Code of Conduct

Safety-health- SETAPE GROUP

Code of Conduct

The code of Conduct is a guide that consolidates the values and principles of the company and translate them into words that describe, in a clear and concise way, the expected behavior of each professional. As a complement to this code, some units of the Organization have policies, guidelines and procedures related to their performance in the company and the daily life of the professional.

Each of us must read this document in full, as well as the policies, guidelines and procedures relating to the unit to which it is associated, and to the other units with which it interacts, in addition to being aware of the guidelines published on the intranet. Although the code of conduct, policies, guidelines and procedures seek to contemplate the widest possible variety of situations, doubts may arise. Do not hesitate to look for your management for clarification.

Conduct in business

The business relationship of the Setape Group is guided by ethics and transparency with all stakeholders and in all dimensions. It is essential that our professionals are uncompromising in observing these principles of conduct in their performance on behalf of the company.

All the professionals in the company have a mission to help our customers achieve their strategic and operational objectives. In addition, they should seek to understand their expectations and achieve them, or even, if possible, overcome them within the established commercial context.

Conduct of our professionals

The Setape is the expression of the value of its professionals, it is the result of the combination of efforts of individuals of related vocations, aiming to create conditions for their professional and human realization. It is the responsibility of all professionals to contribute to achieving this goal.

In our activity we seek equal opportunities and we must provide all professionals with the same treatment and working conditions without distinction of appearance, physical condition or health, color, marital status, gender, age, language, nationality, Political opinion or other nature, social origin, sexual orientation, race, religion or any other condition not linked to strict professional competence.

Similarly, our company does not tolerate any kind of illegitimate discrimination against third-party professionals or against any individual or group it relates to.

Safety, environment and health

Safety, environment and health refer to the conditions and factors that affect, or could affect precisely the safety, environment and health of professionals, external consultants, third parties, visitors or anyone else in the environment of the tape and In the client companies. It also includes initiatives for the health of professionals, for occupational, non-occupational issues, food aspects and other healthy habits.

The installations of the tapas and those operated by it must work with the permits, the approvals and the controls necessary to protect the safety, the environment and the health.

In all its activities related to our projects must be identified and corrected or requested the corrections of the procedures performed outside the safety standards and technicians established by the tape.

Any situation that threatens your physical integrity or your colleagues in the workplace must be identified, you must communicate the fact to your manager or to the area of safety, environment and health.

It must be reported quickly to its managers or to the responsible areas, emergency situations, such as environmental accidents, so that the relevant measures are immediately adopted.

Do not work under the influence of alcohol or drugs.

It is not in possession of any weapons of any kind, unless it has the legal size of the weapon and there is a formal authorisation of the company for the exercise of its function always with the specific weapon for which it possesses the legal size.

Right to free Trade Union Association

The Freedom of Union Association is a right conferred by the law and the Entape recognizes that right, respecting the participation of its professionals in unions and not making any kind of discrimination.

Use of electronic media, cellphones, cameras

Internet access and use of telephone, e-mails, software, hardware, pen drives, external disks, cloud storage, CD/DVD and any other electronic system are available exclusively by the company for professional use.

According to Brazilian law, the Setape is responsible for the acts of its professionals and expects them to use these means with discernment, respecting the internal policies of the company.

All information written or stored in electronic media is owned by the tape and can be monitored.

You can make use of the electronic media of the tape for personal purposes, as long as it does not affect the productivity of your work and does not disrespect the policies and procedures of the company. For example, it is acceptable to occasionally make phone calls or send personal e-mails from your workplace. Excessive personal phone calls or e-mails constitute improper use of these means.

Do not download, upload or otherwise transmit data on pornography, nudity, indecency, vulgarity, obscenity or other inappropriate material.

Do not disable Company information security tools.

Do not install program or connect hardware without license or authorization from the system area.

Do not use the facilities and do not use the media of the company for purposes that may be harmful to you or to the tape.

You should not take photographs in the environment of external companies (customers) without the express authorization of those responsible.

Preservation and proper use of the company’s assets

The company’s assets may be financial, physical or intellectual property, such as financial resources, movable and immovable property, equipment, tools, supplies, communication facilities, computer programs, data, information, Technology, documents, knowledge (know-how), domains, patents, trademarks, copyrights and any other resources or assets that are intended to promote the business and activities of the company.

The professionals of the tape are responsible for the use of the assets of the company and the assets of our clients related to the work responsibly and for their protection against wear, except the normal wear due to the appropriate use, loss, damage, bad Use, theft, embezzlement or rape.

Cleaning and organization

It is the obligation of the professionals to maintain the cleanliness and organization of the workplace and to conserve the goods and resources made available by the tape and its customers for the execution of its function, as well as to avoid unnecessary waste and spending, its and other Professionals, respecting business assets and the environment.

Harassment

“Harassment” means any action, conduct or behavior that an individual or group of individuals may consider to be inappropriate, humiliating, intimidating or hostile. Actions or behaviors that are or may be interpreted as bullying, sexual or otherwise of a different nature should be avoided. In addition, everyone should be careful about actions or behaviors that may be acceptable in one culture, but they are not in another.

“Bullying” is characterized by the exposure of professionals to embarrassing and humiliating situations during the exercise of their function in a repeated manner and for a prolonged period. It’s what we call “moral violence.” These acts aim to humiliate, disqualify and emotionally destabilize the victim’s relationship with the organization and the work environment, which may jeopardize his or her health or employment.

“Sexual harassment” is characterized by the embarrassment of colleagues by means of embarrassing and constant insinuations with the aim of obtaining sexual advantages or favoritism. This attitude can be clear or subtle; explicit or insinuated; Writing or gestural; Come in the form of coercion or blackmail.

When traveling to work, find out about behaviors, practices and local customs to ensure that there is no disrespect or misunderstanding when you relate to a native.

Deviations from the code of conduct

Any indication of an act or behavior incompatible with the code of conduct, or failure to comply with the laws to which the company is submitted, must be reported to the administration of the tape. This can be done directly to your coordinator, manager, manager and or board.

In this channel, both internal and external audiences can communicate, in a confidential and secure manner, conduct that may represent violations of the code of Conduct, policies, guidelines, internal procedures or existing legislation. The record of reports can be carried out in three ways:

If the deviation of conduct has been demonstrated, the necessary measures shall be taken. The person who reports any evidence of infringement of the Code of conduct shall not suffer any kind of retaliation.

Consequences and treatment for deviations from the code of conduct

Deviations from the code of Conduct, policies, guidelines, internal procedures or existing legislation can have serious consequences for those involved, for the company and for the society itself. When the deviation is proven, measures compatible with the severity of the facts, which may cover: verbal or written warning, suspension, shall be applied; or more serious penalties (termination of the employment contract or the provision of services, commercial or business partnership agreements, among others). In addition, the identification of specific situations could give rise to corrective actions or improvement of existing normative instruments, such as revision of standards, procedures, the code of conduct itself, training, among other actions .

Cases involving illicit conduct may be forwarded to the competent authorities, making them liable for administrative, civil or criminal proceedings.

External Resources and consultants

The relationship with partners and service providers is considered a central element in the strategic positioning of the Setape. The company, in this sense, seeks collaboration relationships with a long-term perspective, established with ethical bases, based on trust and the definition of fair negotiating conditions.

It is understood that the relationship with partners and service providers must be guided by the pursuit of quality, technical reliability and value added to the final customer.

The professionals of the tape must choose their resources for our projects under the perspective of objective, technical and ethical criteria, conducted by formally defined procedures, and aiming to ensure the best cost-benefit, and that Be ethical for the company and its customers.

Society and the Environment

A company is a social organization that is justified while preserving its ability to aggregate value to the very society that hosts it. The Setape understands this dimension and seeks to contribute actively to the society and the environment in which it is inserted and with which it relates.

This positioning guides the strategic decisions of the Company, considering the aspects of economic, social and environmental sustainability of its projects, products and services, seeking to maximize its benefits to society and respecting the Relevant legislation.

The Setape expects of its professionals and encourages its customers, partners and their resources to adopt similar environmental and social positioning in order to promote sustainability in their value chain.

Fair competition

The law of free competition seeks to ensure fair and balanced competition opportunities in the market and is a constitutional principle. Therefore, the tapas search, in its competition process, the commercial and technical solution more appropriate to the demands of the customer. The relationship with the competitors is based on respect, ethics, good business practices and Brazilian law.

It prohibits and repudiates any conduct that restricts competition, such as the holding of agreements on bidding between competitors, conspiracy for pricing, market sharing, training and maintenance of monopolies or oligopolies.

Setape does not tolerate violations of Brazilian competition law and all professionals are obliged to comply with it.

Conflicts of Interest

The conflict of interest occurs when the professional uses his influence or acts with the objective of benefiting private interests, and not the interest of the tape, may even be contrary to the interests of the company, causing or not damage and/or damage.

The Setape respects the affectionate and kinship relationships that unite our professionals. However, it believes that some limits need to be established in order to avoid conflict of interests.

Professionals and third parties acting on behalf of the tape have an obligation to identify and avoid situations that may lead them to make decisions motivated by other interests other than those of the company.

Confidential information and insider information

The professionals of the tape are committed not to disclose the information of the company itself, from suppliers, customers and partners, that are privileged or confidential.

Information that is or may be considered confidential covers, as appropriate: technical, financial or commercial information, business opportunities, specifications, drawings, diagrams, models, samples, flowcharts, programs of Computer, strategies, budgets, plans, technologies, ideas, concepts, knowledge, discoveries, formulas, methods, projects, analyses, procedures, calculations, among others, regardless of the way in which such documents are Available.

In addition, confidential information may be defined contractually with third parties, whose disclosure and access are limited to certain persons.

It is considered “insider information” means the relevant information not yet released on the market, that the professional is aware of in the performance of his duties, capable of influencing in a ponderous way:

• Quotation of the securities issued by the company to whom the information refers or referenced to them;

• Investor’s decision to buy, sell or maintain those securities;

• Investor’s decision to exercise any rights inherent to the condition of the holder of securities issued by the company to whom the information is referred to or referenced therein.

• “Securities” are documents issued by companies or other entities (public or private), which represent a set of rights and duties relating to their holders and which can be bought and sold on the securities markets. They are examples of securities: Shares, Debentures, convertible notes and promissory notes.

Disclosure of confidential information may harm the company and/or third parties, and it is considered contractual failure, both of its contract to provide services with the secret and of confidentiality commitments that may have been concluded Between the tapas and customers, subject to payment of fines and indemnities.

The professional who, by virtue of their activity or as a result of their responsibilities, has access to insider information and market securities on the basis of such information or provide such information to persons who may Negotiate them, you are acting against the law and can be held responsible civil, administrative and criminally.

Information security

The security of information aims to strengthen the security of the intellectual property of the tape, ensuring more protection to its information assets, such as storage systems, information generated in our company or made available by third parties.

All files and data pertaining to the professional activity created, received or stored in the system of the tape, whether by e-mail, network or corporate cellular, are owned by the tape and constitute professional and legal assets of the company.

• Do not install software without proper authorization on your computer. The acquisition and installation of new programmes must be approved by the information security area and the product must be accompanied by a legally acquired license.

• You should not share your credentials, be they login, password or badge, this data is individual and non-transferable and your guard, secrecy and maintenance are the personal responsibility of the enabled user.

• Although information is not your responsibility and you have, by chance, had access, do not disclose it or misuse it.

SAO Paulo, July/2017

The board

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