear of reprisal.

With third parties

We expect third parties working with Trilha Gold to act in accordance with the Code’s principles. If you are involved in retaining any of these aforementioned third parties, it is your responsibility to ensure that they are aware of the Code.

Speak Freely

Your personal commitment to compliance is fundamental to the Trilha Gold success. If you believe someone has done, does, or may be about to do something that constitutes a violation of the Code or applicable laws, policies or procedures, it is your ethical responsibility to speak up about it. The longer it takes to resolve an issue, the worse it becomes.

Professional Ethics

O que é ética profissional e qual a sua importância no ambiente de trabalho? Professional ethics is nothing more than a set of rules, behaviors and values that aim to raise awareness and guide the attitude and behavior of professionals within an institution. In this sense, professional ethics is extremely important, both for companies and for professionals seeking a better engagement in the labor market.

The professional who demonstrates knowledge about ethical conduct stands out from other employees, gaining more respect, trust and credibility from their superiors and teammates.

Ethical conduct within the company

Having a more ethical posture also helps in the processes progress within the company, achieving goals, increasing productivity and improving the organizational climate and interpersonal relationships. When the company and its professionals value the ethical attitudes, such as temperance, respect, patience and humility, it is much easier to establish good relationships, proactivity, autonomy and innovation.

Concepts of professional ethics:

  • Honesty

Being honest is one of the main characteristics for any employee, regardless of their area of expertise, whether inside or outside the company. This quality, certainly, opens the way and helps the people to find the personal and professional success. It is essential to be honest with colleagues and other team professionals, earning respect and trust from superiors.

  • Respect the company hierarchy

Regardless of the friendly relationship existing between two people, it is necessary to respect the hierarchical relationship existing within the company. It is important that each person is valued for his/her achievements and reached goals, and not for a friendly relationship that may exist with someone who is at a higher level in the company’s hierarchy.

  • Own your mistakes

Mistakes happen, but it is essential that the employee knows how to recognize. At these times, it’s no use despairing or looking for justifications. Just make sure the error doesn’t happen again. The important thing is always to tell the truth.

  • • Never take credit for others accomplishments

One of the motivational pillars within a work environment is recognition, and for this professional growth to work, it is necessary to recognize the merit of others and give credit to those who really deserve it. This means never accepting someone else’s praise or merit. It is necessary to recognize the work of others and be honest about the authorship of the accomplishments of each professional within a team. Rewards must reach those who deserve it.

  • Have respect

Words have weight as much as attitudes. It is fundamental to be polite with everyone around you. Respect is essential and is part of the professional ethics standards. Although constructive criticism is sometimes required, this is always expected to be done in a polite way. It is necessary that each one treats the others as he/she would like to be treated.

Business and Competition

Commitment to Fair Competition

We are committed to gaining a competitive advantage through legal means only. Many countries around the world have laws that protect and promote free and fair competition. These laws regulate how we deal with competitors, customers, distributors and other parties. They are complex and can operate differently for each particular situation and require a different analysis for each product or country, and a different analysis when the Trilha Gold is the market leader.

Free and fair competition laws apply in all aspects of our activity involving competitors, whether in our presence in a trade association, collecting competitive information, or working with mutual customers. Trade associations should never be used as a forum to establish a common approach to a customer or to craft an “industry solution” to a business problem.

When collecting competitive information, always pay attention to applicable laws. Do not seek or accept confidential information from competitors. Do not use lies, misrepresentation or deception to encourage customers, suppliers or former employees of competitors to provide information that must be kept confidential.

No Corruption or Bribery

One should never seek to obtain favorable regulatory treatment for the Trilha Gold or attempt to advance Trilha Gold business interests by taking (or attempting to take) actions that may improperly influence anyone in favor of Trilha Gold. Many countries have specific laws against the improper influence or corruption of public officials. Pay special attention to this type of situation, where the country’s government regulates our products and is also a customer.

Bribes are anything that creates a sense of obligation to the recipient: money, gifts, entertainment, services or employment offers may be considered bribes. It can be difficult to distinguish a genuine gift from a bribe. It is very important that you do not offer, or accept, anything that could be construed as a bribe. Even gifts that are exchanged purely as a friendship can be misinterpreted and perceived as an improper advantage to create influence if given to a person or company in a position to offer help to Trilha Gold.

It is not considered acceptable to break the Code by claiming it is “normal” or “accepted” practice in a particular country to accept or offer gifts or money to close a business. If you have any questions about the appropriateness of a payment or transfer of any item of value, please contact your immediate superior so that they can speak to the Board of Directors before acting.

Insider Information

We do business with public companies (that sell shares in public offerings). If you receive information during the performance of your duties that is not accessible to the public and that may influence the share price of the other company, you must not use this information for your benefit, nor disclose the information to third parties or persons who are not involved in the project.

Copyright, Intellectual Property and Trade Secrets

Never infringe the copyright or intellectual property of others. Employees who previously worked for companies competing with Trilha Gold must take extra precautions regarding the protection of their former employer’s corporate and trade secrets. Never use corporate or trade secrets of former employers to conduct business for Trilha Gold.



Innovation and quality are fundamental pillars of our vision and our values. In order to maintain our success, Trilha Gold must react according to transitory market situations and work towards product excellence through efficient business processes. One of the objectives of quality management is the continuous improvement of products and business processes.

Fair and Decent Working Conditions

We are committed to providing ethical and dignified working conditions, and we respect the individual’s right to fair, polite and respectful treatment. We do not tolerate harassment or discrimination based on ethnic origin, race, age, gender, sexual orientation, religious beliefs, disabilities, or any other legally protected characteristic subject to compliance with applicable law. Decisions regarding hiring must always be made in cooperation with the local Human Resources department.

Health, Safety, Protection and Environment

Health, Safety, Protection and the Environment are integral parts of our operations. We have standards and policies designed to reduce the potential for exposure to occupational risks. We conduct our operations in accordance with applicable environmental, health, safety and security laws and regulations, company standards and best practices. We take all reasonable and practical steps to ensure a clean, safe, secure and healthy work environment. We seek continuous improvement whenever possible and economically viable. We regularly monitor our performance to ensure compliance with our standards and objectives, ensure our processes and equipment are top notch to prevent future accidents.


“Sustainable Development” is a globally accepted approach to sustaining economic growth without harming the planet or depleting its resources, providing improvements in the quality of life for its current and future inhabitants. Our success in a complex, rapidly evolving healthcare delivery environment depends on our ability to develop strategies that both industry and society can benefit from.

This means developing innovative solutions, providing a rewarding workplace, committing to being a trusted partner and supporting the communities in which we operate. Finally, providing innovation to our customers and partners will be our greatest gift to society.

Commitment to Human Rights

Trilha Gold recognizes its role in influencing the promotion and protection of human rights and in ensuring that our business operations do not contribute directly or indirectly to human rights violations. Likewise, the demonstration of respect for Trilha Gold’s Code of Conduct by third parties will have a direct influence on Trilha Gold’s decision to continue or renew business relationships with these third parties. In short, we adhere to the following expectations based on internationally accepted ethical standards:

  • Salaries are fair and competitive, based on performance and ethical conduct.
  • Employees are not subjected to unfair or unethical working conditions, including all forms of forced labor.
  • Labor standards are in accordance with the legislation of the jurisdictions under which we operate.
  • All of our operations provide a safe and healthy working environment. Workers are not subject to bad working conditions.
  • We do not discriminate in hiring, employment, wages, promotion, working conditions or any other occasion based on ethnic origin, race, age, gender, sexual orientation, religious beliefs or convictions, disabilities, or any other legally protected characteristic and subject to compliance with applicable law.
Working with Government Agencies

Trilha Gold employees generally need to deal with government agencies responsible for overseeing compliance with laws and regulations. Only employees authorized to interact with government officials should answer direct questions. Each Trilha Gold Group company must adopt procedures related to requests from regulatory or governmental authorities in accordance with Trilha Gold policies.

Privacy and Data Security

We protect the personal information that we handle in our business activities. We respect the privacy rights of our employees, customers and third parties. We collect and process data only for specific and legitimate business purposes, and we protect this data from unauthorized access. Whenever possible, we use anonymous or anonymized data so as not to identify individuals. Each Trilha Gold Group company and third parties that collect and/or process personal data on behalf of Trilha Gold must comply with our data privacy policies and adopt policies and procedures to ensure compliance with applicable laws, policies and procedures.

Relationships with Third Parties

We expect our suppliers, service providers and contractors to follow basic human rights principles that are compatible with ours, and to conduct their business in accordance with high ethical standards, in accordance with the principles adopted by Trilha Gold. Trilha Gold’s relationships with third parties are based on legal, efficient and fair practices. We expect the third parties we work with to abide by laws that mandate the fair treatment of workers, the provision of a safe and healthy work environment, and the protection of environmental quality.


Financial Integrity

Each company of Trilha Gold Group maintains its respective accounting books, records and accounts within the framework of an internal control system. All circumstances relevant to accounting must be fully and accurately documented and recorded in accordance with the Trilha Gold accounting standards and specific guidelines.

Each Trilha Gold Group company must have and insert a document retention policy that applies to the period of safekeeping and retention of financial books, records and accounts. Each Trilha Gold Group company must also put in place security measures against the risk that our company may be used by third parties for money laundering. Most countries do not tolerate money laundering practices, a criminal practice of filtering money from illegal activities through a series of legal transactions to “launder it” and giving the impression that this money comes from legitimate sources.

Separating the Company from Personal Interests

Personal interests should not influence your business judgment or decisions. You must avoid any situation where your personal interests are inconsistent with the interests of Trilha Gold, creating a conflict of loyalty. A conflict of interest is characterized when your personal, social, financial or political interests are placed before the interests of Trilha Gold, or if your external interests affect your objectivity, motivation or performance as a collaborator. Activities of relatives and close associates can also cause conflicts of interest. Even apparent conflicts can damage your reputation or the Trilha Gold reputation.

Always follow Trilha Gold’s sourcing and due diligence procedures when selecting individuals or companies to represent Trilha Gold, always disclosing potential conflicts.

Political Activity

There are legal restrictions on Trilha Gold support of political candidates or their involvement in political activities. In some cases, being a member of Trilha Gold may be interpreted as a contribution or activity of Trilha Gold itself, and Trilha Gold may be required to communicate its contributions, or in some cases, they may be prohibited by law.

For all of these reasons, if you are involved in personal political activities, care must be taken not to use the company time or resources, and not to engage in any political or lobbying activities using the Trilha Gold corporate name. Any decisions taken by a Trilha Gold Group company to support candidates for public office, or for political parties or specific political initiatives, must be approved in advance by the Board of Directors.

Inside of Trilha Gold

No Retaliation

Retaliation violates Trilha Gold policy. Trilha Gold strictly prohibits retaliation against anyone who raises a compliance issue in good faith or who helps resolve a compliance issue. Retaliation can lead to disciplinary action, up to and including dismissel.

Protecting Trilha Gold Property

The assets of Trilha Gold are valuable and must be protected against damage, theft and misuse. Generally, company assets such as equipment, facilities and documents should only be used for authorized activities.

Intellectual property is an important asset of the Trilha Gold. Our technology, our technical data contain large amounts of intellectual property, which is protected by legal security measures, which include patents, trademarks, copyrights and trade secrets. If disclosure of confidential information to third parties is necessary, the disclosure must be preceded by data protection steps, such as signing Confidentiality Agreements.

IT security

We all have a responsibility to use Trilha Gold’s network, computers and communication systems in an ethical and lawful manner. While occasional use of these systems is permitted, it must be appropriate and not interfere with everyday work. To the extent permitted by applicable law, Trilha Gold reserves the right to monitor accesses and use of all company systems. Therefore, there will be no privacy or confidentiality when accessing the company’s systems.

Social networks

We respect our employees’ legal rights to use social media. However, the Board manages Trilha Gold’s official social media activities. The same principles that apply to all Trilha Gold communications also apply to content and media channels. Please review and follow the Trilha Gold Social Media Guidelines, Trilha Gold trade policies, and local laws and regulations, all of which endorse ethical behavior and good judgment in the use of social media.

Who can help

Asking for Help and Advice

None of us know the answer to every question or what to do in every situation. You are responsible for conducting and learning about your work in accordance with the Trilha Gold vision and values, the Code, policies and procedures, and all applicable laws. But it is not always simple to determine what the “right answer” is. When there is uncertainty about some point of this Code or other policies and procedures, ask and seek advice, either to confirm that an action is in line with the Trilha Gold vision or to raise an issue that you believe is a breach of the Code, or even be illegal.

Contact Persons

The Board and Legal department are committed to ensure that the Conduct Code is consistently followed across Trilha Gold. The Board of Directors and Legal department also serve as a contact for employees, business partners and customers on matters related to the implementation of and compliance with the Conduct Code. Each company of Trilha Gold Group must also identify a local person, who will work together with the Board of Directors and the Legal Department to coordinate local endeavors, initiatives and training programs accordingly.

There may be times when you may want to speak to someone other than your direct superior. In such cases, you can contact Human Resources, the Legal department or the Board.

Which Law Applies?

Trilha Gold conducts business transactions across the country, and our employees are citizens of many different states. An important challenge for all of us is to understand how the laws of these states can apply to our operations. In some cases, there may be a conflict between the applicable laws of two or more states. When this type of conflict exists, it is essential to seek Trilha Gold Legal advice to understand how to properly resolve this conflict.