Code of Conduct and Ethics for Third Parties

Summary

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10Introduction .............................................. 04

Purpose ...................................................... 06

Coverage ................................................... 07

Integrity ..................................................... 08Facilitation Payments, Corruption and Bribes

Relationship with Public Administration

Gifts and Hospitality

Free Competition

Conflict of Interests

Work ............................................................ 1 2

Health and Safety .................................. 13

Environment and Community ............ 15

Confidentiality of Information ............ 16

Monitoring and Compliance ............... 17

Ethics Channel ............................................ 18

Definitions ................................................ 19Public Agent

Associates

Employees

Hospitality

Facilitation payment

Third Party

Term of Aware and Commitment ............. 21

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Introduction

SPIC Brasil/HPP São Simão (“Company”) is committed to creating business with sustainable development, without causing negative effects on the environment or depleting its resources and, at the same time, improving the quality of life of its community and contributing for a more ethical, prosperous and reliable society.

Third parties are a fundamental part of the construction of this model. For this reason, their responsibility goes beyond legal and institutional requirements, encompassing the moral duty in relation to the entire production chain and society, that is, it impacts all people, groups and institutions.

The Code of Conduct and Ethics for Third Parties (“Code”) aims to establish the requirements of SPIC Brasil/HPP São Simão with regard to its relations with third parties, but also seeks to create bonds and clarify its counterparts of the harm of their noncompliance with broadly, not only as to its relationship with the Company.

Our requirements and commitments to third parties are based on ethical, legal and socio-environmental conduct. The minimum expected conduct is addressed in this Code, in order to reinforce our values and guide third parties when doing business with the Company.

We emphasize that the violation of this Code may result not only in the termination of services to SPIC Brasil/HPP São Simão, but also at risk of the continuity of the third party’s business, due to legal and contractual actions, which impacts the entire chain of value in which it is inserted. Additionally, we highlight the observance of actions that do not allow any kind of inhuman or severe treatment, coerced or forced labor, so that there is a solid continuity of business with third parties and parties involved in this relationship.

For this, we act and positively influence each employee, third party and others involved in our production chain, encouraging good conduct practices.

We encourage this code to also be shared with the third party’s employees, in order to disseminate conduct based on ethics, transparency and integrity.

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Coverage

Our choices and maintenance of third-party hiring are based on technical, financial, quality, socio-environmental, ethical and compliance with legal, labor and environmental requirements.

This code aims to reinforce and clarify third parties about the minimum conduct expected when conducting business with SPIC Brasil/HPP São Simão.

Here, the most relevant topics for conducting relations are addressed, but these do not revoke legal and contractual requirements.

This Code applies to all third parties with whom SPIC Brasil/HPP São Simão has a relationship, to the associates of these third parties and to their employees.

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Integrity

We do not authorize payment of facilitation for public or private agents, in order to illegally expedite the performance of routine work such as, for example, the release of licenses, permits, certificates, etc. Third parties must not make, nor authorize, this type of payment, directly or through associates, especially while they are carrying out activities for or on behalf of the Company.

Third parties must conduct their business in an ethical and transparent manner and in accordance with current and applicable national and international laws. In case of non-uniform laws in their interpretation or wording, we will always choose the most restrictive law in its standards of integrity, always aiming to meet the highest requirements and international practices.

Our employees are forbidden from receiving any kind of gift, presents, entertainment, hospitality, privileges, payments, loans, donations, services or other forms of benefits of more than R$ 300.00 (three hundred reais), for themselves or for anyone else. Receipts of any amount in times of competitive process may characterize undue influence on decision making or negotiation and are therefore not authorized.

In the event of receiving a gift or a present in nonconformity and with the impossibility of returning it to its sender, it will be donated to assistance entities in the communities where we operate or will receive another destination, according to the deliberation of the Ethics and Integrity Committee.

4Facilitation Payments, Corruption and Bribes

Gifts andHospitality

SPIC Brasil/HPP São Simão does not agree with any practice of corruption, extortion, fraud, bribery, facilitation payments and money laundering.

Relationshipwith Public Administration

We do not adopt, do not encourage and do not admit the practice of any conduct that constitutes or results in acts that are harmful to public administration, national or foreign, as provided in the current legislation

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Contacts with third parties must follow specific standards and appropriate ethical conduct, avoiding situations of conflict of interest or any relationships that interfere, or appear to interfere, in the full exercise of business.

Third parties must not participate in any form of agreement, combination, cost manipulation, commercial strategy, division of markets and/or territories, as well as any other form of action that may restrict the free offer of products or services to the market.

We encourage free competition and prohibit our employees from sharing confidential data (commercial or operational) with any third parties, especially with participants in the commercial competition process, except when permitted by Brazilian law and contractual commitments with the Company.

Conflictof Interests

FreeCompetition

We do not approve any offer, promise, payment or delivery of money, presents, services, entertainment or any other benefit that characterizes an improper advantage or has the appearance of impropriety carried out, directly or indirectly, with any public or private agent. The receipt of commissions, presents and

personal privileges in the purchase of materials or other services creates conflicts of interest and damages the Company’s image. Therefore, they are not tolerated.

Private relations of SPIC Brasil/HPP São Simão employees with third parties that compromise business impartiality or that benefit private or individual interests to the detriment of the interests of the Company are considered conflicts of interest and are not allowed.

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Work

Our working relationships are based on respect for dignity, human rights and current legislation.

Employees, agents or contractors of third parties must respect the access, identification and permanence controls at the facilities of SPIC Brasil/HPP São Simão, this Code and other established labor standards.

Discrimination on grounds of color, age, gender, sexual orientation, ethnicity, regionality, nationality, disability, religion, political affiliation, union membership or marital status is not tolerated.

We expect that our third parties do not use child or slave labor, analogous or properly; do not engage in or support human trafficking; comply with all labor and tax obligations; as well as monitor and certify this requirement in its value chain, with the purpose to prevent and combat such practices with its suppliers, partners and counterparts.

5It is not allowed to promote electoral campaigns on the physical and virtual (e-mail, social media etc.) Company’s premises, in order to ensure equality for all candidates.

Healthand Safety

Third parties must guarantee the safety of their employees, even as compliance with the applicable legislation in force and the health and safety rules established by SPIC Brasil/HPP São Simão.

It is forbidden for third parties to use, sell or possess alcoholic beverages or illicit drugs within the premises of SPIC Brasil/HPP São Simão or remain on the Company’s premises if they are under the influence of such substances.

6We care for the physical integrity of our employees and demand that our third parties provide a safe and healthy work environment for their employees and associates.

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The carrying of a weapon of any kind on the Company’s premises is prohibited, except in the cases expressed in specific legislation, due to the activity developed within the company.

Environmentand Community

We work to transform natural resources into prosperity and sustainable development, which is why we value, respect and care for the environment and the community in which we operate, and we demand the same from our third parties.

We value third parties who contribute to ecologically sustainable development, seeking to continuously reduce the environmental impact of their inputs, operations, products and services.

We require that our third parties respect legal requirements and ensure that risks and possible environmental impacts are identified and controlled in accordance with applicable legislation.

Third parties must conduct their activities with a commitment to take measures that minimize the negative impacts on natural resources, the environment, its subcontractors and the community.

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Confidentialityof Information

Our third parties are not authorized to use or disclose the Company’s confidential information to which they have access, or which result from working with us, except when permitted by law or contractual commitments entered with the Company.

Third parties must protect all intellectual property rights, trade secrets and confidential information of the Company, as well as any type of personal or sensitive data that is granted to them.

8It is forbidden to obtaining, using, reproducing or disclosing privileged, relevant or confidential facts, data or information about SPIC Brasil/HPP São Simão is not yet disclosed to the market, for its own benefit or for the benefitof third parties.

We do not authorize the holding of a lecture, seminar or academic work on the Company’s processes and business without authorization from the CEO and in line with the area’s Director.

Monitoringand Compliance

For the purpose of monitoring our third parties’ commitment to this Code, we reserve the right to conduct due diligence prior to contracting, and to conduct - if necessary - audits of third parties’ facilities or business practices, directly or through a third-party representative.

Upon request, the third party must provide written documentation on the actions implemented that demonstrate compliance with any of the requirements provided for in this Code.

We expect our third parties to commit to the request for this code and request formalization by signing the Term of Aware and Commitment.

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EthicsChannel

SPIC Brasil/HPP São Simão encourages its employees and third parties to report any violations of the guidelines of this Code, current legislation and other corporate policies of which they are aware in our Ethics Channel.

We have a proactive, transparent, independent, impartial and anonymous communication tool for reporting violations or suspected non-compliance with any of the points described in this Code.

Retaliation against whistleblowers who, in good faith, report violations and irregularities are prohibited. We reinforce this protection through specific internal policies and processes.

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Contacts:E-mail: spicbrasil@linhaetica.com.brWebsite: www.linhaetica.com.br/etica/SPICBrasilPhone: 0800 713 0109 (available from Monday to Friday, from 8 a.m. until 8 p.m.)Zip Code: 79518

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Director, employee, agent, supplier, subcontractor or any other individual or entity related to the Third Party in carrying out its activities with or on behalf of SPIC Brasil/HPP São Simão.

Associates

Every person who is engaged in the Company’s work activities, whether own or third party, including directors, officers, managers, employees and interns.

Employees

It covers but is not limited to cultural events (such as theater, opera and concerts), sports (such as football, tennis and volleyball) or any other similar activities or events.

Entertainment

They are payments made to guarantee or speed up routine actions or, otherwise, induce public agents or third parties to perform routine

FacilitationPayment

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Individual or legal entity, including its subsidiary and affiliated companies, that supplies products or provides services to SPIC Brasil/HPP São Simão or on its behalf, including its subcontractors.

Third Party

It covers, but is not limited to meals, alcoholic beverages, accommodation, travel, tours and transportation offered to any employee of the Company.

Hospitality I declare for all purposes that we have received a physical and/or digital copy of the SPIC Brasil/HPP São Simão Code of Conduct for Third Parties with guidance on the main ethical and socio-environmental aspects expected in the relationship with the Company.

I further declare that I have read the entire contents of this Code, I understand its importance and committing myself to comply with them in full in all my business relations.

I also commit to disclosing the values of this Code to my representatives, employees and suppliers.

¹ Person designated by the third party to act and respond on his behalf, representing him in negotiations throughout the commercial relationship with SPIC Brazil, regardless of having direct contact with the negotiation processes and activities.

Company

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Legible name of the legal representative¹

Position of legal representative

Place and date

Signature

Term of Awareand Commitment

Any person who holds a position, job or public function, which may be civil servants, public employers or individuals, acting in a transitory or unpaid manner, by election, appointment, contracting or any other form of relationship with the government entities can be considered public agents.

Public Agents

actions that they are required to perform, such as issuing licenses, immigration controls or releasing goods held at customs. This does not include legally applicable administrative fees.