Compliance

1. OBJECTIVE

With the commitment and corporate responsibility, the Code of Ethics and Conduct of Beontag, or "Company", has as its main objective the construction of trust with all employees, third parties, partners, customers and government entities, establishing the standards of integrity and conduct expected by Beontag. This Beontag Code of Ethics and Conduct aims to assist all those who represent or act on its behalf to adopt a uniform global approach to ethical issues in the conduct and development of the Company's business, contributing to its sustainability.

The Code of Ethics and Conduct is one of the documents that make up the Beontag Compliance Program, guiding other Policies and Procedures that complement and deepen the guidelines provided for in this Code.

2. SCOPE

This Policy must be known and fully complied with by all Employees, employees, service providers, interns, Senior Management of Beontag and all its subsidiaries, especially by those who participate, directly or indirectly, in the flow of hiring Third Parties by Beontag. In addition, this Policy shall be complied with by any Third Parties acting on behalf of, in the interest of or for the benefit of Beontag, as applicable.

3. PURPOSE AND VALUES

Beontag's purpose is to empower companies, brands and people to express their unique identity.

Beontag's vision is to give voice to trillions of everyday items in a sustainable way.

Our values, which should guide all Beontag's day-to-day decisions, are:

• Respect;
• Commitment; 
• Integrity;
• Environmental protection;
• Innovation.

4. GENERAL GUIDELINES

Beontag understands that each one has responsibilities for their acts and omissions, however, ethics, integrity, transparency and good faith are principles that must always govern any act and, within the scope of Beontag, it is expected that all decision-making respects such principles, as well as the legislation applicable to the context and our internal rules. We value full respect for human rights, privacy and the environment. We expect from everyone at Beontag exemplary behavior regarding the behavior patterns provided herein.

The standard of conduct to be followed is always the most honest, just, and lawful. It should be taken into account that everyone is, in some way, a representative of Beontag, and that their image and reputation are directly impacted by the acts performed by their Employees, thus, everyone must act professionally at all times.

Beontag does not tolerate any conduct contrary to ethical and integrity principles, which is discriminatory, anti-competitive, violates human rights and the right to privacy, presents a risk to the environment or represents any non-compliance with applicable laws or standards.

Any type of exception, non-compliance or negotiation regarding compliance with applicable laws and the rules contained in this Code will not be accepted, regardless of the position, responsibilities and hierarchical position of the Beontag professional.

It is everyone's responsibility to report immediately and in as much detail as possible, depending on the context, even if suspected, of any situation that may represent or be interpreted as non-compliance with Beontag's internal rules, misconduct, or violation of applicable laws.

The Compliance Department is available to clarify any doubt about the content of this Code or Beontag's internal Compliance Policies and Procedures, so that there is no misinterpretation of the rules that may lead to misbehavior. It is also possible to use the Beontag Ethics Channel to send complaints, resolve doubts, suggestions or request clarifications about our Code of Ethics and Conduct and other Compliance Program Policies and Procedures.

5. FUNDAMENTAL PRINCIPLES

Some principles are fundamental to govern Beontag's activities, demonstrating the minimum, non-negotiable and indispensable standards that the Company values, encourages and expects from everyone who relates to it, in order to ensure that there is a general and common identity to all the companies that make up the Group. Thus, the following principles are mandatory in the exercise of Beontag's professional activities:

• Always act ethically, with integrity, honesty and fairness;
• To cherish the dignity of the human person;
• To respect human rights and the environment;
• Do not practice any discriminatory act;
• To comply with all legal and moral standards related to the specific professional activity;
• To preserve the integrity and reputation of Beontag in the conduct of all its business;
• To comply with all applicable laws, rules, rules and regulations in the countries in which Beontag operates.

6. CULTURE

Everyone is responsible for maintaining a culture that values ethics and integrity, and there must be commitment and engagement on the part of Beontag Employees.

We have listed some measures to be adopted on a daily basis that can help disseminate Beontag's standards of conduct:

• To act as an example for staff and colleagues with ethical performance;
• Never ignore or cover up integrity or ethical issues, and it is mandatory to promptly deal with situations when identifying them, even if only requesting help or forwarding it to the person responsible;
• To use Beontag's Ethics Channel for complaints, questions, clarifications and suggestions in all matters related to the Compliance Program;
• To communicate with the Compliance Department for greater understanding and clarification regarding Beontag's Compliance Policies and Procedures;
• To ensure open communication with staff and other co-workers to seek guidance and report on ethical and integrity related situations;
• Do not commit acts of reprisal against colleagues who act in favor of ethics and integrity within Beontag;
• To value and actively participate in actions that promote ethics and integrity within Beontag;
• To encourage self-disclosure by becoming aware that a colleague has committed a violation of Beontag's internal rules, as voluntary reporting may be taken into account when applying disciplinary measures.

7. STANDARDS OF THE CODE OF ETHICS AND CONDUCT

a. Corporate Social Responsibility

Below are the standards, rules and guidelines that represent Beontag's commitment to corporate social responsibility globally, which must be followed by all Employees and Third Parties that apply to the reality of Beontag in their daily lives:

• Equality and Non-Discrimination

Beontag does not tolerate any form of discrimination. We encourage that a healthy and harmonious work environment be cultivated, full of diversity and free of any segregation, all of which must be equal in employment relationships, which includes any relationships within the scope of Beontag.

As part of Beontag's reality, it is essential to respect human rights and not to practice any form of discrimination, regardless of age, gender, sexual orientation, marital status, family situation, physical condition, nationality, ethnic origin, religion, language, race, level of education, economic situation, origin or social condition, political or ideological beliefs. We must effectively promote the inclusion of all people, without any kind of discrimination.

Everyone must be treated with the appropriate respect, in a dignified and integral manner, without any form of discrimination, regardless of the degree of relationship, whether customers, co-workers, hierarchical superiors, subordinates, competitors, suppliers, service providers, business partners or any other third parties.

• Human Rights

Beontag is committed to absolute respect for human rights, such as dignity, equality, freedom, the right to life, health, privacy, the environment, among others. Thus, any form of child, forced, slavery, slave or any other form of illegal labor exploitation that represents a violation of human rights in its operations will not be accepted.

We encourage everyone who interacts on behalf of Beontag or for its benefit, as well as customers and Third Parties, to be committed to the same principle. There will be no relationship between Beontag and companies that are suspected or proven to be involved in human rights violations.

Beontag supports the provisions of the Universal Declaration of Human Rights of the United Nations by ensuring that it does not participate in or participate in, encourage or practice any act that violates the inviolable principles of the human being.

• Harassment

Harassment can occur in different forms, such as moral and sexual harassment, which are prohibited by Beontag. Beontag is committed to promoting a work environment of absolute intolerance to violence and harassment, preventing the behaviors and practices that generate or encourage such conduct. Everyone must abstain, prevent and combat violence and harassment with the utmost commitment.

• Environment

Respect for the environment is one of Beontag's values, so everyone must give due importance to environmental aspects in the conduct of business operations and fully comply with treaties, laws and regulations related to the environment.

We must always consciously and optimally use the available resources, seeking to avoid wear, waste and improper use. All Beontag activity must be properly evaluated so that the option with the lowest possible impact on the environment and greater conservation of the fauna, flora and resources used is chosen and applied.

• Privacy, Personal Data Protection and Intellectual Property

It is everyone's right to the protection of your personal data, therefore, in the context of Beontag, we must properly use Beontag's personal data and confidential and proprietary information protecting them from any form of infringement, leakage, theft, loss, degradation, diversion, disclosure, reproduction, falsification, improper access and use for non-professional purposes or appropriate to the applicable legislation.

Beontag is committed to respecting the privacy and protection of all personal data that may be processed, always observing the specific purpose suitable for carrying out the treatments, in a legal, transparent and secure manner, especially sensitive personal data.

Any processing of personal data must be carried out in accordance with the principles, rules, legal bases and rights provided for in applicable legislation regarding the protection of personal data and information security.

It is forbidden to use Beontag's trademarks, logos and any other intellectual property rights, in whole or in part, without its prior and express authorization.

We are all responsible for protecting the confidentiality, integrity and availability of confidential and personal information, regardless of whether it belongs to Beontag, our employees, suppliers, partners or others with whom we do business. We must ensure that data is treated and protected in accordance with privacy and security requirements, standards and regulations worldwide.

All forecasts, directions and responsibilities on the subject can be accessed in Beontag's Privacy and Personal Data Protection Policy, as well as in other specific policies and procedures related to the subject.

• Social Media and Communications

Beontag's values and principles must always be observed when using social networks, virtual communities and other digital media using the name or referring to the Company, and it is forbidden to post information in a discriminatory manner, criticism of competition, incitement to violence, political demonstrations, or that may harm the image of Beontag and any companies of the Group, in any type of social or digital media that may be part.

All communication on behalf of Beontag must be respectful, cordial and professional, using objective and clear vocabulary, in order to avoid any negative reading or confusing interpretation. The use of disrespectful, inappropriate or aggressive language is prohibited.

It is not allowed to use the name of Beontag or put yourself in the position of official representative of the Company during the use of social or digital media, except when there is prior and express authorization to do so.

Attention must be paid not to share unnecessary Beontag data, use the Company name or images of the Beontag environment when using social networks. Any conduct on social media or during communications that inappropriately exposes the image of Beontag, our Employees, customers, partners or third parties, as well as the services and products we offer is punishable.

• Political Participation and Social Organizations

During their free time, Beontag Employees may freely participate in political actions and social or non-governmental organizations, as well as act in favor of social causes of their choice, provided that the performance or positioning is not linked in any way to the image and name of Beontag.

• Safety

Beontag understands that a safe work environment is essential for a healthy functioning of the Company, thus, we value the safety of our Employees, acting in the prevention of exposure to undue risks, harmful or unhealthy activities.

Employees must follow all work safety rules in the corporate environment, being prohibited from being exposed to dangerous, degrading or illegal forms of work.

• Freedom of collective association

Beontag recognizes and respects the fundamental right of freedom of association of all its employees. This includes the right to join or affiliate with any organization of your choice, including trade unions and other professional associations.

Any form of intimidation, threat or retaliation against employees who exercise their right to freedom of association is prohibited. Furthermore, Beontag will not discriminate or offer preferential treatment based on membership or non-affiliation with an organization.

Any violation of this internal policy will be taken seriously and the Company will take appropriate disciplinary action against any employee who engages in intimidation, threats or retaliation against an employee who exercises his right to freedom of association.

Freedom of association is a fundamental right and Beontag is committed to protecting and promoting this right for all of its employees.

b. Corruption and bribery

Beontag is actively committed to fighting corruption. Any acts, even if only attempts, of corruption, bribery or other attempts to obtain undue advantages will not be admitted.

In order to configure corruption and related practices, it is not necessary that the intended advantage is effectively obtained, or that the conduct is practiced, since the mere request or offer of advantage already qualifies an irregularity and is prohibited by Beontag.

If any Beontag Employee is in a situation where the other party, as a Public or Private Agent, requests any undue advantage in exchange for Beontag's favor in an undue manner, the request must be refused immediately and expressly. The Employee must inform the party that the conduct is illegal by law and prohibited by the Beontag Compliance Program and, finally, promptly report the situation to the Beontag Ethics Channel or directly to the Compliance Department so that appropriate measures are taken.

c. Giveaways, Gifts and Hospitality

Beontag allows the receipt or offer of giveaways, gifts and hospitality in accordance with internal rules, being restricted to the cultivation of good relationships with customers, suppliers, partners or other third parties, promotion of Beontag's image and brand, demonstration of Beontag's products and services or celebrations of special/relevant dates to the Company.

The offer or receipt of giveaways, gifts and hospitality must be in accordance with ethical standards, transparency, honesty and integrity, being forbidden to occur secretly or giving any appearance of irregularity and generate any embarrassments or risks to the image of Beontag.

It is forbidden to offer giveaways and gifts to Government Officials and/or third parties related to it (relatives, people of close relationship).

d. Donations and Sponsorship

Donations and sponsorship contributions will be made with the highest standard of transparency, integrity and legality. Beontag will only make donations or sponsorships that are in full compliance with national and international legal and constitutional provisions.

The granting of any donation or sponsorship does not guarantee authorization to use the Company's logos and brands. No donation or sponsorship may be granted without due diligence and knowledge and authorization from the Beontag Donations and Sponsorships Committee. It is forbidden for any employee, partner or third party with whom Beontag relates to make a donation or sponsorship in the name and/or interest of Beontag, without prior and express authorization.

Beontag and all companies in the group do not make electoral donations or for political movements and prohibit any form of support, donation or contribution of a political and electoral nature, directly or indirectly through third parties, whether financial or non-financial, on behalf of Beontag or expressing any link with the Company.

e. Conflict of Interests

Beontag expects that no one will practice any preferential treatment to anyone for personal interest or aspiration. A distinction shall be maintained between the business of the Company and that of particular scope.

f. Relationship with Government

Beontag expressly prohibits any act of corruption, bribery, fraud and other illegalities during the interaction with the Government.

All performance of Beontag with respect to Government Officials must be professional, respectful, transparent, honest and integral at all times.

All Beontag employees, third parties and business partners must comply with the provisions of the applicable Anti-Corruption Rules, such as the Brazilian Anti-Corruption Law No. 12.846/2013, the United States Foreign Corrupt Practices Act (“FCPA”), the United Kingdom Anti-Corruption Law of 2010 (“UKBA”), and other laws of the countries in which we operate and internal rules and procedures, such as the Beontag Anti-Corruption Policy, which must be our guide on a day-to-day basis.

g. Commercial relationships

All Beontag business relationships must follow the principles of ethics and integrity required internally by the Company. Loyal business practices and compliance with Beontag's trade rules, policies and internal rules should be promoted. If there is any conflict between Beontag's standards of ethics and integrity and the business practices we intend to adopt, the ethical principles and guidelines must overlap and be prioritized.

No discrimination is allowed in relation to Beontag's customers, suppliers, partners or third parties. Even so, Beontag has the right not to engage, negotiate or enter into any commercial relationship in which it does not have interests or when it identifies risks arising from the relationship, such as legal, ethical, image, reputational, environmental and social, and it is even possible to terminate such relationships under these justifications. All business decisions must be based on objective, technical, economic and legal criteria.

It is not permitted to accept or offer any assets to assist in obtaining business, undue benefits or securing special concessions to Beontag.

h. Relationships with Competitors

We encourage and value the practice of free competition and initiative, considering that they are extremely relevant factors for a balance of the market in which Beontag is inserted. In this way, Beontag encourages its Employees, suppliers and even competitors to act competitively, provided that all applicable antitrust legislation is strictly respected. Any interaction with a competitor must occur lawfully and for legitimate reasons, in a respectful and cordial manner, and the practice of anti-competitive conduct is absolutely prohibited.

No practices will be admitted, in any degree of relationship of Beontag, that violate the principles and guidelines of free initiative and competition, which may harm the balance of the market and represent illegal practices.

i. Accounting and Financial Books and Records

Beontag shall keep all its books and accounting and financial records updated, in a complete, detailed, transparent and accurate manner, in order to meticulously reflect the economic and financial reality of Beontag's business. Beontag's business transactions must be recorded reliably, so that the Company's books reflect its economic and financial reality.

j. Corporate Assets

The corporate assets provided by Beontag to its Employees are its property. The use of these goods by Employees during working hours, especially electronic goods, must occur exclusively for professional use.

The conservation of corporate equipment is the full responsibility of Employees who make use of them, and must ensure their integrity and proper functioning. Failures, breaks, malfunctions, losses and other hypotheses that are caused by misuse by the Employee will be your responsibility.

Electronic corporate goods provided by Beontag to its Employees are subject to access, monitoring, requisition and/or audit without prior notice, depending on Beontag's demand and needs.

k. Confidentiality and Intellectual Property

All information processed by Beontag, even if by related third parties, must be treated carefully, transparently, ethically and in good faith, always in accordance with the mission and values, Group's internal Policies and Procedures and applicable legislation.

The disclosure of information classified as confidential property or under the responsibility of Beontag is prohibited without prior formal and express authorization.

It is not allowed to make use of internal Beontag information of a technical, operational, commercial, financial or legal nature, such as know-how, processes, formulas, forms, spreadsheets, terms, reports, production systems, logistics and layouts, business plans, accounting methods, techniques and accumulated experiences, documents, files, contracts, papers, studies, opinions, research, for personal or third party advantage.

It is also prohibited to share, for personal or third party advantage, any confidential information of Beontag to any other partners, suppliers, third parties, competitors, or any individual or legal entity that is part of the Beontag branch that may make direct or indirect use of the information.

l. Investigations and Audit

All Beontag Employees must fully cooperate with any form of investigation or audit carried out within the Company. It is prohibited to obstruct, perform acts that impair the integrity of the investigation or audit, provide false statements or any act that unduly hinders investigation or audit, being subject to the application of Beontag's internal disciplinary measures and applicable legislation.

8. ETHICS CHANNEL

It is the duty of all Employees and Third Parties to immediately report any and all acts or indications of corruption, fraud, misconduct, violations of Beontag's internal Policies or applicable legislation, to the Beontag Ethics Channel, in order to ensure the protection of the ethical and legal principles adopted by the Company and preserve its image in the market.

The Ethics Channel can be accessed through:

• Telephone 0800 512 7702;
• Website https://www.contatoseguro.com.br/beontag

This channel is managed by a specialized company, being an independent, secure, confidential and impartial tool, available 24 hours a day, 7 days a week and 365 days a year to the internal and external public of Beontag. It is possible to make anonymous reports when using the Channel, always maintaining responsibility, ethics and good faith when making reports, which must be consistent and true. There will be no retaliation for sending reports in good faith, and it will be guaranteed that no individual, including Beontag employees, will be exposed or punished for using the channel tool or for participating in investigation processes arising from the reports. Any type of retaliation against whistleblowers, victims and witnesses of any case reported to the Channel or the Compliance Department is prohibited.

Any situations, doubts, questions, exceptions and/or clarifications on the application of this Policy should be directly to the Compliance Department, through the email: compliance@beontag.com or access the Beontag Ethics Channel.

9. INVESTIGATIONS, DISCIPLINARY MEASURES AND SANCTIONS

Any complaints, even if suspected, of violations of this Policy will be forwarded to the Data Protection Committee and submitted to an internal investigation procedure by Beontag's Compliance Department. If it is found, after a robust investigation, that there was misconduct, sanctions may be applied by Beontag, proportional to the nature or severity of the infraction committed.

The person responsible for committing an illicit act may be subject to judicial and/or administrative punishment, in accordance with the legislation of the country in which it has jurisdiction.