Code of Ethics and Conduct

I – INTRODUCTION

1. What is the Code of Ethics and Conduct?

The Code of Ethics and Conduct is the instrument in which the values of Ecobrasa Corporation Unip. Lda are inherent, hereinafter referred to as ECOBRASA, as well as the ethical principles and rules of conduct to which the company and its employees are subject and undertake as intrinsically theirs. ECOBRASA is a company that collaborates in the development of the community, having as strategy the social responsibility before the society in general, with great focus on its employees and clients, in order to contribute to the construction of a balanced society.

2. For whom is it intended?

This Code shall apply to all employees and other stakeholders of the company, as well as to their Representatives, and a term of commitment shall be signed after reading and understanding this Code.

2.1 Employees shall read, understand and apply the laws described in the Code and other procedures that apply to their work.

2.2 Suppliers shall read, understand and apply the laws described in the Code and its procedures that apply to the products and services provided/to be provided.

2.3 Leaders have an increased responsibility in relation to the Code. They are responsible for promoting a culture of honesty and integrity, creating a positive working environment in which people are treated with respect and dignity. This environment is built on the correct understanding and application of this Code and the laws in force.

3. Monitoring of the application of the Code

The Human Resources (HR) department shall be responsible for the implementation and monitoring of this Code of Ethics and Conduct, for its interpretation and clarification of doubts. It shall also be responsible for ensuring its compliance and for resolving any issue related to its non-compliance, taking the measures it deems appropriate. Any person may contact the HR department to request any clarification of a specific situation, submit a complaint or report any other irregular situation that may allegedly constitute a violation of the rules contained in this Code.

4. Key objectives

The Code of Ethics and Conduct is the expression of the business commitment to maintain the highest ethical levels of performance and quality assurance. The Code defines the company we want to be, the values that govern and guide it and the ethical conduct we expect from our employees. The Code expresses the conviction that ethical conduct is based on individual responsibility. With the current access we have to technology, capital and human work, an honest conduct and an upright behavior become an added value to the services and products offered by companies. In short, this Code has as a general objective to make known to employees, clients, public entities, suppliers and, in general, to the whole community, the principles and values by which Ecobrasa Corporation Unip. Lda regulates its activity, promoting growing relationships of trust between all, as well as strengthening the culture of ECOBRASA. The specific objective of this Code is to clarify, with the employees, the rules of conduct that they shall observe, through their decisions, behaviors and attitudes.

II – PRINCIPLES AND VALUES

1. Principles

1.1 Legal commitment: comply fully with the laws of the country, as a minimum starting point to be socially responsible.

1.2 Ethical behavior: the objective is to promote respect for ethical and professional conduct.

1.3 Consideration by the stakeholders: listen to and consider the requirements of persons or entities that have an identifiable interest in the activities of the organization. The objective is to provide stakeholders with the follow-up and performance they expect from us.

1.4 Respect for human rights and people: recognize the importance and universality of human rights, ensuring that the organization’s activities do not violate them. To value and acknowledge people for their qualifications and skills.

1.5 Environmental responsibility: a commitment to protect the environment through actions that encourage sustainable development, saving environmental and cultural resources for future generations.

2. Values

2.1 Ethics: Respect for professional behavior. Committing itself to create long-term economic value based on sustainable relationships with all our stakeholders. To establish relationships with principles of honesty, rectitude and transparency.

2.2 Appreciation: The recognition and appraisal by the qualification and competence of the employee

2.3 Pro-activity: Being able to anticipate trends, innovate and solve possible problems, proposing the best solutions.

2.4 Quality: The purpose of ECOBRASA is customer satisfaction and therefore it constantly seeks to improve its products and services.

2.5 Sustainability: It is committed to a management policy based on economic, social and environmental sustainability, as this is what gives us prospects for the future.

III – INTEGRITY IN RELATIONS WITH STAKEHOLDERS

1. Clients

Treat clients with professionalism, efficiency, respect, loyalty, good faith and dedication. To ensure equal treatment to all clients. To provide services in order to satisfy their needs, fulfilling the agreed conditions and commitments. Treat and protect adequately the client’s information to which it has access, through the provision of services, preserving its confidentiality and integrity.

2. Suppliers

Choose suppliers based on impartial, fair and transparent criteria, without granting privileges or favoritism. The selection shall be made in accordance with the commercial conditions, the quality of the products or services offered and the ability of the supplier to meet the agreed requirements.

3. Public Authorities

Ensure strict compliance with all national and international laws, regulations and norms in force in the regions where it operates. Provide the supervisory and inspection authorities with all the required collaboration or information within its reach.

4. Employees

Define human resources policies based on respect for the dignity, diversity and rights of each person. Treat each employee fairly and enhance equal opportunities for personal and professional development, including through rigorous and constructive performance evaluation and participation in professional training programs. Respect and promote the balance between the employee’s professional life and personal life.

5. Community

Ensure the social legitimacy of its business by strengthening lasting relationships with the communities where it operates and the integration of its interests in conducting and managing its business.

The relationship with the communities should take into account the specificities of the different realities and stakeholders involved, privileging and valuing the construction of social capital and the rescue of citizenship and self-esteem. Furthermore, it should encourage and strengthen local networks in order to promote dialogue and solidarity between the parties.

6. Competition

Respect market rules, promoting fair competition, avoiding any act that may prevent, distort or restrict competition in a sensitive way. Relate with competitors in a cordial manner promoting mutual respect.

IV – INTEGRITY IN LABOR RELATIONS AND LABOR STANDARDS

1. Child Labor and Forced Labor

ECOBRASA, both within the company and with its suppliers (including its subcontractors) and business partners, does not accept forced or slave labor or any other form of exploitation of children or adolescents.

2. Freedom of Association and the Right to Collective Bargaining

ECOBRASA respects free association, acknowledges union entities as legal representatives of employees and seeks constant dialogue. On the other hand, ECOBRASA encourages its suppliers and service providers to respect equally the right of all their employees to organize themselves through associations or unions, in accordance with the laws in force, and to maintain constant dialogue with such organizations. Negotiations and dialogue with the entities shall only be done by formally authorized persons.

3. Prejudice and Discrimination

ECOBRASA values diversity in all its relationships. Therefore, everyone should be given respectful, cordial and fair treatment by ECOBRASA’s employees, third parties, directors, suppliers and service providers or by those who represent it.

ECOBRASA does not admit discrimination or prejudice of any nature, whether of gender, race, religion, age group, sex, political conviction, nationality, marital status, sexual orientation, physical condition or any other in its relations. In the processes of recruitment, selection and promotion, candidates shall be evaluated solely for their skills and conditions to meet and adapt to the expectations of the position, and decisions based on prejudice, favoritism or even privileges of any nature shall not be accepted.

4. Harassment and Misuse of Power

ECOBRASA does not tolerate any misuse of power or harassment, such as sexual, economic, moral or of any other nature, nor situations that characterize disrespect, intimidation, physical violence or threat in relationships, internal or external.

Any person who considers himself or herself to be discriminated against, humiliated or the target of prejudice, abusive acts or disrespect promoted by employees, third parties, directors, representatives, suppliers or service providers of ECOBRASA shall communicate the fact to his or her direct hierarchical superior, using the contact channels made available. However, should they feel constrained to do so, they shall report the situation to ECOBRASA’s Management.

5. Fighting Corruption

ECOBRASA does not tolerate any form of corruption. The commission of acts of corruption shall be deemed as a violation of the rules and guidelines of this Code of Conduct.

ECOBRASA works continuously for business efficiency, respecting the principles of fair competition and acting in accordance with external mechanisms (laws, regulations, among others) and internal mechanisms to combat corruption, in order to ensure transparency as an integral part of the business model.

6. Health, Safety and Environment

ECOBRASA adopts a preventive approach to environmental challenges in its operations and business decisions, continuously seeking the reduction of energy consumption, the creation of sustainable processes and the development of initiatives that promote greater social and environmental responsibility.

All information relating to health, safety and the environment that may have impacts on ECOBRASA’s direct and indirect employees on the communities or on the environment itself shall be treated in a transparent manner.

The employee, direct or indirect, as well as the suppliers and service providers of Ecobrasa Corporation Unip. Lda should familiarize themselves with the policies, procedures and standards regarding health, safety, environment and information security in force in the company and comply with them.

V – GENERAL PROVISIONS

1. Nature and Scope

1.1 This Code of Ethics and Conduct establishes the principles and rules to be observed by employees in all activities of the Company, in the performance of the professional duties entrusted to them at all times.

2. Interpretation and Supervision

2.1 The Company’s Human Resources Department shall be responsible for clarifying any doubts that may arise regarding the application of this Code of Ethics and Conduct, and in general, the interpretation of its rules.

2.2 Supervision of the obligations established in this Code of Ethics and Conduct and compliance with them shall be the responsibility of the Human Resources Department.

3. Validity

This Code of Ethics and Conduct shall be immediately effective.

4. Communication Channels

To facilitate compliance with this Code of Ethics and Conduct, the Company has a confidential channel for reporting possible violations.

Reports can be made by email to denuncias@ecobrasa.pt , a channel managed by an external entity, and shall be resolved through a rigorous, transparent and objective procedure, safeguarding the confidentiality of the complainant