Grupo Limppano’s relationship with its employees, customers and partners, suppliers, third parties, communities, and the press will be based on the reciprocity of ethical and transparent behavior between the parties, aiming to propose internal initiatives that can ensure employee well-being and guarantee the business is productive:

l. COMPANY

Committed to a Human Resources and Social Responsibility Policy, the Grupo Limppano aims to put actions into practice that meet the needs for decent working conditions and ensure the maintenance of workers’ quality of life. These actions are aligned with adhering to current labor legislation, collective agreements, and social rights.

• We ensure occupational safety and health, while providing all necessary conditions and equipment;
• We forbid any acts of discrimination or bias, and actively champion respect for all forms of diversity, including ethnic, religious, social, cultural, linguistic, political, aesthetic, age, physical, mental, psychological, gender, and sexual orientation, ensuring all discriminatory conduct is strictly rejected;
• We recognize the right of free association of our employees, respecting and ensuring their participation in unions, and do not engage in any type of negative discrimination in relation to unionized employees;
• We encourage openness to transparent internal communication between teams, departments, and with leadership;
• We integrate affiliates, providing mutual respect and a cooperative work environment;
• We value teamwork and collaboration between all departments of Grupo Limppano;
• We promote equal opportunities for all employees by administering a performance evaluation that ensure equal opportunities for all without any form of discrimination;
• We take action against the use of child labor and forced labor;
• We are proactive in curbing any manifestation of moral and sexual harassment.

II. EMPLOYEES AND SERVICE PROVIDERS

Employees and service providers are required to carry out their activities within the standard of ethical and transparent conduct in accordance with internal regulations and policies:

• Always wear respective PPE provided for the performance of the activities in accordance with the standards stipulated;

• Report any situations involving moral or physical risk in the workplace to the respective immediate manager;

• Do not carry weapons on Grupo Limppano’s premises or during activities that are carried out outside the facilities;

• Do not carry, store, consume, or be under the influence of any types of narcotics and/or alcoholic beverages on Grupo Limppano’s premises;

• Let an immediate superior when undergoing medical treatment that involves the use of medications that could affect reflexes and, consequently, safety when performing daily activities;

• Care for the Grupo Limppano assets, ensuring their good maintenance and appropriate use, in strict compliance with internal rules and guidelines;

• Care for and ensure the efficient use of the equipment entrusted to individuals by Grupo Limppano to perform activities, including computers, cell phones, tablets, vehicles, etc., considering that these assets are owned by Grupo Limppano and are available to the employee or service provider as a work tool. In the event of any loss, damage, theft, or robbery, individuals should report the incident to their immediate managers and directly inform the Information Technology (IT) department. Additionally, in cases of theft and robbery, a report should be filed with the nearest police station;

• Prioritize the use of Grupo Limppano’s technology equipment for matters related to our activities;

• Do not use systems, equipment and/or any means of communication to store, transmit, transfer, and/or forward obscene, pornographic, rumor-based, violent, discriminatory, racist, or defamatory content that disrespects any individual or entity or that is contrary to our principles and values;

• Do not install any type of software on the company’s equipment. If the need arises, request authorization and support from the IT Sector;

• Use corporate email appropriately and exclusively for Grupo Limppano activities, according to internal rules and procedures;

• Make sure internal information is kept secure, reporting any known violations or security incidents involving IT to the Ethics Committee. We would like to emphasize that the rules for secrecy and confidentiality of information remain in place even after any employment/service contract with Grupo Limppano is terminated for a period of five (5) years;

• Uphold respect for the organizational hierarchy, fellow employees, service providers, local communities, and suppliers, while also ensuring the workplace is characterized by respect and order;

• Meet contractual obligations with the utmost commitment, quality, and diligence;

• Wear clothing compatible with Grupo Limppano’s dress code standards when an activity does not require uniforms to access the facilities of Grupo Limppano companies and when working externally;

• Any materials created by employees and partners while engaged in Grupo Limppano business are the sole property of the Company. These materials are strictly prohibited from being copied, reproduced, transmitted, distributed, or utilized without the express authorization of the Executive Board;

• Respect political, religious, ethnic, social, cultural, linguistic, aesthetic, age, physical, mental, psychological, gender, sexual orientation and other diversity. The dissemination, discrimination, and practice of such activities on the premises and/or interference with their activities and responsibilities is strictly prohibited;

• Only the Marketing department is authorized to post or publish content on behalf of the company. Employees are forbidden from offering personal opinions or making statements representing Grupo Limppano on social media. The disclosure of internal (non-public) information, photos, videos, and use of the Company’s brand are also prohibited without formal Executive Board approval. In the event there is authorization, attention should be paid to the places where photographs and videos will be allowed.

III. CUSTOMERS

Customer focus is a significant aspect of Grupo Limppano. The aim is to achieve customer satisfaction and loyalty by means of the following strategies:

• Courteous, agile, and quality service;

• Understanding the unique characteristics and needs of each customer;

• Resolving issues quickly and accurately;

• Providing information transparently;

• Improving the quality and performance of products on an ongoing basis;

• Ensuring the privacy and protection of customer information.

IV. SUPPLIERS AND THIRD PARTIES

The relationship between Grupo Limppano and its suppliers and third-party companies is based on transparency, harmony and cooperation to ensure that the services provided are of high quality and reliability for our customers. The way suppliers carry out their activities should be aligned with the values of Grupo Limppano and its commitment to maintaining ethical standards.

• Suppliers and third-party companies are selected and contracted based on legal and technical criteria, conducted through defined processes in search of the best cost-benefit ratio;

• Referring suppliers who have a family connection to a Grupo Limppano employee is permitted, provided that the criteria presented in the chapter “Conflict of Interest: Employee Family Members” are followed;

• Suppliers and third-party companies are expected to adhere to Grupo Limppano’s Supplier Management Policy and Code of Conduct;

• Do not carry weapons within Grupo Limppano’s premises or during activities conducted outside the facilities;

• Do not carry, store, consume, or be under the influence of any types of narcotics and/or alcoholic beverages on Grupo Limppano’s premises;

• Let the manager of the corresponding department know when undergoing a medical treatment that involves the use of medications that could affect reflexes and, consequently, safety when performing daily activities;

• Suppliers and third parties are required to:

     ✓ Have integrity, compliance with current legislation and the regulations they are subject to;

     ✓ Prohibit all forms of unacceptable labor, including slave, forced, compulsory, or child labor, or any exploitative practice that violates human dignity, is illegal, or is unethical;

     ✓ Maintain the privacy and protection of any information that they may have access to at any stage of the selection process, during the provision of services to Grupo Limppano and after the respective contract has been terminated;

     ✓ Refrain from giving interviews or speaking on behalf of Grupo Limppano and from disclosing non-public information without the proper authorization of Grupo Limppano’s Executive Board;

     ✓ Comply with the rules stipulated in this Code for offering gifts, presents, entertainment events, or supplier-sponsored events;

     ✓ Prevent employees and service providers from engaging in any form of moral or sexual harassment.

V. COMMUNITIES

Grupo Limppano formalizes its dedication to corporate social responsibility, driving the improvement of quality of life and fostering a conscious, accountable society via tangible initiatives in environmental preservation and social programs.

VI. PRESS

Grupo Limppano prioritizes strong relationships with the media and has established a formal framework for managing these communications:

• Only the Marketing department, Executive Board, or authorized employees may speak on behalf of Grupo Limppano and/or grant interviews on topics and subjects related to the company’s business;

• If any employee is contacted by the press to provide clarifications regarding the company, they are directed to not make statements on the matter and should immediately notify their superior and the Marketing department.

VII. OCCUPATIONAL HEALTH AND SAFETY

We are committed to protecting the health and safety of our employees and stakeholders.

Grupo Limppano adopts measures to comply with the best practices related to health and safety conditions at the workplace and to ensure that all our activities are in accordance with the applicable legislation in the locations where we conduct our operations.

We have created health and preventive medicine programs with the goal of enhancing the well-being and life quality of our staff and the staff’s family members who rely on them.

In the field of occupational safety, we support and encourage the activities of the Internal Committee for Prevention of Accidents and Harassment (CIPA), as well as developing varied activities during the Internal Week for the Prevention of Accidents at Work (SIPAT).

VIII. MORAL HARASSMENT, SEXUAL HARASSMENT, SEXUAL ASSAULT, DISCRIMINATION, PREJUDICE, AND OTHERS

We need to have respect for everyone who is part of our environment. This is absolutely essential, no matter the circumstances. A pleasant and positive work environment is important, and we are all responsible for building and maintaining this.

We value the diversity of our team and we show respect in our relationships with various stakeholders.

We strongly reject any form of moral harassment, sexual harassment, sexual assault, discrimination, and any type of violence within our activities, as defined in our Policy to Combat Harassment and Other Types of Violence.

Moral Harassment: Exposing an individual to humiliating and/or embarrassing, repetitive, and prolonged situations during the workday and in the performance of their duties with the intention of causing emotional distress to the victim.

Inappropriate Behavior: Violating any item of the code of conduct in an isolated manner—such as a single act of disrespect towards a colleague, not using the appropriate PPE for the task, discovery of a romantic relationship between a leader and their direct subordinate, mishandling social media related to the company, wearing inappropriate clothing, etc.

Sexual Harassment: The act of physically constraining someone, through words, gestures, or other means, with the intention of obtaining sexual advantage or favor, causing them embarrassment and violating their sexual freedom, with the perpetrator taking advantage of their position of hierarchical superiority or ascendancy inherent in the exercise of their job, position, or duty. It is also classified in Article 216-A of the Penal Code.

Sexual Assault: Engagement in a lewd or indecent act intended to satisfy sexual desires against the victim’s will. It can be, for example, sending photos of a sexual nature, unwelcome physical contact, forced kissing, unwanted touching, etc. It is also classified in Article 215-A of the Penal Code.

Physical Violence: Any conduct that offends the woman’s bodily integrity or health. It is perpetrated using physical force by the aggressor or with the use of weapons, and this type of violence leaves physical marks on the body and harms the victim in various ways. These include hitting, pushing, biting, hair pulling, strangling, kicking, burning, cutting, and mutilating.

Corruption: Scenarios where money (bribes) and/or benefits (gifts) are offered with the intention of influencing the decision-making of one or more employees to gain unfair advantages.

Violation of human rights and discrimination (Religious, Sexual, Racial, Age): Cases of racial, religious, gender, age, sexual orientation, nationality, social situation, or disability discrimination or other violations of working conditions, such as slave labor, child labor, poor hygienic conditions in bathrooms and locker rooms.

Fraud or Forgery: The act of someone taking an action to obtain an improper advantage for themselves, others, or for the Company or to cause financial harm to either the Company or another person. Fraud occurs in the relationship between people in the private sector. The same action involving the private and public sector is labeled as an act of corruption.

Misuse of privileged or confidential information: The publication or disclosure of any information temporarily or permanently in the Company’s possession to third parties should be categorized as reports of misuse of privileged or confidential information.

If any employee or stakeholder has experienced any type of harassment or witnessed any discriminatory behavior, we encourage you to report it in the organization’s available Ethics Channels.

Safety Committees are also routinely implemented in the units with the involvement of leadership, as a way to discuss and disseminate important information for the safety of our employees. We have internal regulations that detail the rules on health and safety at work, which are periodically communicated to all our employees.

IX. CONFLICT OF INTEREST AND GUIDELINES

A conflict of interest occurs when personal interests or the interests of third parties either overlap with or are confused with the interests of Grupo Limppano.

Some situations can lead to, support or suggest this type of conflict. Therefore, every employee is responsible for ensuring that the interests and objectives of Grupo Limppano are not compromised.

The following are considered conflicts of interest:

1. Employee family members:

Family members of employees taking part in the selection processes for hiring employees and contracting suppliers is permitted, provided that the following criteria are followed:

• They act with transparency during the process;
• They comply with all stages of the selection process without any special treatment or advantage;
• There can be no direct or indirect subordination relationship;
• In the case of service providers and suppliers, the contract manager and the person responsible for the negotiation cannot be relatives of the candidate;
• The employee, regardless of their position or rank within Grupo Limppano’s hierarchy, who has a family relationship with the candidate, will not be able to participate in the hiring process, nor will they be able to interfere in the decision-making process;
• The outsourced security/surveillance team is not allowed to recommend candidates for job openings.

2. Romantic relationships between employees:

Familial and romantic relationships are allowed from the point of hiring, as long as there is no hierarchical subordination or influence on decision-making related to either business operations or individual career progression. Employees from the Human Resources department and Executive Board are not allowed to have relationships with each other unless they are specifically authorized by the President of the company.

In instance where a romantic or personal relationship develops between employees, this needs to be reported to the Human Resources department.

3. Side activities:

These are activities carried out by an employee outside of their working hours for Grupo Limppano, regardless of whether these activities are paid or unpaid. These activities cannot interfere with the fulfillment of their duties at the company and cannot have an impact on their performance and the image of Grupo Limppano;

Such activities are not permitted to be carried out during working hours or on company premises. The use of Grupo Limppano assets for these activities is prohibited;

Employees are not permitted to be a partner of, or perform services for, companies competing with Grupo Limppano;

It is forbidden to conduct business involving the sale or trade of any goods or services within the premises of the company, including the act of lending money.

4. Gifts, presents, and entertainment events:

We do not tolerate the offering and/or receiving of gifts as a way to influence business decisions or to enable improper payments and we take all measures to ensure that our employees comply with these rules;

Only gifts and institutional items without commercial value are allowed to be accepted, such as: office supplies, notebooks, pens, calendars, bottles, books, etc. If the employee receives gifts or presents other than the criteria defined above, and which have a commercial value of up to one hundred reais (R$100.00), they must be notified to their immediate management;

If the commercial value of the gift or present received is higher than the value above, it should be submitted to the Human Resources department to define the acceptance and/or to hold a drawing among the employees;

Under no circumstances is it permitted to accept personal trips or any monetary value from representatives or companies that are part of the relationship group of Grupo Limppano;

Accepting any invitations to supplier-sponsored entertainment events is also forbidden;

Only positions previously defined by the Executive Board are authorized to offer institutional gifts and presents on special occasions, in accordance with strategic events planned by the Group.

5. Business meals:

A conflict of interest occurs when personal interests or the interests of third parties either overlap with or are confused with the interests of Grupo Limppano.

Certain situations have the potential to create, give rise to, or cause this type of conflict. As such, every employee is responsible for ensuring that the interests and objectives of Grupo Limppano are not compromised.

6. Supplier-sponsored events

Participation in business events (congresses, lectures, and training) sponsored by members of the Company’s external relationships group may only occur with the authorization of the Executive Board. Grupo Limppano needs to indicate which employees are permitted to participate in the event.

X. ETHICS COMMITTEE

It is the responsibility of the Ethics Committee of the Grupo Limppano to oversee, manage, and ensure adherence to the behavioral guidelines and standards of conduct outlined in the Conduct Management manual throughout the organization. The Committee is set in motion by an independent third-party consulting company for investigating the actions that are taken after evaluating the reported information.

The primary responsibilities of the Ethics Committee are:

• To analyze situations not set forth in the Code and define how to proceed;
• To respond to any concerns and provide guidance on how to act in the face of potential ethical dilemmas;
• To analyze situations involving non-compliance with the Code in order to recommend actions to be taken;
• To manage the communication channels of Grupo Limppano’s Conduct Management structure;
• To direct received incidents and complaints towards a process of investigation and examination to gather more information or determine the facts related to them;
• To review this Code annually and update it whenever necessary;
• To impartially define the penalties that should be applied in the event that the Code of Conduct and current legislation is violated, preserving common sense and justice.

XI. VIOLATIONS OF THE CODE OF CONDUCT AND ETHICS

Violations or suspected violations of the Code of Conduct and current legislation must be reported immediately. We are committed to fostering an environment in which our employees and/or stakeholders can defend their opinions and raise their concerns about behavior that violates this Code, internal policies and applicable law.

Your report is very important to help us detect these situations and take all necessary measures to ensure that our Code is properly applied.

To report a violation or suspected violation, our employees and/or stakeholders can use our Ethics Channel, anonymously and with total secrecy and confidentiality, available 24 hours a day, 7 days a week.

Available channels:

• Website: https://canal.ouvidordigital.com.br/grupolimppano
• Phone No.: 0800 591 2213 – Code 601
• WhatsApp: 31 98947-7889 (does not receive calls)

You may report your concern orally or in writing, and can identify yourself or remain anonymous;

The reports are submitted and managed by a fully independent outsourced company in order to preserve confidentiality and transparency, and are shared only with the individuals responsible for the investigation—the Ethics Committee;

We guarantee that there will be no retaliation for those who file reports in good faith with the Ethics Channel;

We ensure protection for those who, in an appropriate, responsible, and good faith manner, raise questions and concerns, and we do not retaliate against anyone who raises a concern or assists in the investigation of suspected violations;

Retaliation can come in many forms, such as harassment, exclusion from meetings, performance reviews, etc. If any of our employees believe they have been subjected to retaliation for reporting a problem, we advise them to report it immediately to the office of the President;

Violation of this Code constitutes a violation of the duties of the employment contract and will result in the initiation of a procedure to investigate irregularities, which may subject employees to the application of disciplinary and/or even criminal measures if they are found to have violated existing legislation;

The Ethics Committee will be responsible for investigating the case. They will also be responsible for determining the application of disciplinary measures and penalties, taking into account the relevance of the facts and the seriousness of the infraction.

XII. PROCEDURE FOR INVESTIGATION OF REPORTS – ETHICS COMMITTEE

From the moment we are aware of any deviation in conduct and ethics, it is our duty, as guardians of our culture, to conduct an investigation and address them appropriately, ensuring that rules are followed and a strong ethical foundation is maintained within the culture.

Any delay in addressing the report makes us complicit in the situation.

Steps:

1. Report filed through one of our channels
   The Ethics Committee receives the report, verifies that the information provided was sufficient to begin an investigation, ensuring everything is in order and properly managed to move forward systematically.
   
   
2. Investigation of reports
   Messages may be exchanged with the complainant (if the complainant has opted to receive messages via SMS) to gain an understanding of the situation based on statements, presentation of documents, and other sources. If there is no response or if the new information is not sufficient, the report will be closed due to lack of information.
   
   
3. Decision on next steps
   Based on the data gathered during the investigation, the Ethics Committee uses this information to discuss the facts, determine the most appropriate penalty, and consider whether any collective internal actions are needed to prevent future occurrences.
   
   
4. Application of disciplinary sanction or penalties
   Before applying any disciplinary measure, a few items need to be evaluated. These include the seriousness of the offense, the motivation behind the individual’s actions, their length of service, and their work history.
   The imposition of a penalty or sanction will depend on how serious the infraction is.
   Once the severity level is determined, the following measures may be taken: a verbal warning, written warning, suspension from one (1) to ten (10) days, and dismissal either with or without cause.
   
   
5. Completed and documented report
   All steps of the investigation and the conclusion of the report will be documented in a historical record, ensuring compliance and providing support for any potential future legal actions, if applicable.
   The specific procedures and guidelines on how the Ethics Channel operates are documented in our Internal Regulations of the Ethics Channel, which have been approved by the Ethics Committee.

XIII. PROCEDURE FOR INVESTIGATION OF REPORTS – ETHICS COMMITTEE

It is everyone’s responsibility to know and apply the guidelines of the Code of Ethical and Moral Conduct in order to ensure a healthy work environment and relationships based on the values of Grupo Limppano.

All violations will be reviewed and treated confidentially in order to apply the appropriate disciplinary measures in accordance with Grupo Limppano’s disciplinary sanctions rules, CLT (Consolidation of Labor Laws) guidelines, and/or any other relevant legislation related to the violation.

1. LABOR PENALTIES
   Labor penalties are punitive actions that aim to address inappropriate employee conduct and prevent recurrence.
   If such inappropriate behaviors recur, the employer has the option to terminate the employment contract, making it unfeasible to continue the working relationship.
   
   Four penalties are applicable: a verbal warning, written warning, suspension, and dismissal.
   
   Defined by the legislation, punitive measures should be applied gradually and adopted according to the frequency of offenses and/or the seriousness of the behavior, with the aim of giving the employee a chance to correct their conduct.
   However, it is important to note that the power of discipline must be exercised in moderation and be compatible with the violation committed. It is necessary for the employer, represented by the Ethics Committee, to always analyze each case with common sense and fairness.
   
   
2. DISCIPLINARY MEASURE
   Disciplinary measures have a dual purpose: they are punitive, yet also guiding. They must always remain proportionate to the infraction committed. If any measure is deemed to be too extreme or unwarranted, it could face legal consequences, and there may be implications such as the need to compensate for damages or the possibility of an indirect termination of an employment contract.
   For a very serious offense, if the measure is too mild (example: warning) it can have a negative psychological effect on the offender and other people (feeling of impunity).
   
   
3. GUIDELINES FOR THE APPLICATION OF DISCIPLINARY SANCTIONS
   Before applying any disciplinary measure, the following criteria should be evaluated:

• Severity of the offense (mild or severe);
• Reasons that led the offender to commit the offense;
• Length of service;
• Employee work record: previous disciplinary actions or punishments, commendations, performance levels, collaboration with the company/colleagues, etc.
  
  Legislation stipulates an order that an employer must follow when imposing a sanction. Everything will depend on the seriousness of the offense committed by the employee.
  
  3.1 VERBAL WARNING
  The warning should not be given in front of other people because doing so could result in the need to pay compensation for causing moral damage. The employer needs to clearly identify the inappropriate behavior and outline what the consequences will be if the employee repeats the error in the future.
  
  3.2 WRITTEN WARNING
  Must be prepared in two copies, and one of those copies is given to the employee. The warning must contain the description of the wrongful act, based on labor legislation and the company’s internal regulations. If the employee has already been warned verbally, such information must be included in the text of the punishment.
  
  3.3 SUSPENSION
  If the employer has already given a verbal and written warning and the employee continues to make the same infraction, the employer may suspend the employee for a maximum of thirty (30) days. Anything beyond that is regarded as excessive punishment according to Article 474 of the CLT.
  
  3.4 DISMISSAL WITHOUT JUST CAUSE
  This is one of the severe penalties that can be applied if the wrongful act is serious. As such, the employee will lose their job, but this will not affect their severance rights.
  
  3.5 DISMISSAL FOR JUST CAUSE
  This is the maximum punishment that can be imposed on the employee. Provided for in Article 482 of the CLT, just cause is considered to be any serious wrongful act that results in the termination of the employment contract. Thus, in addition to losing their job, the employee will be limited in receiving their severance rights upon termination. However, it is important to note that it is not any breach of contract that entitles the employer to terminate it.
  
  For cases of sexual harassment, sexual assault, and violence, in addition to the administrative sanctions that may be applied, the offender will be subject to appropriate legal procedures.
  
  

XIV. QUESTION CHANNEL

A channel for resolving questions and uncertainties related to the Code of Conduct and ethical dilemmas, as well as to receive suggestions and criticisms concerning the Group’s Conduct Management.

• Email: condutacomite@limppano.com.br
• WhatsApp: 21 99977-5778
  

XV. FINAL CONSIDERATIONS

All employees and stakeholders are responsible for safeguarding the image and reputation of Grupo Limppano.

It is therefore everyone’s responsibility to understand and apply the guidelines of the Code of Conduct in order to ensure a work environment and relationships based on high standards of moral conduct and the values of Grupo Limppano.

The leadership team plays a key role in this Management and is considered an important communication channel for providing guidance and clearing up any uncertainties.

This Code is effective as of this date and will be valid for two (2) years when, if necessary, it must be amended and re-published.

Rio de Janeiro, March 21, 2023.