Compliance, Safety and Health Program – SETAPE Group

Dear Ladies and Gentlemen: Partners, employees, interns and external consultants.

The evolution of our society is demanding an improvement in the ethical and behavioral behavior of professionals and companies where they work. Our country has published more and more specific laws and regulations forcing all Brazilians to improve our culture and their ethical and moral attitudes.

SETAPE, since its creation in 1974, has always been deeply committed to the highest ethical and moral concepts, demanding from all its employees the application of these concepts.

In order to constantly evolve the implementation of this culture to all employees directly or indirectly involved in our activities, a study was made of our internal procedures, of the Laws and Government Decrees and Resolutions; as well as contract clauses made with our customers, resulting in this consolidation of the COMPLIANCE, SAFETY AND HEALTH PROGRAM whose items we must observe in all procedures of our activities and with our SETAPE customers.

Compliance is a set of internal measures that makes it possible to prevent or minimize the risk of violating the laws resulting from an activity practiced by an economic agent and any of its partners or collaborators.

The SETAPE GROUP is aiming through this program to reinforce its commitment to the values and objectives explained here, primarily with the compliance with the legislation. This objective is quite comprehensive and for this reason it requires not only the commitment to comply with a series of procedures, but also and mainly a concern to always seek an improvement in the excellence of all our attitudes towards society.

We will achieve our goal and positive results when we get all employees to bear in mind the importance of doing the right thing.

The rules of this program are also based on the anti-corruption law, 12.846/2013 (http://www.planalto.gov.br/ccivil_03/_ato2011-2014/2013/lei/l12846.htm)

1. Declaration of Compliance

In order to provide solutions for any gaps that may eventually be deduced from the contractual relationship between the companies of the SETAPE GROUP, its collaborators, employees, partners, suppliers and client, in relation to the regulation of ethical conduct and in accordance with the principles of corporate compliance, as well as with a view to reaffirming and asserting its full and unlimited commitment to honest, loyal and according to the law, not only in the context of the Contracts but also in relation to any activity relationship of third parties and to society in general, SETAPE GROUP declares:

• That it undertakes to observe and comply with all applicable laws and regulations under the competent jurisdiction due to its constitutive acts, the jurisdiction of the Contracts or the place of performance of the Installment Object, but also to act in conformity and satisfy all the duties and obligations arising, in a broad and inclusive sense, from the Norms and Statutes in the repression of corruption, enticement and other similar illegal acts, such as the Brazilian Anticorruption Law (‘Law 12.846/2013’), among others.
• Who undertakes for all purposes of law, who will not grant, offer, promise or authorize payment in cash or by any other means, or have granted any type of benefit, favor, donation, gift, service, business opportunity or other type of economic advantage improper to any Public or Private Authority or individual and/or legal person legitimately or apparently invested by such Authority and/or any third party acting under its name or under the name of SETAPE.
• Agree, agree, acknowledge and declare that the expression “Public Authority” shall mean and be understood as encompassing any and all physical or legal personnel Invested mandate, designated or reputable as Government agent, or under any other title that fits the functions or privileges reserved by the Law or in fact to the State and its representatives, directly or through delegation, which also includes any and all officials or employees of the Public Administration, administrators and/or employees of a Public Company or controlled by the Government and/or regulatory agency, as well as by a private concessionaire of public services, within the scope of the State and Federal Public Administration, an International Public Organization and any private company.
• That they agree and acknowledge that the term “Public Authority” must also refer to Political Parties and their members and representatives, regardless of the existence of a present or expired Mandate, title or position encompassed among those established in this declaration.
• For all legal purposes, which will not grant, offer, promise or authorize payment in cash or by any other means, or grant any type of benefit, favor, donation, gift, service, business opportunity or other type of economic advantage improper to any director, employee or other agent formally or informally invested, and/or to any formal third party or apparently acting under the name of SETAPE.
• They undertake to immediately communicate to the persons responsible for the SETAPE GROUP, regarding any request or request, by individuals, organizations or legal entities referred to above, for any type of improper, unethical, and/or profitable benefit.

Note: In the case of violations of the items referred to above and/or the SETAPE CODE OF CONDUCT, the representative who has this information must take it to the attention of the SETAPE GROUP, which, according to the rules and procedures, will take the necessary measures and eventual communication to the respective Public or Private Authority, as the case may be.

2. Declaration of Social Responsibility

The representatives and the SETAPE GROUP commit to:

2.1 – Child labor

Not support the use of child labor (under the age of 18) in places subject to real or presumed danger, nor under the age of 16 in hazardous facilities. Respect the rights of the child, expressed in ILO Resolution 146.

2.2 – Forced labor

Not support the use of forced labor and not allow workers to have their documents withheld or being forced to make deposits as a condition for admission.

2.3 – Health and Safety

Provide a safe and healthy work environment, including access to drinking water, clean toilets, male and female, necessary individual and collective safety equipment and training in its use, taking appropriate measures to prevent accidents and damage to health.

Provide safety equipment in accordance with health and safety standards, to providers, in length to the needs and conditions of each workplace.

2.4 – Freedom of Association and the Right to Collective Bargaining

Respect the right of all employees to form or join unions, as well as to negotiate collectively, ensuring that there is no reprisals.

2.5 – Discrimination

To restrain any attitude of discrimination by race, social class, nationality, religion, disability, sex, age, sexual orientation, union or political association.

3. Auditing of Material Purchasing Procedures, Contracting Services and Control of Travel Expenses

All purchase purchases, service contracts including through external consultants and travel expenses will be audited in the home department and in the administrative department.

Travel expenses, which represent the large percentage of this type of contract, must follow the Travel Expenses Standard, available in our ERP SETAPE.

4. Occupational Health Medical Control Program

The representatives and the SETAPE GROUP commit to:

To perform annual medical examinations of its partners, employees and request that their external collaborators also provide the certificate so that it remains in their registration, in order to meet the labor and legal standards of the OCCUPATIONAL HEALTH MEDICAL CONTROL PROGRAM – PCMSO (NR-07).

Not to require that employees routinely work more than 44 hours a week with at least one day off during that period and a maximum of 12 paid overtime hours per week. They must comply with the legislation and regulations of their line of law Law No. 6,514, of 22, December, 1977 – Amends Chapter V of Title II of the Consolidation of labor laws, relating to Occupational Safety and Medicine Ordinance No. 3,214 of June 8, 1978

– Approves the Regulatory Norms – RN of Chapter V of Title II, of the Consolidation of Labor Laws, related to Occupational Safety and Medicine, and its subsequent modifications (based on: Ordinance No. 24, of December 29, 1996, of Ministry of Labor and Employment – Occupational Health Medical Control Program and Ordinance No. 8, of SSST/TEM, of May 8, 1999, republished on May 13 of the same year, establishes the obligation on the part of the companies, of the elaboration and implementation of an Occupational Health Medical Control Program (PCMSO) – NR – 7.

ILO Convention No. 161 – Occupational Health Services, Ratified by the Brazilian Government on 05/18/1990.

ILO Resolution 171 – Workplace Health and Workplace Health Surveillance Program.

Physically Disabled (Law 3298/99).

5. PERP – Program for Environmental Risk Prevention

The representatives and the SETAPE GROUP commit to:

To comply with the Regulatory Norms (RNs) mentioned in Ordinance No. 3,214 of June 8, 1,978, and its amendments, of the Ministry of Labor and Social Security, Chapter V, Title II of the CLT.

To prepare the PERP – Program for Environmental Risk Prevention, which meets NR 9, which identifies and evaluates the environmental agents listed in the annex of NR – 15 in the SETAPE work environment.

Note: SETAPE is classified according to CNAE-7112-0, at risk level 1.

The PERP – Annual Report is to be kept in SETAPE archives, whose responsible for the preparation and measurement of risks is the partner Mechanical and Safety Engineer – Mr. Waldemar Di Migueli Junior.

6. Maintenance of Updated Registration of External Consultants

The representatives and the SETAPE GROUP commit to:

To keep up-to-date its register of service provider companies, in execution, regarding the documentation of these companies, the service provision contract, which contains their confidentiality clauses for the execution of the work provided to our clients.