The ethical principles that guide our actions and also underlie the solid and reliable image of KREITON CALDEIRARIA E USINAGEM LTDA are firmly supported by pillars consisting of this code of ethics and conduct, by our Mission, our Values and the Quality Policy of the Management System.

1. Kreiton´s Ethical Principles

Compliance with applicable laws and regulations, including the law nr. 12,846 of 01/08/2013, constitutes a fundamental principle of KREITON. KREITON´s decisions include justice, legality and good governance and accounting practices.

Honesty, respect, loyalty, responsibility, decency, zeal, effectiveness, quality, trust, transparency, safety and awareness of the ethical principles are the greater values that guide the relationship of KREITON with the stakeholders with whom it relates.

KREITON seeks to achieve increasing levels of quality and profitability, with competency and social responsibility, valuing its Employees by prioritizing the issues of health, safety and preservation of the environment.

KREITON neither supports nor promotes the practice of fraud of any kind.

KREITON is committed to comply with applicable law, including, but not limited to: anti-corruption, practice of fair competition, no agreement with piracy, tax evasion and smuggling, and its operations must be in accordance with such principles.

It is the duty of all employees to comply with and enforce the provisions of this Code, being the leaders assigned additional duty to disseminate and ensure compliance with this Code in their respective areas of work.

Any induction of third parties to perpetrate illegal acts or collaboration with these do not reflect KREITON´s principles, and those responsible for such conduct shall be properly punished disciplinarily, regardless of the foreseen legal penalties.

2. People Management

The criteria used for admissions and promotions shall meet the requirements of each function that foresee principles encompassing potential abilities, skills, values, etc. KREITON shall not make any discrimination based on age, marital status, race or color, country of origin, philosophical or political conviction, religion, sex, physical or mental disability, sexual orientation or identity of the individual.

3. Conduct and Responsibilities of Employees

Matters which relate solely to the company, without exception, shall be treated with all due confidentiality, because every Collaborator should know that breeching of this Code of Conduct and Ethics may result in disciplinary action or even contract  termination, depending on the severity of the occurrence.

All employees shall perform their activities and conduct company´s business issues with due transparency and strict adherence to the law, with respect to the principles and guidelines of the company, to the human rights and the environment. They are responsible for ensuring KREITON´s reputation and interests and for taking the appropriate measures, if they have knowledge of irregularities committed by third parties.

Every Employee has the responsibility to know and practice the provisions of this Code of Conduct and Ethics. Their relationship with Clients and Suppliers shall be based on principles of transparency and correctness, thus upholding KREITON´ name and image.

4. Behavior in the Workplace

KREITON expects from its Employees a decent, honest conduct, with respect, trust and warmth socially speaking, regardless of hierarchical position, position or function.

Everyone is responsible for maintaining a work environment where mutual respect, courtesy and serenity prevails, and where there aren’t any facts that may result in any constraints or cause inappropriate situations.

Moral or sexual harassment will not be tolerated and any other  misconduct that may or will characterize harassment and, if it occurs, it shall be reported to senior management.

5. Business Relationships

Trade relations shall always be conducted in compliance with legal and market practices and, in particular, with the rules on economic and competition defense, both nationally and internationally.

It is strictly prohibited for KREITON´s employees to favor improper benefits or in disagreement with the legal market practices, to make any payments that are considered unethical or can cause doubts, favoring Clients and Suppliers to the detriment of others and privileges or advantages to private, public or equivalent officials, both directly and through third parties.

5.1. Clients

KREITON cares about the satisfaction of its Clients, and this causes the basic principles of their actions to emphasize  quality, productivity, competitiveness, social community responsibility and the environment.

5.2. Competitors

KREITON respects its competitors and seeks to overcome them ethically and transparently, by offering better products and services. Attitudes that can result in slandering or back-biting of competitors.

Agreements aimed at abuse of economic power or arbitrary commercial practices shall not be promoted with competitors.

5.3. Public Power (National or Foreign)

KREITON’s relationship with public authorities shall be based on professional attitudes. Any form of pressure or request that does not correspond to this definition, shall be contested and immediately communicated to Top Management.

KREITON has as its business philosophy to comply strictly with the legislation where it operates and expects the same behavior from its professionals. It considers, however, that it is legitimate to contest legal or abusive actions, discriminatory or incorrect taxing, which will be done through administrative or legal actions in the competent powers.

It is expressly forbidden to all its employees to offer or promise, directly or through third parties, payments, gifts or benefits and advantages to public officials, as well as to relatives or similar to any of the previously described, in order to get the benefit for the company and to mitigate fraud practice in bids with public agents.

Offering hospitality, tokens and gifts must be associated with the dissemination of KREITON´s image and shall never characterize the intent of institutional gain or advantage.

5.4. Suppliers

The relationship with Suppliers and other partners shall always be guided by the search for quality, productivity, competitiveness, social and community responsibility, and environmental responsibility. Because of this, everyone shall be evaluated through criteria that meet KREITON´s expectations, mainly cost effectiveness, technical and financial reliability and integrity.

6. Conflict of Interest

The conflict of interest occurs when an employee influences or may influence a KREITON´s decision that results or may result in a personal gain, directly or indirectly, for himself/herself, for family members or friends.

The activities carried out shall neither conflict with the company’s interests nor compromise its integrity, confidentiality and safety.

6.1. Money

Employees are forbidden to receive money from Suppliers. If proposed, the money must be refused and the immediate Supervisor or Top Management be informed, being applied the penalty corresponding to the Supplier concerned (e.g. disqualification and/or suspension of registration).

6.2. Gifts/Tokens

Accepting personal gifts in the form of products or services is prohibited.

Gifts/tokens shall contain the Supplier´s logo, trademark or name or have a limited corresponding value that does not violate the laws or internal rules and feature personal advantages.

6.3. Invitations for Meals, Events and Travels

Sporting and cultural events and meals can only be accepted for maintenance and professional development of the relationship with Suppliers.

The sole purpose of travels shall be professional for technical / commercial purposes (e.g., inspection, Evaluation and development of Suppliers or Cooperation Agreements, etc.). Recreational trips are prohibited.

7. Political and Trade Union Activities

There are no restrictions to party-political activities of its Employees, provided they do not interfere with their professional responsibilities, without any effect on their performance, being respected the individual right of individual employees and partners regarding their  political and trade union involvement, recognizing the freedom of association and collective bargaining agreements.

8. Donations, Contributions, and Sponsorships

Donations will only be made and allowed if they are transparent, tax deductible and when it may be possible to justify their reason and destination.

Donations will not be made and are prohibited to individuals, political parties, candidates for public office and political posts, religious institutions and/or any organization/institution that represent risk to KREITON´s reputation.

Any contributions aimed at sponsoring must be transparent, be based on a formal contract and possess legal business purpose. Contributions to events organized by persons or organizations / institutions cited in the previous paragraph are not allowed.

9. Use and Preservation of Goods

All employees are responsible for the conservation of KREITON´s assets such as industrial plant, machinery, vehicles, equipment, furniture, etc.

The use of resources such as internet access and telephone, as well as the use of emails and of the installed computer infrastructure, shall be restricted to the professional activity of the Employee.

10. Accounting Records

The records must be made in a true manner, in compliance with what determines the legislation, tax rules, based on correct and legitimate documentation (so as not to characterize payments of disguised values). The accounting entries and records are available to Top Management, external independent auditing and controlling authorities present at KREITON´s units.

11. Occupational Health and Safety, Environment - SMS

KREITON is committed to achieve the goals established and continuously improve its products and processes, respecting the environment, occupational health and safety, by extending this demand to its employees, service providers, suppliers, clients and visitors.

In order to achieve this, it continuously seeks to comply with the prevailing Legislation concerning the Environment, Occupational Health and Safety and other Requirements applicable to KREITON´s business.

12. Use of Forced Labor and/or Child Labor

KREITON neither tolerates, allows and supports the use of forced labor and/or child labor in any process related to the company’s activities, nor with the activities of its partners, Clients and Suppliers.

13. Ethics Committee

Top management can install, whenever necessary, a non-permanent Ethics Committee, that will be responsible for investigating complaints related to the Code of Conduct and Ethics, related to suspicion of fraud and/or corruption, as well as for establishing criteria for cases not provided for in the Code.

14. Commitments Undertaken by KREITON

Any verbal or written complaint made to KREITON´s Human Resources Department will be treated with the following criteria:

1. Confidentiality of complaints and the source, even if the person wants to identify himself/herself.;

2. Guarantee of anonymity;

3. Prohibition of retaliation of any kind, for those who do, investigate and decide on any disciplinary action/penalties related complaints, if applicable.

4. Verification of all claims and never erase and/or delete any registry;

5. Application of the relevant disciplinary measures, whenever there is a deviation from the Code of Conduct and Ethics, regardless of hierarchical level, technical knowledge, performance, level of friendship, etc.

15. Final Considerations

The present Code of Conduct and Ethics  shall remain in force indefinitely, with any eventual updates, within a period not to exceed two years.

The guidelines set out herein this Code of Conduct and Ethics will be made known to all KREITON´s Employees.

Revision 00 – September/2017
Top Management