CODE OF

 CONDUCT AND ETHICS 

The purpose of this code of conduct is to consolidate the ethical principles that govern the Brasilata family, guiding internal and external relations.

Parties interested in Brasilata's business must be aware of this code and strictly observe its terms, especially when negotiating.

1. Company guidelines

1.1 Vision

To remain among the most profitable companies in the sector, providing shareholders with an adequate return on their invested capital over the long term.
To be recognized globally as the most innovative company in the segment in which it operates (General Line). Maintain leadership in the Brazilian market.
Be at the forefront of knowledge and development of people, products, processes and forms of management.


1.2 Mission

Increasing company value through excellent return on investment.
Stimulating the creation of knowledge and acting globally in its commercialization.
Developing new packaging solutions, predominantly made of steel.

1.3 Values

Profit is the way to keep shareholders interested in the business, developing the company's growth. An organization's achievements are the result of the combined efforts of each individual who belongs to it. Everyone is responsible for profitability and benefits from it through profit sharing.
Development and appreciation of the Brasilata woman and man, through participative management and long-term employment relationships based on a fair balance between duties and rights.
Long-term relationships with customers, based on trust and coherence, through the supply of products and services that meet their needs and exceed their expectations, with innovation as a way of differentiating and creating value.
Long-term, ethical and coherent relationships with suppliers, in order to obtain the best quality inputs at competitive costs, with security of supply.
To be an ethical and positive entity in the communities in which it operates, rigorously exercising its social and environmental responsibility.

1.4 Management Policies

1.4.1 Personnel Administration Policy

For Brasilata, the human being is a value above all others. As a competitive strategy, the company has chosen to create value through innovation, the only source of which is people.
Thus, the Brasilata Woman and Man are directly responsible for the ideas that give rise to innovations. Each employee is therefore hired with the full inventive function and for this reason is called an inventor.
The Brasilata Woman and Brasilata Man are valued for their respect, camaraderie and pride, which are consolidated by the stability of the workforce.
The communication channels are continuously open through the Simplification Project, where everyone can express their ideas and demands freely and are guaranteed a quick response.

1.4.2 Health and Safety Policy

The company continually seeks the safety and well-being of its inventors, constantly investing in improving working conditions and training. For Brasilata, safety is a priority and a condition of employment.
Specific legislation is complied with absolutely rigorously, with a commitment to continuous improvement in occupational health and safety management.

1.4.3 Diversity Policy

The search for diversity is a direct consequence of the search for innovation. The company permanently believes that "success comes much more from the sum of differences than from the sum of equalities".
Diversity is therefore encouraged, whether by gender, color, religion, age, sexual orientation or physical or mental disability.

1.4.4 Quality policy

Brasilata's goal is to provide products and services that meet the needs and exceed the expectations of its customers.
The company seeks the effectiveness of its Quality Management System by continuously improving its processes, supporting new management styles and changes in technology.
Decisions are made to strengthen long-term relationships with shareholders, employees, customers, suppliers and the community.
Training is carried out on an ongoing basis with all employees in order to empower them.
Our people are managed with the aim of making each employee a partner in the organization's objectives.

1.4.5 Environmental policy

Brasilata, as a transformation industry, is aware of the possible impacts it can have on the environment and its responsibility to promote sustainable development. Its policy is to prevent pollution by controlling its production process and strictly complying with current environmental legislation.
In other words, through continuous improvement, it constantly seeks to reduce the consumption of natural resources, raw materials and energy.

2. The Company's Ethical Commitment

2.1 Stakeholder relations

Brasilata's controlled, controlling or affiliated legal entities and individuals who are members of management with decision-making power and/or their family members are considered interested parties. In these situations, there is a conflict of interest, since the decision-making process on the issue may result in a gain for these related parties or for third parties with whom they are involved and interfere with their capacity for impartial judgment. In such circumstances, the director must declare that he/she is prevented from deliberating on the matter and abstain from the decision.
Brasilata's relationship with its different stakeholders must always be based on honesty, integrity and transparency, and the policies must be compatible with the company's values.

2.2 Relations with Shareholders

Brasilata seeks an adequate return on invested capital to keep shareholders interested in the business. The principles of good corporate governance are pursued.
Despite being a family company with a small number of shareholders, the financial reports seek to follow the rules of publicly traded companies, not least to facilitate an eventual public launch of shares.

2.3 Customer relations

Our quest to satisfy and exceed our customers' needs is based on a long-term relationship based on innovation, quality products and services, and punctual delivery.

2.4 Relations with suppliers

Brasilata seeks a long-term relationship with its suppliers, prioritizing quality and guaranteed supply, under market conditions and always guided by the same conditions it has with its customers.

2.5 Relations with Inventors (Employees)

The long-term relationship with inventors is guided by the fulfillment of rights and duties.
Freedom of expression is officially valued by the Simplification Project. The channel of communication with management is permanently open.
Tolerance for errors: innovation doesn't happen without errors, so the company considers that the costs of well-intentioned errors, as long as they are acknowledged, are part of the training costs.

Every quarter, the Board of Directors communicates the company's financial situation to all inventors in a face-to-face meeting.

2.6 Relations with society

Brasilata complies strictly with the law, especially with regard to taxes, despite the high tax burden in Brazil.
Tax evasion is not allowed, which could lead the company to compete at a disadvantage in some markets. Brasilata prefers not to compete in such markets.

3. Ethical Commitments of Inventors

3.1 Commitment to Innovation and Continuous Improvement

The company expects all its inventors to be committed to innovation and continuous improvement in the search for both product differentiation and process efficiency. The Simplification Project is the channel through which ideas and records of improvements flow.

3.2 Commitment to Asset Preservation

In addition to the obvious care taken to preserve the company's tangible assets (financial resources, stock, machinery, equipment and buildings), special care is expected to be taken with intangible assets (knowledge).
Brasilata invests heavily in innovation, in training its staff and in generating knowledge. Therefore, the unauthorized disclosure of internal knowledge and confidential information that could be used by third parties is considered a serious breach of conduct.

3.3 Commitment to coworkers

Treat other inventors with respect and politeness. Embarrassing an inventor is considered serious misconduct. Sexual harassment and bullying are particularly intolerable.

3.4 Teamwork

Brasilata values teamwork and informal groups, and the Simplification Project is a privileged channel for them to transmit their ideas and the records of the improvements made.

3.5 Customer relations

Satisfying and exceeding customer needs is Brasilata's strategic objective.
Customers must be served with attention and courtesy, and information must be truthful, clear and transparent.
Customer expenses related to meals, transportation, accommodation or entertainment are acceptable as long as they are justified by work reasons, within reasonable limits.

3.6 Relations with suppliers

Relations with suppliers must be loyal and long-term, in line with market principles.
Gifts and presents can only be accepted if they have a commercial value of no more than R$200.00 (two hundred reais). Above this, they must, in principle, be reported to the Ethics Committee and, if rejected, returned with thanks and explanations.
The hiring of company suppliers for private services must be previously reported to the Ethics Committee.

3.7 Relationship with Competitors

Brasilata's competitiveness must be based on the differentiation and excellence of its products and services and not on the disparagement of its competitors.
Therefore, no verbal or written statements should be made that could denigrate the image of competitors, and the competitor should be treated with the same respect that Brasilata expects to be treated with.

3.8 Conflict of interest

A conflict of interest occurs when the inventor may make or influence a Brasilata decision that results in some personal gain for him/herself, a family member or friends.
In the event of a conflict of interest, the expected attitude is for the inventor to declare him/herself barred or to communicate the fact to the Ethics Committee, which must decide whether or not to bar the inventor.

4. Ethics Committee

4.1 Duties
The Brasilata-CEB Ethics Committee is responsible for judging cases of violation of the Code of Ethics and determining any disciplinary actions.

4.2 Composition

The CEB is made up of the CDE-Executive Steering Committee and the General Coordinator of Our People-CGNP. When evaluating possible breaches of conduct, the manager responsible for the area in which the inventor works will also be part of the Ethics Committee.

4.3 Contact

4.3.1 Verbal

Verbal contact with any member of the CDE.

4.3.2 Electronic Message

Send an e-mail to cde@brasilata.com.br.

4.3.3 Anonymous Idea

Send an anonymous idea through the Simplification Project system.

4.3.4 Whistleblowing Channel
The whistleblowing channel can be activated through anonymous ideas, via the link https://psimp.com.br/denuncia_new.php?an=1 where any type of irregularity or dissatisfaction can be reported. All anonymous ideas are forwarded to the chairman of the Board of Directors, who analyzes them and forwards them to those responsible for verification and decision making.