The Internal Ombudsman is the means by which anyone can report violations of laws and this Code. With the continuous commitment of everyone, we will be able to increasingly elevate ethical conduct and promote a healthy work environment, fair competition and maintain a positive image of EMICOL in the market.

This Code establishes the obligation to report any violation of laws and this Code applicable to all those who work, conduct business, or provide services to EMICOL. It is important to emphasize that communication to the immediate manager does not exclude the need for communication through the Internal Ombudsman.

We know that reporting a violation may not be an easy decision. However, the Internal Ombudsman is a safe and anonymous way to report your ethical concerns. We guarantee the confidentiality of the information and that no whistleblower will suffer any form of retaliation, even if in the end the report proves to be wrong.

Everyone's confidence in the applicability of this Code is fundamental. By reporting misconduct, we elevate ethical behavior.

Our Internal Ombudsman is also open to answering questions about the Compliance of Conduct (Compliance).

WHAT CAN BE REPORTED?

Any suspected ethical violation, examples:

• Any crime: robbery, theft, fraud, bribery or corruption, including those committed in other countries where EMICOL operates.
• Harassment and moral, sexual abuse, bullying, violation of human rights or prejudice of any nature (regarding race, color, religion or belief, sexual orientation, social status, nationality, age, political-party option or any type of mental disability or physics);
• Acts of physical or verbal violence (offensive and racial and sexual discrimination) and use of profanity (expletive);
• Fraud and falsification of documents, records, etc;
• Lack of application of labor legislation;
• Any acts carried out even outside the company's premises that may have negative effects on the company's image, under the terms of labor legislation.
• Failure to comply with any legal obligation, by action or omission of the person responsible;
• Favoring Employees, Customers or Suppliers to obtain an undue advantage for themselves or others.

HOW TO MAKE A COMPLAINT?

EMICOL makes available to anyone who becomes aware of violations of laws and the Code or who have doubts as to their meaning, intention or application, must expose such situations or resolve their doubts promptly, which can be done through the following channels:

• EMICOL Website: www.EMICOL.com– Ombudsman Channel
• Email: [email protected]
• Third Party Phone: 0800 364 2651 - Option 2
• Third Party Form: https://doctorsac.com.br/ouvidoria_EMICOL.asp
• Internal Ombudsman Box: DES

Note: The boxes are located in EMICOL's internal areas, with restricted access to the Conduct Compliance Committee.

When reporting your suspicions, we ask that you send us as much information as you have at your disposal, for example:

• Who is involved?
• What is the fact to be reported?
• How did you become aware of the fact?
• Where did the event occur?
• When did it happen?
• Is it still happening?

Reports can be made anonymously through our Reporting Channels. If you choose to report via email, we guarantee anonymity and discretion during the investigation.

EMICOL's Compliance Compliance Committee is responsible for investigating complaints. Violations that are not covered by the Code will be taken to the Committee, composed of the Vice President with the support of Human Resources.

Complaints made by all those to whom the Code applies will play an important role with EMICOL. That way we can deal with issues quickly before serious consequences can arise.

NO ACHIEVEMENT

It is important that everyone promotes a work environment in which everyone can communicate their concerns about ethical issues without fear of retaliation.

Retaliation against anyone who raises concerns or concerns about misconduct will not be tolerated. No Employee will be disciplined for reporting concerns about possible violations of law and this Code.

CALCULATION OF COMPLAINTS

Upon receipt of the complaint, the Conduct Compliance Committee will carry out all the necessary analyzes to investigate the suspicions.

DISCIPLINARY MEASURES AND COMMUNICATION TO THE COMPETENT AUTHORITIES

Each ethical violation will be treated individually, and may generate: verbal and formal warnings, termination of employment or services; civil or criminal proceedings may apply to any and all Employees who violate the Code, applicable law, or company policies and procedures.

Sanctions applied to Employees will follow the labor legislation, which provides, as the case may be, warning, suspension or dismissal, always taking into account the proportionality of the punishment against ethical deviation.

For Business Partners the applicable penalties will be:

• According to the contract, we will follow what is described for ongoing business and/or;
• Exclusion from our Suppliers base, with the impossibility of providing services or goods to EMICOL, when there is no negotiation agreement in force.

Compliance with this Code is an integral part of the employment contract of all Employees, as well as the contracts with our Business Partners. In any case, EMICOL has a legal obligation to report criminal and/or administrative offenses to the competent authorities.

BACK TO START

EMICOL believes that with a healthy and inclusive work environment, we will better perform our duties. And everyone should collaborate to maintain a healthy work environment, treating each other with respect, warmth and professionalism.

EMICOL has total confidence in its Employees, believing in the commitment of each one to elevate EMICOL to the highest levels in the market.

For EMICOL, respect must exist between all hierarchical levels, regardless of skin color, age, ethnicity, gender, physical conditions, etc., with the mission to maintain respect for human dignity.

DIVERSITY

EMICOL values ​​the diversity it maintains in its workforce.

In this way, any type of prejudice and discrimination directed against Employees, Customers, Sales Representatives, Business Partners and/or Service Providers is repudiated. EMICOL does not accept any act of discrimination or intolerance in relation to:

• Breed
• Religion
• Nationality
• Age
• economic capacity
• political positioning
• Genre
• Ethnic origin
• Religious Freedom (Individual needs can be communicated to HR)
• Physical or psychic functional diversity, etc.

EMICOL also does not accept any type of harassment and/or moral, sexual abuse, psychological oppression, offenses (bullying) or any other conduct that generates an intimidating and offensive environment to the personal rights of its Employees, which is why EMICOL does not accept :

• Sexual or moral harassment;
• Abuse of authority;
• Acts of physical or verbal violence (offensive and racial and sexual discrimination) and use of profanity (expletive);
• Propagation of rumors and/or comments that may harm the image of employees, the company or its members;
• Tolerate, encourage, participate and/or be silent in the face of occurrences of misconduct that violate human dignity.

Here we respect the differences!

WORKPLACE SAFETY

EMICOL values ​​the well-being and safety of its Employees.

It is our obligation to provide all equipment and enforce the obligation to use it to protect everyone's health.

It is the responsibility of everyone who enters EMICOL's facilities to respect and comply with safety standards.

• All Employees are required to comply with occupational health and safety standards, avoiding any risk to their own physical integrity, to the Company and to the safety of other Employees. Likewise, it is the responsibility of the Host Employee that the visitors authorized by him/her respect the work safety standards during their stay at EMICOL's premises;
• It is not allowed to enter any EMICOL installation carrying firearms or bladed weapons, except in the exercise of their function; and
• It is inadmissible to perform work activities under the influence of alcoholic beverages or drugs not prescribed by a health professional.
• It is prohibited to take pictures of the external parts as well as the internal parts of the company without express authorization. The procedure puts industrial secrecy and property security at risk.

WORKING DAY

EMICOL has the obligation to comply with all provisions of the labor legislation. It is the obligation of all Employees to respect and comply with the laws relating to working hours.

It is essential that Employees read and sign the Bank of Hours Agreement, when applicable, as well as the working hours compensation agreement, before starting their activities at EMICOL.

HOME OFFICE

In specific situations and according to its function, EMICOL will allow the possibility of remote work. In this modality, we must continue to ensure the application of the standards contained in this Code, the maintenance of processes and productivity, as well as the safety of the Know How of EMICOL. Even in remote work, the rules on intellectual property set out in this Code apply (see the “Intellectual Property” section).

At the office we provide the entire structure to protect our sensitive data. Employees must observe the good practices detailed in this Code in the “Information Security” section and the Terms of Responsibility must be replicated in teleworking.

EMICOL is committed, and proud, to fully comply with labor legislation. Thus, outside the office, we hope that Employees will continue to comply and also demand respect for labor standards, which is why EMICOL requests and advises that:

• comply with working hours: Create a routine that allows you to continue with your productivity, fulfilling the working hours stipulated in your employment contract or by your manager. Do not work less than agreed and, equally, do not exceed your working day, respecting even your rest time. In case of problems, consult our Human Resources area.
• Ergonomics: Set up a quiet, light and airy workplace to work. Likewise, take care of your posture to avoid physical injury.

UNION FREEDOM AND COLLECTIVE BARGAINING

EMICOL leaves free the rights of Employees to union association and collective bargaining.

ENVIRONMENTAL RESPONSIBILITY

Our production requires environmental licenses issued by regulatory authorities and EMICOL understands its obligation to comply with all requirements imposed to obtain these environmental licenses, as well as to keep them in force throughout the operation.

We understand that responsibility for the environment is part of our culture and the preservation of natural resources is important for our sustainable growth, in addition to being determinant for the quality of life of our Employees and the local communities where we operate.

BACK TO START

EMICOL's Employees must deal with Business Partners who may enter into any relationship with the company, in order to avoid even the appearance of any conflict of personal interests with those of the company, so that we can have a healthy work environment and maintain the personal and business integrity of EMICOL.

CONFLICTS OF INTEREST

The Conflict of Interest is characterized as a situation in which the judgment appears to have been influenced by the receipt of some type of personal advantage. Even if the decision was not deliberately influenced, Conflict of Interest situations can cause serious damage to the Employee's reputation and, consequently, to the business we conduct. It is the Employee's duty to be always attentive, in detail, to our professional and personal relationships, to rule out any possibility of influence of private interests in our business. In case of doubt, contact your leadership for further clarification and/or our Human Resources area.

In the next sections we will cover examples of Conflicts of Interest that can occur in the workplace.

NEPOTISM

The practice of favoring or prioritizing relatives and family members in favor of personal and own benefits is not allowed, without taking into account the capacity of other people equally or more qualified for certain positions, positions or other appointments.

RELATIONSHIP WITH BUSINESS PARTNERS

If you have a personal relationship (family, friendship, affective or financial) with Business Partners who provide services directly to their respective area or department, you will need to proactively communicate this relationship to the Human Resources area. Communication is necessary to assess the business relationship and mitigate any possible Conflict of Interest.

SPONSORED ACTIVITIES, EVENTS AND GRATIFICATIONS

It is forbidden for Employees and Business Partners, directly or through the use of Third Parties, to offer, authorize, grant or receive payments or any valued gratuity to obtain undue or inadequate advantages to carry out or retain EMICOL's business.

However, EMICOL understands that, in order to strengthen business relationships, it is common for Employees to receive invitations from Business Partners to participate in dinners, business trips, sporting events, concerts, etc.

EMICOL does not allow:

• Receive trips for leisure.
• Make personal use of samples intended for EMICOL
• Receive money of any amount or by any means
• Receive gifts with a value above the one determined in the Term of Relationship with Business Partners and Third Parties.
• Receive any type of product, service or value, whether in the form of bonuses, discounts, promotional funds or in cash, in exchange for any type of personal favors or for the benefit of oneself or the company.
• Receive gifts upon demands or requests.

Note: Gifts with values ​​above those determined in the Terms of Relationship with Business Partners and Third Parties must be immediately sent to our Human Resources area, for drawing at the end of the year party or at events.

EMICOL allows after communication made to its leadership, our area of ​​Human Resources and Board Approval:

• Participate in business events, not open to the public, sponsored by Business Partners;
• Receive tickets for musical, cultural and similar shows;
• Receive tickets for major sporting events (example: Formula 1, World Cup, Olympics);
• Receive invitations to business meals;
• Accept business travel paid for by the Business Partner to visit facilities;
• Receive invitations to paid courses and events, as long as they are related to the Employee's role.

EMICOL allows without approval:

• Receive groceries or gifts with a value below the one determined in the Term of Relationship with Business Partners and Third Parties;
• Participate in events, open to the public, sponsored by the Business Partner; and
• Receive low value gifts, such as pens, notebooks, and the like.

PERSONAL RELATIONSHIP

EMICOL understands as normal work, personal and even affective relationships among its Employees. Employees of the same family working in the Company are also common. Below are some examples of situations:

EMICOL does not allow:

• Affective relationship between manager and subordinate within the same area;
• Family relationship (up to first degree) of Employees who work in the same sector/department; and
• Indication of family members, without informing the person responsible for hiring.

EMICOL allows after communication made to our area of ​​Human Resources and Board Approval:

• Affective relationship of Employee manager with third parties hired by the respective area; and
• Hiring family members as a supplier/customer.

EMICOL allows without approval:

• Affective relationship between Employees, where there is no direct subordination and where there is no conflict of interest; and
• Indication for the selection process.

FINANCIAL INVESTMENTS

Employees and sales representatives who have financial investments such as shares, partnerships in companies that conduct business directly with EMICOL or in companies considered to be business competitors, must communicate this relationship to our Human Resources area. As soon as communication is made about the financial investments, EMICOL will take the necessary measures to mitigate the possible risks of conflict.

PARALLEL WORK

• It is prohibited for Employees to carry out side work for Business Partners in which the Employee is responsible for contracting or managing services and products carried out within EMICOL, being prohibited to pass possible information of any nature from one supplier to another;
• It is prohibited for Employees to carry out side work for Clients in which the Employee is responsible for developing or managing products carried out within EMICOL, and it is prohibited to pass on possible information of any nature from one client to another.
• Employees who maintain other businesses cannot carry out activities that take the focus and effort away from their work at EMICOL during working hours;
• It is prohibited to use EMICOL's assets to conduct business unrelated to EMICOL's operations; and
• It is not permitted to operate or provide assistance to a competitor of EMICOL or to engage in any competing activities.

BEHAVIOR OF EMPLOYEES ON SOCIAL NETWORKS OR ANY DISCLOSURE MEDIA

Personal content produced on social networks or in any dissemination media may impact both the image of Employees and the image of EMICOL and Third Parties. Therefore, three points must be respected:

• Only departments previously designated by Senior Management are authorized to post content on public social networks, through EMICOL's fanpages (Instagram/ Facebook/ Twitter/ LinkedIn/ among others);
• Do not criticize EMICOL, its Employees and Third Parties on social networks; and
• That whoever works at EMICOL, knows how to preserve their image within the cultural standards of morals and good customs (self-exposure, criminal activities and others that are cause for public execration), so that they cannot affect EMICOL's image and quality ethics of its Employees.

PREVENTION AND FIGHTING FRAUD AND CORRUPTION

Employees must act with integrity, respecting and not violating norms related to anti-corruption, as well as the provisions of the Anti-Corruption Law and the Brazilian Penal Code.

EMICOL repudiates any act of corruption, extortion or fraud, prohibiting its Employees from offering or giving, directly or indirectly, any undue advantage to Business Partners, Government Agents or Third Parties representing the Company, with the intention of obtaining any favor improper.

CHILD LABOR AND CONDITIONS ANALOGUES TO SLAVERY

EMICOL will not conduct business with companies, whether national or international, that use child labor. Likewise, we will not conduct business with any company or entity that keeps workers in forced or involuntary situations, with conditions analogous to slavery. If Suppliers are found to use child labor or people in situations similar to slavery, immediately inform our Human Resources area.

NATIONAL AND INTERNATIONAL TRADE

In our operations we use inputs produced both locally and internationally. In both situations, we must protect ourselves against money laundering, financing of organized crime and terrorism.

Money laundering is the term that designates the concealment of values ​​of illegal origin, to make them appear lawful. EMICOL's involvement in money laundering operations, even if involuntary, can have serious consequences. More than not getting involved in such operations, we must use mechanisms that identify suspicious operations, such as:

• Payments in large amounts of cash;
• Refund requests after payments or above the invoice amount;
• Fractional payment from several paying sources;
• Payments made through suspect countries; and
• Payments made from accounts other than those usually used;
• In case of any suspicion of a case of money laundering, do not make the payment and immediately report it to our Internal Ombudsman.

INTEGRITY IN INFORMATION RECORDS

EMICOL keeps records of information in a detailed, accurate and correct manner and always in compliance with the rules and laws. The transparency of records is reflected in the reputation and credibility of the Company and that it can guarantee its obligations to its Business Partners, Financial Market and Government Agencies.

PUBLIC ADMINISTRATION

Under the Law of Conflict of Interests between public and private, it is necessary to include, in all hiring of Employees, the communication about the existence of a direct or indirect relationship - up to 3rd degree of kinship (parents, spouses, children and siblings) - with the Federal, State or Municipal Public Administration, including here Municipalities, Public Companies and Mixed Economy Companies. If applicable to your case, please contact our Human Resources area.

BACK TO START

It is the responsibility of all Employees to use EMICOL's assets properly for business related to the Company and that they are not used for personal purposes. All Employees have the responsibility to take care of the assets provided by the Company, maintaining care against theft, robbery, loss or damage.

An asset is understood to be that which has value to EMICOL, which may be something tangible or intangible, facilities, machines, information, etc.

If there is any damage where the misuse of corporate assets is proven, the damage caused will be deducted from the remuneration.

EMICOL retains the right to monitor the communications and activities of assets assigned to Employees.

INFORMATION SECURITY

• It is not allowed to share logins and passwords or any form of access to third parties, from any system managed by EMICOL;
• Each Employee has certain access to EMICOL's systems, and it is their responsibility to maintain the integrity and reliability of their access; and
• Passwords are for personal use and not transferable and must be kept confidential.
• When you are away, block your access to the computer so that information is secure;
• Preserve confidential information, not allowing information to be leaked to unauthorized persons, such as business strategies, commercial policy, registration data, salaries, bank data information; and
• Avoid commenting on the Company's projects in public environments (airplanes, restaurants, etc.), as this fact can compromise the confidentiality of the information;

For Employees who received electronic devices (desktop, notebook or cell phone), it is mandatory to read and sign the Term of Responsibility for Use of Notebook and the Term of Responsibility on the use of EMICOL's cell phone device before handling them.

To ensure confidentiality and access to information, it is essential that Employees read and sign the Confidentiality and Individual Access Commitment Term before starting to perform their work.

DATA PRIVACY

It is the obligation of EMICOL Employees to responsibly handle the personal data of Business Partners, Consumers and co-workers in accordance with the General Data Protection Law.

Business Partners must also be committed to protecting the personal data processed by them, their employees, representatives and subcontractors, whether as controllers or operators of the data, maintaining an internal structure with appropriate technical and organizational measures for the control and security of personal data, with a specific person in charge and with processes that ensure the processing, storage, sharing and disposal of personal data, all in accordance with the General Data Protection Law and any other laws and regulations related to the processing of personal data and applicable privacy, as well as all guidelines and codes of conduct issued by the National Data Protection Authority (ANPD) or other competent authority. Business Partners must ensure that they only collect and process data that are strictly necessary to fulfill a certain purpose, that they have an adequate legal basis and that they act transparently with the data subject, in order to guarantee the exercise of all their rights. Furthermore, any and all treatment carried out by Business Partners on behalf of EMICOL must take place in accordance with their instructions and in accordance with applicable law. Business information and personal data must circulate in secure and controlled computing environments, including proper access rights management procedures. Business Partners are responsible for ensuring that they have an adequate legal basis –– including consent, when necessary –– for the processing and sharing of personal data that may be transferred to EMICOL throughout the business relationship, exempting EMICOL from any liability accordingly, in accordance with our “EMICOL Privacy Policy”.

INTELLECTUAL PROPERTY

Any and all material or immaterial production produced in connection with EMICOL's operations, on its corporate devices or within the network, belongs to the Company.

The brands and/or projects that are in the research and development phase related to EMICOL's products are owned by the Company and are protected by Brazilian law. It is prohibited for any Employee or Third Parties to have the right to use them, or retransmit them, without the express and due concessions and permissions from EMICOL.

INSIDE INFORMATION

Information considered privileged or confidential is that not known outside EMICOL's environment, and a possible leak could cause negative situations with the Company's operations. It is prohibited for any Employee or Third Party to disclose such information to others without proper authorization from the responsible management.

Example of information considered confidential and not available to the public:

• mergers or acquisitions;
• Company strategic plans;
• Contracts with international partners; and
• Development of products and processes (new or improvements).

BACK TO START

This Code provides important information to guide Employees on how to act accordingly in the relationship with Business Partners and it is essential that Employees read and sign the Term of Relationship with Business Partners and Third Parties before starting to carry out their work.

In addition, this Code seeks to prevent illegal practices by EMICOL's Employees, that is, those that contravene internal requirements and/or legislation, in particular the law of administrative misconduct, the law on bidding, the penal code and the anti-corruption law.

CLIENTS

Respect them and seek to satisfy them in every way within a relationship that is beneficial for the Client and for EMICOL.

We must always think as if we were in the Client's shoes, seeking to understand their demands and business needs so that we can propose innovative solutions and exceed expectations.

SUPPLIERS

Treat suppliers with respect, fulfilling what is promised to them. The choice of supplier or service provider must be made with the best for EMICOL, in no way, take into account possible personal advantages for the Employee who is participating in this selection.

EMICOL recommends that the Purchasing Department be involved in any contracting of (national) products and provision of services to mitigate the risk of conflict of interest between the supplier/service provider and the contracting area.

That is why EMICOL does not allow, when contracting suppliers, that:

• Have an explicit or implicit connection with slave labor, child exploitation or that submit their Employees to inhumane degrading conditions in all links of the organization; and
• Are in disagreement with the procedures and records of the Company.

COMPETITIONS

We compete with competitors in the market actively, yet respectfully and in compliance with competition laws. Competitors are a force that challenges us to continually improve each day.

COMMERCIAL PRACTICES

All EMICOL products are advertised and marketed in accordance with the regulations required by regulatory agencies. Additionally, all information disclosed to the public in the form of advertising and marketing of the Company's products is complete.

RELATIONSHIP WITH PUBLIC AGENTS

EMICOL does not conduct business through bribery. Bribery can be defined as making, or even soliciting, any payment, donation, provision of favors, direct or indirect advantages to public agents (such as hospitality, investment opportunity, refund of payments, etc.), and it is a crime. Likewise, it is strictly prohibited to accept or request a bribe, for one's own benefit or for the benefit of EMICOL. The same rule applies to foreign public agents.

POLITICAL CONTRIBUTIONS

EMICOL does not participate in political campaigns, does not support candidates or political parties. Therefore, we do not make donations to political campaigns and we do not make any political contribution.

The Employee is expected to follow the same way that EMICOL remains apolitical, at least within the work environment. Acting politically on behalf of yourself or others is prohibited. Caution and measured behavior are mandatory in personal expressions of their “political preferences and positions”.

philanthropic donations

EMICOL can support humanitarian causes. Philanthropic donations will only be made to Non-Governmental Organizations (“NGOs”), non-profit entities or social investments.

Philanthropic donations must be made without any counterpart or favor of any kind to EMICOL.

Donations of money to public agents, individuals or public or private companies are not allowed. Product donations to public agents, individuals, public or private companies must be approved by the Company's Board.

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