COMPLIANCE

LETTER FROM THE MANAGEMENT

It is with great satisfaction that ECOPLAN ENGENHARIA announces its strategy to invest in integrity and in preventing and combating corruption.

Disseminating and defending the principles related to ethics and transparency strengthens the relationship of coherence and seriousness between company-employee-client-society.

The formalization of these principles is described in the Code of Compliance: Conduct and Ethics, an important instrument that consolidates the set of rules and procedures that support the actions of ECOPLAN ENGENHARIA throughout its existence.

ECOPLAN ENGENHARIA Code of Compliance: Conduct and Ethics guides professional conduct, internal and external, and serves as a reference for decision-making, applying to all employees, regardless of hierarchical level. The observance and practice of the behaviors described in the Code are essential for strengthening the company's business.

The Management of ECOPLAN ENGENHARIA believes in the dedication and commitment of its employees regarding the understanding and application of the Code in their day-to-day work.

It is important to point out that each employee is responsible for the perpetuation of ECOPLAN ENGENHARIA, mainly through attitudes and examples.


Sincerely

Júlio Fortini de Souza
Managing Director

Carlos Alves Mees
Technical-Operational Coordinator



With the implementation of the Program, ECOPLAN ENGENHARIA seeks to strengthen the Culture of Compliance in its work environment, aiming at the observance of laws, rules, and internal and external guidelines regarding the way an employee relates to other colleagues in the context of professional, how we do business with customers and suppliers and how the company positions itself in the community. Through a Compliance Program, the company established standards of “Conduct and Ethics” that are fundamental for its public image and its ability to do business. In order to consolidate these foundations, ECOPLAN ENGENHARIA adhered to the Business Pact for Integrity and Against Corruption of the Ethos Institute.

ECOPLAN ENGENHARIA points out that the anti-corruption laws in force in the country apply to employees, directors, and third parties who are working with the company.

ECOPLAN ENGENHARIA is committed to preventing all types of corruption, so that its relations are based on clear and objective criteria, always seeking to ensure that the laws in force are not violated. Contrary to what many people think, corruption is not necessarily restricted to the embezzlement of money, which is why it is necessary to know the rules that involve corrupt acts within the company as a whole. It is necessary to be aware that small acts, sometimes seen as of little importance, can also constitute misconduct as they testify against the ethical standards defined in the Compliance Policy.

Thus, we expect employees and third parties to behave in accordance with the company's “Conduct and Ethics” rules and to follow its principles conscientiously and in their entirety.



ECOPLAN ENGENHARIA'S ANTI-CORRUPTION POLICY establishes the commitment of Management and its employees (own and third parties) to conduct business with integrity, legality, and transparency, complying with current Brazilian anti-corruption and fraud prevention legislation.

Therefore, everyone must follow the guidelines established in the company's “Compliance Manual: Conduct and Ethics”, seeking to ensure compliance with this policy.

Júlio Fortini de Souza
Diretor



ECOPLAN ENGENHARIA, by making this space available, enables its EMPLOYEES, CUSTOMERS, SUPPLIERS, and SUBCONTRACTORS to communicate to the CONDUCT AND ETHICS COMMITTEE facts that present illegal, doubtful, and unethical conduct, characterizing a possible violation of the company's preventive policies of conduct and ethics.

The notifications mentioned here may be anonymous or identified, will be analyzed and, whenever possible, actions will be taken to improve the company's relations with its different public. The confidentiality of notifications will be observed, and any type of retaliation will be prohibited.

The available communication channels are listed below:

mail-to  : compliance@ecoplan.com.br

  : Rua Felicíssimo de Azevedo, 924 - Higienópolis - Porto Alegre/RS - ZIP-CODE 90540-046 - A/C Conduct and Ethics Committee.

Attention! If you want to receive a follow-up of your notification, it is essential to identify yourself.



RELATIONSHIP WITH CUSTOMERS
  • The company develops its products and services always considering the interests of customers. The opinion and understanding of the customer regarding the requirements of the product/service to be performed are of paramount importance. However, the customer's requests must be limited to the contractual terms and the object of the contract, prohibiting any action under the justification of meeting the Customer's requests that do not constitute a strict obligation of the company. The private interests of Customer representatives are not considered to be the Customer's interests;
  • The company aims at a long-term relationship with customers, being aware of its responsibility to them;
  • Prices and payment terms must always be clear and evident, and ambiguous or implicit clauses will not be included in contracts;
  • The company does not participate in actions whose purpose is to circumvent regulatory bodies, government authorities, tax authorities or third parties, nor does it cooperate in the provision of services related to funds obtained illegally;
  • The confidentiality of customer information is protected by law.

RELATIONSHIPS WITH SUPPLIERS AND SUBCONTRACTORS
  • Contracts entered into with third parties/suppliers must have clauses ensuring compliance with the company's preventive conduct and ethics policies and current anti-corruption laws. Aims to prevent unlawful payments/acts and provide the company with means to terminate the relationship if there are breaches of the contract. It must prevent occurrences of a nature contrary to the rules of conduct and ethics by third parties/suppliers.

With regard to SUPPLIERS, the company requests UNDERSTANDING and COMPLIANCE with the following PROHIBITED conduct:

  • Take advantage of someone by using any illegal business practice, such as manipulation and abuse of privileged information;
  • Communicating information relevant to a new business among competitors;
  • Enter into any collusive agreement or compromise with a competitor regarding price fixing, customer or territory allocation, customer/supplier boycotts, or other similar agreements;
  • Work with other companies to limit competition to influence supply.

With regard to SUBCONTRACTORS, the company requests the UNDERSTANDING and COMPLIANCE with the following PROHIBITED conduct:

  • Provide or request any type of favoritism, especially to public officials, politically exposed persons, and agents of regulatory bodies;
  • Manipulate or defraud public bidding or contract arising therefrom, as well as remove bidders through fraud or offer of advantage of any kind;
  • Ask customers or suppliers for gifts, souvenirs, etc., for your own benefit or for the benefit of others;
  • Speak, on behalf of the company, with any form of media, without prior authorization from Management.
GIFTS, MEALS, TRAVEL, ACCOMMODATION, AND ENTERTAINMENT

It's allowed:

  • Offering or receiving institutional gifts (with no commercial value as they display a brand or advertisement);
  • Offering or receiving gifts related to business dealings, whose value must be limited to 20% of the minimum wage in force in Brazil;
  • Offering or receiving meals, travel, and accommodation is limited to the duration of the trip and restricted to the time necessary to fulfill the contractual purpose.

Not allowed:

  • Offering or receiving gifts, freebies, meals, travel, accommodation, and entertainment when linked to employees with the power to interfere in a decision in the interest of the donor;
  • Giving or receiving cash or cash equivalents (such as gift certificates or payment receipts).
SPONSORSHIPS AND PHILANTHROPICAL DONATIONS

ECOPLAN ENGENHARIA does not usually make sponsorships and philanthropic donations. However, when performed, they must:

Sponsorships

  • Be transparent and previously approved by the Board of Directors, under no circumstances can payment be made in cash or through a deposit into a personal checking account.
  • Proceed with verification of the conduct of the institution to be sponsored in the National Register of Disreputable and Suspended Companies (CEIS).
  • Sponsorships made at the direct request, suggestion, or recommendation of a government official or business partner are prohibited.

Philanthropic Donations:

  • Be transparent and, whenever possible, tax-deductible.
  • Carry out a prior verification of the conduct of the institution to be benefited in the Register of Non-Profit Private Entities Impeded (CEPIM).
  • Donations made at the direct request, suggestion, or recommendation of a government official or business partner are prohibited.
POLITICAL CONTRIBUTIONS
  • Contributions to political parties or candidates with company resources or on its behalf (CNPJ) are prohibited.
  • As defined under the terms of current legislation, ECOPLAN ENGENHARIA employees and directors have the free right to exercise individual political manifestation, including the right to contribute their own resources to political parties or candidates. However, the use of any installation, means or resource and the name of ECOPLAN ENGENHARIA for such activity is prohibited.
CONFLICT OF INTERESTS
  • The conflict of interest in the employee-company relationship occurs when the employee uses his influence or commits acts with the intention of benefiting particular interests that oppose the interests of ECOPLAN ENGENHARIA or may cause harm.
  • Directors and employees must avoid real or implied conflicts between their personal interests and those of the company, which directly involve them or their close relatives.
FAIR COMPETITION
  • It is forbidden for the Board of Directors and collaborators to make informal contacts with public and private officials directly or indirectly involved in tenders in which ECOPLAN ENGENHARIA participates, whether the process is in progress or in preparation.
  • Any contact with companies competing in bids in which ECOPLAN ENGENHARIA participates directly or indirectly, with the aim of reducing, defrauding, frustrating, or ending competition between the participants is prohibited.
ACCOUNTING AND FINANCIAL INFORMATION
  • ECOPLAN ENGENHARIA's accounting and financial information must use methods and procedures in order to safeguard its assets, verify the adequacy and support of accounting data, promote operational efficiency, and encourage adherence to the policies defined by management, with the aim of avoiding fraud, errors, inefficiencies, and crises.