COMPLIANCE Program

Safety and Health – GRUPO SETAPE

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

The evolution of our society is requiring an improvement in the ethical and behavioral behaviour of the professionals and companies where they operate. Our country has published more and more specific laws and norms requiring all Brazilians to improve our culture and ethical and moral attitudes.

The SETAPE since its creation in 1974, has always been deeply committed to the highest ethical and moral concepts, requiring all its employees to apply these concepts.

With the objective of constantly evolving in the implementation of this culture to all employees involved directly or indirectly in our activities, a study of our internal procedures, laws and ordinances and government resolutions was done, As well as clauses of contract made with our clients, resulting in this consolidation of the COMPLIANCE, safety and health program whose items we must observe in all the procedures of our activities and with our clients of the tapas.

Compliance is a set of internal measures that allows to prevent or minimise the risks of infringement of the laws arising from the activity practiced by an economic agent and any of its partners or employees.

The Setape Group is aiming through this program to strengthen its commitment to the values and objectives stated here, primarily with compliance with the legislation. This objective is quite comprehensive and therefore it requires not only the commitment to fulfilling a series of procedures, but also and especially 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 keep in mind the importance of doing the right thing.

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

Compliance statement

In order to provide solutions to any gaps that may possibly be deducted from the contractual relationship between the companies of the Setape Group, their collaborators, employees, partners, suppliers and customers, 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 law-abiding behaviour, not only in the context of contracts but also in relation to Any third-party activity relationship and the company in general, the Setape Group declares:

undertakes to observe and comply with all applicable laws and regulations under the competent jurisdiction on account of its constituent acts, the forum of contracts or the place of execution of the Prestational object, but also act accordingly and satisfy all Duties and obligations arising, in a broad and inclusive sense, of the rules and statutes in repression of corruption, grooming and other similar illicits, such as the Brazilian anti-corruption law (‘ 12.846/2013 ‘ Law), among others.
Who commits for all purposes of law, which will not grant, offer, promise or authorize payment in cash or any other means, or grant any kind 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 legitimate or seemingly invested in such authority and/or any third party acting under its name or under the name of the tape.
Agree, Anuem, acknowledge and declare that the term “public authority” should mean and be understood as embracing any and all physical or legal personnel invested mandate, designated or disreputable as a government agent, or under any other title Compatible to the functions or privileges reserved by law or in fact to the State and its representatives, directly or by delegation, which also includes any and all officers or servants of the public administration, administrators and/or employees of a Public company or controlled by the public authorities and/or regulatory agency, as well as by private concessionaire of public services, in the framework of the State and Federal public administration, of an international public organization and of any private com
pany Who agree, Anuem and acknowledge that the term “public authority” should also refer to political parties and their members and representatives, irrespective of whether there is a present or expired mandate, title or position encompassed among those Established in this statement.
For all purposes of law, which will not grant, offer, promise or authorize payment in cash or any other means, or grant any kind of benefit, favor, donation, gift, service, business opportunity or other kind of advantage Economic improper to any director, employee or other formal or informally invested agent, and/or any third party formal or seemingly acting under the name of the tape.
They undertake to communicate immediately to the officers of the Setape Group, as to the possible request or request, by individuals, organizations or legal entities mentioned above, for any kind of improper, unethical, and/or lucrative benefit.

Note: In the case of infringements of the abovementioned items and/or the code of conduct of the Setape, the representative who has this information shall bring it to the attention of the officers of the Setape group, which in accordance with the rules and procedures, shall take the Appropriate measures and possible communication to the respective pubic or private authority as appropriate.

Social Responsibility Statement

The representatives and the Setape Group undertake:

Child labor

Do not support the use of child labor (under 18 years) in places subject to real or presumed danger and not less than 16 years in hazardous installations. Respect the rights of the Child, expressed by ILO resolution 146.

Forced labor

Do not support the use of forced labour and do not allow workers to have their documents withheld or be obliged to make deposits as a condition to be admitted.

Health and safety

Provide a safe and healthy working environment that includes access to drinking water, clean, male and female bathrooms, necessary individual and collective safety equipment and training for use, taking appropriate steps to Prevent accidents and health damage.

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

Freedom of association and the right to collective bargaining

Respect the right of all employees to form or associate themselves with trade unions, as well as negotiate collectively, ensuring that there are no reprisals.

Discrimination

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

Medical Occupational Health Control program

The representatives and the Setape Group undertake:

To perform annual medical examinations of their partners, employees and to request that their external co-workers also provide the attestation to be in their register, in order to meet the labor and legal norms of the medical control program of Occupational health- PCMSO (NR-07).

(a) Do not require employees to have a day of work routinely exceeding 44 hours per week with at least a rest-time in that period and a maximum of 12 hours of weekly, remunerated overtime. Must comply with the laws and norms of their branch of activities Law No. 6,514, of 22, December 1,977-amends chapter V of title II of the consolidation of labour laws, concerning the safety and Medicine of labor Ordinance N º 3,214 of June 8, 1,978-Approves the (s) regulatory standards – NR of chapter V of title II, of the consolidation of labour laws, relating to occupational safety and medicine, and subsequent modifications (based on: Ordinance No. 24, of 29 December 1,994, of the Ministry of Labour and Employment-Medical control program of Occupational health and Portess N º 8, of SSST/has, of 08 May 1,996, republished on 13 May of the same year, establishes the obligation for parts of the companies, the elaboration and implementation of a program of medical control Occupational Health (PCMSO) – NR – 7.

ILO Convention No. 161 – Health services at work, ratified by the Brazilian Government in 18/05/1990.

ILO Resolution No. 171 – Programme for the monitoring of the work environment and the health of workers.

Physically Handicapped (law 3298/99).

PPRA – Environmental Risk Prevention Program

The representatives and the Setape Group undertake:

(a) Meet the regulatory Standards (NRs) cited in Ordinance No. 3,214 of June 8, 1,978, and its amendments, from the Ministry of Labour and Social security, chapter V, title II of the CLT.

(a) Draw up the PPRA-Environmental risk Prevention program, which meets NR 9, which identifies and evaluates the environmental agents listed in the appendix to the Nr – 15 in the work environment of the tapas.

Note: The cover is classified according to the CNAE-7112-0, at risk Level 1.

To keep in the archives of the PPRA-Annual report, whose responsible for the elaboration and measurements of the risks is the partner Eng. Mechanical and safety-Mr. Waldemar Di Migueli Junior.

Maintenance of updated registration of external consultants

The representatives and the Setape Group undertake:

To keep up to date their registration of the service providers, running, with respect to the documentation of these companies, to the service contract, which contains their clauses of secrecy for the execution of the work rendered to our clients.

SAO Paulo, July/2017

The board

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