Aligned with our values, the main objectives of EGATI Code of Ethics are:

1. Disseminate guidelines that are in line with the company corporate governance, adopting measures to prevent corrupt or harmful conduct to the public administration, seeking to prevent any misconduct and conflicts of interest, with the application of appropriate disciplinary measures when, perhaps, such deviations are found;
2. Become a practical guide to personal and professional conduct, bringing a set of guidelines and internal standards of integrity at EGATI, with the purpose of preventing, detecting and correcting corruption acts, misuse, fraud, money laundering, irregularities and acts harmful to public or private property, and also those not consistent with Brazilian legislation, especially Law No. 12.486/2013 (“Anticorruption Law”) and Decree No. 8.420/2015 that regulates it or those that may replace it, to be used by everyone in our company, in their interactions and daily decisions, such as the administrator, mandatory, representative, contractor and subcontractor, making it a pattern of relationship for all our activities and actions, both national and international, always complying with applicable rules and laws;

Regardless of position and function, the Code of Ethics is strictly applicable to all employees of the company.

All individuals and legal entities, directly or indirectly linked to the operations – both in Brazil and abroad – which EGATI has actions control, must follow the Code of Ethics.

People or companies (third parties) who have relations with the company, but are not subject to its effective control, must sign a Commitment Statement in which they undertake to follow the integrity policy adopted by EGATI.

These third parties must comply with the required relevant aspects of EGATI integrity policy. Instructions and information about the implemented Program will be provided and its adherence will be required.

In the event that a third party does not comply with the integrity policy, once it has been instructed on this essential requirement, EGATI shall take corrective measures that may even lead to the agreement breach.

EGATI managers should take constant measures to ensure that the professionals under their responsibility comply with the rules and guidelines of the Integrity Program.

Our employees, among other procedures related to any person, both from the public and private sector, national or foreign, must have a conduct that includes never offering, promising or making payments, courtesies or donations – such as:  air tickets, lodgings, food, tickets to concerts, cinemas, gifts, or similar favors – in order to obtain an improper commercial advantage.

All our employees must be aware of and comply with laws and regulatory requirements that affect the day-to-day responsibilities of their work, and also understand in details how our integrity policy should be applied.

In case of non-compliance with the Integrity Program – whether they are harmful acts against the administration and public property (such as the promise or offer of any kind of bribery) or payment, commission, gift or remuneration to any authority, public officials, corporate or public bodies executives, without limiting to these issues alone – may result in serious administrative and criminal penalties, in addition to disciplinary actions. Such penalties even include the possibility of the company dismissal with fair cause.

Our employees who become aware of any irregularity must immediately report any possible violation of the laws or the company Integrity Program.

Witnesses or denunciators, whenever called, must fully and honestly cooperate with investigations related to integrity issues.

Suppliers or business partners will be selected by EGATI and monitored by the Compliance Committee. For the selection of a supplier or business partner we must avoid potential conflicts of interest, and inappropriate gifts or other value items, which may suggest or induce relationship privileges, cannot be accepted.

For contracted suppliers or business partners, in addition to the quality of their services, we must ensure that they are committed to EGATI values and high standards of integrity.

Suppliers or business partners in their company-related operations must sign a Commitment Statement confirming that they are aware of and comply with EGATI Integrity Policy.

For cases of contracts with government agencies, when contracting services and materials, we will strictly follow government procurement regulations.

Our Integrity Policy applies to all individuals and legal entities (Business Partners), directly or indirectly linked to the company operations. EGATI reputation and integrity is our primary asset and depends on our employees, partners and suppliers everywhere, acting in compliance with our Code of Ethics.

The objective of EGATI with this Commitment Statement is to ensure that all its Business Partners reflect the same standard of ethical conduct of the company, including Brazilian laws, especially Law No. 12.486/2013 (“Anticorruption Law”) and Decree No. 8.420/2015 that regulates it or those that may replace it.

Therefore, EGATI Business Partners, by signing this Commitment Statement, agree and share this commitment with the full compliance with our Integrity Policy in their company-related operations.

We recognize the important role that the Public Authorities (governments at various levels and other institutions of direct or indirect administration) plays regarding the management, promotion and implementation of services that improve the quality of life of people and societies.

Regarding contracts involving the provision of services to the Government, EGATI is emphatic in the compliance with the following principles and conducts:

a) Full compliance with all requirements of Law No. 12.486/2015 (Anticorruption Law) and Decree No. 8.420/2015, which regulates it;

b) Performance based on transparency, responsibility and loyalty to the values of the company itself and contacted institutions;

c) Compliance with all legally-based requirements and provisions, notices, contracts and bidding processes that it is involved with;

d) Waiver of any type of action or omission that entails benefits – direct or indirect – that may be illegal or characterize an unlawful advantage;

e) Report to those applicable all signs of violations to legality, business ethics and good management practices.

EGATI must comply with all export controls, with the economic guidelines which Brazil is linked to or subject to, and with customs laws that regulate the transfer of goods and technology across borders.

Before starting any export operation, EGATI must ensure the correctness when obtaining the licenses or authorizations.

It is essential to ensure that none of our employees involved in the goods or services export negotiations is responding to criminal proceedings of active corruption in an international commercial transaction or has been convicted of a crime against foreign public administration.

To act internationally, EGATI must comply with the laws, regulations and anticorruption policies established by Brazilian law and the legislation of countries which we have commercial relations with. Such compliance includes, by extension, the compliance with integrity determinations and recommendations implemented by national and foreign bodies and entities.

EGATI Integrity Policy does not allow business relations with persons or companies identified in restricted party lists by national and foreign governments.

EGATI understands that society is the ultimate beneficiary of its operations and recognizes the importance of implementing social, economic and environmental vectors wherever it operates. As a result of this concern, EGATI is committed to:

a) Always product positive impacts for society wherever it is developing any activity;

b) Operate guided by the respect for people, their cultures and the environment where they live;

c) Collaborate so that all those directly or indirectly involved in their projects achieve economic benefits;

d) Be involved, whenever possible, in actions or programs that encourage the sustainability of local and regional communities where it operates;

e) In each of its provision of service projects, outline a policy of social and environmental responsibility.

EGATI Ethical Conduct Line is intended for any employee who is in any of the following situations:

a) Whenever doubtful on how to act;

b) When aware of unlawful conduct or non-compliance with the Code of Ethics;

c) Suffering harassment or receiving an unlawful request from a public agent.

In the face of these circumstances, the employee must immediately communicate the company or a member of the Compliance Committee through the Ethical Conduct channel, accessible by e-mail: canaldedenuncia@egati.com.br.

The Ethical Conduct Line ensures the absolute confidentiality of the identity and provided information.

The company ensures that no one will be punished or retaliated for the relevant provided information.

The Compliance Committee shall receive, investigate and respond, in a timely manner, to any complaint through the ethical conduct channel.