RB Group is committed to managing its business ethically and honorably, supporting the laws, rules and regulations in force in the country, in an honest manner with shareholders, business partners, government authorities, the public, as well as with its employees. RB Group seeks to build trust through an ethical, socially and ecologically responsible organization based on the following principles:

• Compliance with Laws, Rules and Regulations.

RB Group strives to conduct its business in compliance with applicable laws, rules and regulations and in accordance with high ethical principles. The Group also undertakes to comply with the codes applicable to the segments in which it operates.

Our reputation for integrity, quality, and honesty is based on this commitment and helps us to achieve long-term success.

• Corporate Responsibility

RB Group is dedicated to acting in an economically, socially and environmentally responsible manner, being committed to the principles of sustainable development, committed to making efficient use of natural resources and to minimizing the environmental impact of its activities and products over their life cycles. The health and safety of all employees, neighbors, customers, consumers, and other individuals impacted by your business activities, as well as the protection of the environment, have high priority.

RB Group also ensures that its processes, technologies and products meet the most stringent applicable quality and safety standards. Quality management is an integral part of all operations.

• Antitrust Law and Fairness in Business

RB Group believes that fair competition contributes to consumer welfare. It strives to promote business in an active, competent, and ethical manner. To this end, it follows all applicable antitrust, competition, and fair trade laws in all markets where it operates, without taking unfair advantage of third parties, whether customers, suppliers, or competitors.

• Anti-Corruption Practices

RB Group opposes corruption and bribery and does not accept practices aimed at obtaining business by illicit means. No company employee is permitted to offer, receive or accept any kind of benefit to or from business partners that might compromise or appear to compromise the ability to make objective and commercially fair decisions.

• Confidentiality of Insider Information

RB Group prohibits its employees from using privileged information. This applies particularly to those who have access to such information about the company or affiliates or a company with which the Group does business. Insider information may relate to, for example: plans; new products or processes; mergers, acquisitions or sales of businesses or securities; problems faced by RB Group or a company with which it does business; sales; profitability; negotiations concerning significant contracts or business relationships; significant litigation; or financial information.

If the information is such that a potential investor would consider it significant in making an investment decision, the employee who holds the information may not provide it to third parties until it becomes public. In addition, employees must not buy or sell shares in any other company about which they have obtained non-public information, or provide it to others, until it becomes public. Using private information in the above way can also be considered illegal.

• Fair Labor Conditions

RB Group is a socially responsible employer and recognizes that its employees are a very strong point. The Group seeks high commitment from these employees and, in return, shares its success with them, committing itself to providing a work environment that values diversity and the richness of the corporate culture. Human resources policies and activities should contribute to the creation of a workplace where everyone has the opportunity for professional and personal growth. RB Group respects each individual and provides an open environment for the exchange of ideas, criticism and opinions.

It is also committed to creating equal employment opportunities for all and does not accept discrimination or harassment of any kind. Threats or acts of violence and physical intimidation are prohibited, as is the use of illegal drugs in the workplace.

• Environment, Health and Safety

RB Group’s employees must commit to the protection of the environment, controlling the environmental aspects of their activities, as well as for their personal health and that of their coworkers, and for the work environment, eliminating eventual unsafe acts in the execution of their tasks.

• Forced Labor

RB Group contributes to the elimination of all forms of forced labor performed under coercion, i.e. all work or service which is not performed voluntarily and which is exacted from an individual under threat, by force or as a punishment. Workers cannot have their documents withheld or be required to make deposits as a condition of being hired or fired. There is no evidence of practices indicative of forced or compulsory labor, including,

among others, the following:

• Physical and sexual violence;
• Forced Labor;
• Withholding of wages/including payment of employment taxes and/or payment of deposit

to start the job;

• Restriction of mobility/movement;
• Withholding passports and identity documents;
• Threats to report to the authorities.

• Child Labor

RB Group does not engage in or support the use of child labor (under 18 in locations subject to real or perceived hazardousness, and not under 16 in non-hazardous facilities). Respects the rights of the child, as expressed by ILO Resolution 146.

• Conflict of Interest

A “conflict of interest” exists when a person has a personal interest that differs from those pursued by the company. In such situations, the company’s interests must not be compromised. Conflicts of interest can arise in various situations, such as the ones mentioned below that require special attention:

• Employees must not receive improper personal benefits as a result of their positions within the company or obtain personal enrichment through access to confidential information.
• RB’s employees should not accept, under any circumstances or pretext, gifts from suppliers and/or business partners without prior authorization or consent from the company’s board of directors. Only promotional materials with the company’s logo can be accepted without prior authorization.
• RB Group’s employees should, whenever possible, be accompanied by another employee when invited, on behalf of the company, to attend sponsored events (lunches, parties, among others) by companies that have or may come to have business with RB Group.
• All employees have a duty to comment on the legitimate interests of RB Group when the opportunity to do so arises. They must not take advantage of opportunities, use corporate property and information, or their positions for personal gain, or compete directly or indirectly with the company.
• Employees must not hold positions in any outside commercial organization that could adversely affect their motivation or performance, unless such service is specifically approved by the company.
• RB Group encourages its employees to engage in community service in their local communities and in philanthropic activities. However, you must ensure that all these external activities, even if philanthropic or voluntary, do not constitute a conflict of interest and are compatible with your duties in the company.
• Any conflict or potential conflict of interest must be communicated and discussed with the respective superiors.

• Record Retention and Reporting

RB applies the highest quality standards to information recording. All financial statements and company books, records and accounts – whether kept in electronic files or printed on paper – must reflect transactions and events accurately and in accordance with legal requirements, accounting principles, and also with the company’s internal accounting system. Dishonest communication within the company, or to organizations or persons outside the company, is expressly forbidden. RB Group is committed to providing complete, accurate, timely and understandable information in all reports and documents filed with or submitted to it in accordance with Brazilian laws and other public communications.

• Asset Protection and Proper Use

Collectively, employees have a responsibility to safeguard and make proper and efficient use of RB Group’s properties. Each employee also has the obligation to protect the company’s assets from loss, damage, misuse, theft, embezzlement, or destruction. Any situations or incidents that could lead to such facts must be immediately communicated by employees to their respective superiors.

• Confidentiality and Privacy

Information is one of RB Group’s most valuable corporate assets, and open and effective disclosure of it is essential to its success. However, much of the company’s business information is confidential or proprietary, and such confidentiality must be maintained except when its disclosure is authorized by the company or required by laws or regulations. These rules apply specifically to intellectual property such as trade secrets, patents, trademarks and copyrights, as well as business, marketing and service plans, engineering and industrial know-how, designs, databases, records, salary information or any unpublished financial data or reports.

• Responsibility

All employees must comply with the standards set out in this Code. Violations of the Code will have consequences. In serious cases, these consequences can include removal from office and dismissal.

• Non-discrimination in employment and occupation

RB Group values diversity and values non-discrimination of any kind, race, color, political conviction, gender, religion, sexual orientation, age, place of birth, disability, among others.

In our recruitment, selection, and promotion processes, candidates must be evaluated only for their competencies and conditions to meet and adapt to the expectations of the position, and decisions based on prejudice, favoritism, or even privileges of any nature will not be accepted.

• Freedom of association and the right to collective bargaining

RB Group respects the freedom of association with trade unions and/or other organizations and the effective right to voluntary collective bargaining between employers or employers’ organization and employees’ organization for the regulation of terms and conditions of employment through collective agreements or negotiations.