IBMP Code of Ethics, Conduct and Integrity: Rules for Business Conduct, Slides of Ethics

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SUMMARY

GIFTS, GIVEAWAYS, ENTERTAINMENT AND DONATIONS

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WHAT TO DO IN CASE OF HARASSMENT, DISCRIMINATION AND/OR INTERPERSONAL, PERSONAL OR VALUE CONFLICTS? USE OF DRUGS AND ALCOHOL AND WEAPONS BEARING/POSSESSION

PROHIBITION OF POLITICAL ACTIVITIES VIOLATIONS GENERAL PROVISIONS

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MORAL AND SEXUAL HARASSMENT AND DISCRIMINATION UNACCEPTABLE CONDUCTS ADULT AND CHILD LABOR EXPLOITATION

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3 AIM

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4 ETHICS, CONDUCT AND INTEGRITY COMMITTEE

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SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

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RELATIONSHIPS

7 RELATIONSHIP WITH PARTNERS AND COMPETITORS

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RELATIONSHIP WITH SUPPLIERS

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RELATIONSHIP WITH THE STATE

PG RELATIONSHIP WITH UNIONS AND/OR TRADE ASSOCIATIONS RELATIONSHIP WITH THE PRESS AND THE ADVERTISING MARKET ONFLICT OF INTERESTS PG

INFORMATION CONFIDENTIAL INFORMATION

CONFLICT OF INTERESTS WHAT CONFLICTS ARE THERE BETWEEN PUBLIC AND PRIVATE INTEREST?

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COMPLIANCE WITH IBMP INTERNAL LAWS, REGULATIONS AND STANDARDS

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12 INFORMATION ON COMMUNICATION AND REPORTING CHANNELS

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ETHICS, CONDUCT AND

INTEGRITY COMMITTEE

IBMP has an Ethics, Conduct and Integrity Committee that is

autonomous and independent to investigate and judge cases

of violation of the Code and impose the appropriate disciplinary

sanctions.

Committee members are responsible for resolving any

doubts and providing guidance on compliance with the

Code.

COMPLIANCE WITH IBMP INTERNAL LAWS,

REGULATIONS AND STANDARDS

IBMP and all its members are responsible to comply with the specific legislation of each country it operates and any other standards that may be applicable, as well as the documentation used by IBMP.

Members must always have an ethical and righteous conduct, respecting the rules, not only complying with the Law, but also observing the guidelines provided in this Code and other policies and manuals adopted by IBMP.

Ÿ Members must not use the name of IBMP when dealing with personal matters of any nature.

IBMP must provide the regulatory and inspection authorities with all necessary collaboration and information, responding as soon as possible to requests addressed to it. It is prohibited to adopt any behavior that might prevent the regular exercise of supervision by the competent authorities.

Any active or passive corruption practice is prohibited, either through acts, omissions, creation, or maintenance of favoritism and irregular or fraudulent situations.

Ÿ IBMP does not tolerate the practice of any type of harmful act. Ÿ Alteration or concealment of any type of data is prohibited, being the Member subject to penalties. Ÿ IBMP does not accept any initiative related to money laundering. Ÿ Commercial or financial transactions that involve resources that possibly originate from illegal acts, and/ or that involve locations associated with countries or facilities with favored taxation and privileged tax regimes (tax haven) must be analyzed and approved by the IBMP Board of Directors. Ÿ Any evidence of occurrence of the mentioned events must be reported through the available channels. Any acts of corruption and improbity will be analyzed and, when verified, directed to public authorities.

RELATIONSHIPS

RELATIONSHIP WITH PARTNERS AND COMPETITORS

RELATIONSHIP WITH CUSTOMERS

IBMP is responsible for contributing to the process of creating value for its customers, by meeting their expectations and developing innovative solutions.

IBMP does not discriminate against customers, either by origin, economic size or location. However, it reserves the right to terminate any business relationship whenever its interests are not being met, when the relationship is not in accordance with this Code, or represents any legal, social or environmental risk.

All market and competitor information, legitimate and necessary to the business, must be obtained through transparent and reputable practices and must not be obtained through illegal means. Use of illegal and morally unacceptable ways of accessing confidential information is prohibited.

Ÿ Members are not allowed to adopt any action that defames the name of competitors or partners of IBMP.

No agreements should be promoted with competitors with the objective of abuse of economic or commercial power or arbitrary or anti-competitive commercial practices, such as price agreements, sales conditions, dividing customers or sharing competitively sensitive information.

RELATIONSHIP WITH SUPPLIERS

IBMP only has business with suppliers which comply with the country's labor and environmental legislation, do not directly or indirectly exploit child or slave labor, respect the anti-corruption legislation of the countries where they operate and, preferably, with those that commit to the practices of social responsibility in their production chain.

IBMP is committed to selecting and contracting its suppliers based on technical, professional and ethical criteria, conducted through processes predetermined by a specific area which make it impossible to decide to favor personal interests, friends or relatives. IBMP may terminate a business relationship whenever a supplier disregards the provisions of the Code, or when there is harm to its interests or disregard of legal, ethical, tax, environmental and health and safety at work issues.

Service providers contracted by IBMP must comply with all legal requirements and health, safety and environmental procedures applicable to their activities, as well as the provisions of the Code and procedures sent by the purchasing/supply area.

WHAT CONFLICTS ARE THERE

BETWEEN PUBLIC AND PRIVATE

INTEREST?

In addition to the situations described above, other precautions must be taken to prevent conflicts of interest between private and public activities. In this case, conflicts of interest are any situation generated by the confrontation between public and private interests, which may compromise the collective interest or improperly influence the performance of the civil service. Thus, the following conducts are prohibited:

• IBMP hiring or doing business with companies in which a public official, their spouse, partner or relatives, straight or collateral, up to the third degree, participate with the intention of influencing their management acts;
• Offering gifts to a public official whose decisions IBMP is interested in, except for promotional gifts or giveaways;
• Hiring, even if indirectly or as a consultant, a public official in position or within six months after leaving the position, except in cases authorized by law;
• Use of privileged information received from a public official who had an obligation to keep it confidential; and acting with or in partnership with public servants who are relatives of the Members and who have decision-making power in IBMP business and operations;
• Complementary rules on preventing conflicts of interest may be created by the Ethics, Conduct and Integrity Committee.

Members must not perform external activities, such as consulting or occupying a position in organizations with conflicting interests, unless there is a specific situation previously analyzed and approved by the Legal area and/or the Technological Innovation Center.

Bonds with IBMP suppliers or competitors, direct or through a spouse, partner or family, are also not recommended, especially if the position held by the Member gives him the power to influence transactions or allow access to privileged information.

CONFLICT OF INTERESTS

CONFIDENTIAL INFORMATION

PERSONAL DATA PROTECTION

Personal data (as defined by Federal Law n. 13,709 / 2018) and/or information that has not been made public by the institutional area of IBMP (such as research, technological developments, projects, patent application - initial phase, industrial secret, business secret, know-how, technical data, processes and market information, investments and purchases or sales, among others) must be kept confidential, unless the disclosure is authorized in writing by the Technological Innovation Center (TIC) or the Board, according to each situation.

All Members are responsible for safeguarding the data to which they have access.

Ÿ Members are responsible for treating confidentially the intellectual property information to which they have access as a result of their work, using it carefully. Disclosure of this information is not permitted without the express authorization of the IBMP Technological Innovation Center (TIC), in line with the Institute's Innovation Policy. Ÿ Confidential information in response to legitimate requests from government authorities can only be provided after it is considered that they will be treated

Personal data is all information related to identified or identifiable natural person and sensitive personal data is all data about racial or ethnic origin, religious belief, political opinion, union or religious, philosophical or political organization membership, data concerning health or sexual life, genetic or biometric data, when linked to a natural person, according to Law n. 13.709/2018 (General Data Protection Law - LGPD).

Personal data of employees, suppliers or partners must be considered confidential and can only be collected, processed or used when there is legal permission or the consent of the person involved/holder of the personal data.

Ÿ Data of reported/investigated persons, if provided by the whistleblower, may be provided to the administrative or judicial authorities, when required by those authorities because of any procedure derived from the denunciation, as to the persons involved in any subsequent investigation or legal proceedings arising from the investigation. This transfer of data to the administrative or judicial authorities will always be performed in accordance with the current legislation on personal data protection.

INFORMATION

confidentially and after taking appropriate measures to protect their confidentiality. It is subject to prior consultation with the IBMP Technological Innovation Center and Legal Counsel. Ÿ In case confidential information is entrusted to IBMP by third parties professionally involved, IBMP and its Members commit to protect such information so that it is not improperly disclosed. This obligation remains current even after the IBMP Member leaves, during and after the term of the contract which establishes the bond with clients and partners of the Institute.

Ÿ The use of confidential information for personal or third-party interest is a crime and may be subject to labor and criminal sanctions, in addition to termination for cause at the discretion of the IBMP Ethics, Conduct and Integrity Committee. Ÿ In lectures and participations in seminars and other public events, the confidentiality of information about IBMP and its business must be strictly respected. Prior authorization by the TIC to disclose the information is required, as provided for in the Innovation Policy.

UNACCEPTABLE CONDUCTS

ADULT AND CHILD LABOR EXPLOITATION

MORAL AND SEXUAL HARASSMENT AND DISCRIMINATION

IBMP does not use slave labor, even in a similar way, nor child labor and strongly rejects this practice, not doing business with entities that use such practices. In this way, the third party when contracting with IBMP tacitly declares that it does not use slave or child labor in its services, which is not to be confused with the activity performed by a minor apprentice in accordance with the law.

One of IBMP's values is “Valuation of the Human Capital”, thus committing itself to the development and maintenance of a healthy work environment which values respect for its Members, ensuring the right to working conditions that respect individual dignity and the regulations in force.

In this way, IBMP is committed to promoting an environment free of any type of verbal or physical harassment, including incidents that constitute disrespect, intimidation, threat, bullying or any type of discrimination, whether based on gender, race, color, sexual orientation, age, nationality, religious belief, social level, trade union association, political ideals or any type of disability.

Use of derogatory or defamatory nicknames to another Member or third parties' employees, as well as lack respect or treat them differently is also prohibited.

WHAT TO DO IN CASE OF

HARASSMENT, DISCRIMINATION

AND/OR INTERPERSONAL,

PERSONAL OR VALUE CONFLICTS?

USE OF DRUGS AND ALCOHOL

AND WEAPONS BEARING/POSSESSION

If any third party feels harassed, discriminated or faces any interpersonal, personal or values conflict (in daily life or in the performance of a specific activity), this person should contact the reporting channel and report the situation. If possible, they should present evidence that proves the occurrence of this type of violence in the workplace, such as witnesses.

IBMP prohibits the use of illicit drugs and the consumption of alcohol on its premises, as well as being in possession, using, selling or distributing any type of illegal substances in the workplace, under penalty of sanctions to those involved. On special occasions in IBMP, promotional events, socializing parties, lunches or dinners with customers or partners, moderate alcohol use may be tolerated. No weapons of any kind are permitted on the premises of IBMP, except for professionals expressly authorized to do so, when duly proven to the Human Resources area.