Code of Ethics and Conduct

The Code of Ethics and Conduct is a document approved by Engetron’s Management, intended to define the principles of conduct in the Company’s business activities, as well as the commitments and responsibilities of employees in their professional relationships.

The Code of Ethics and Conduct establishes a commitment to the values of honesty, integrity, and transparency in all commercial relationships.

The Code of Ethics and Conduct applies to Engetron’s executives, all employees, and partners who establish business relationships with the company.

The Code of Ethics and Conduct is communicated to all employees through training and is made available in the Standards directory. It may also be requested at any time from the Human Resources Department.

The Code of Ethics and Conduct is subject to revisions that may be carried out based on contributions submitted by employees or third parties, or in response to regulatory developments, laws, and other requirements.

Any modifications made to the Code of Ethics and Conduct will be published and made available through the channels indicated above.

Engetron recognizes that the commitment and professionalism of its employees are essential factors in maintaining competitiveness, creating value for shareholders, and ensuring customer satisfaction. The principles outlined below reinforce the importance of respecting the individual in accordance with national laws, guaranteeing equal treatment, and eliminating any form of discrimination.

The Code of Ethics and Conduct is an integral part of Engetron’s employment contract, and all employees must comply with its provisions.

Any violation of the Code is therefore considered a serious offense and may result in the application of appropriate disciplinary measures.

Employees who hold coordination, supervision, leadership, management, or executive positions must serve as examples of leadership and guidance, in accordance with the business conduct principles outlined in this Code. Through their behavior, they must demonstrate to other employees that respecting the Code is a fundamental aspect of their work, ensuring that everyone understands that business results must never come at the expense of the principles established in the Code of Ethics and Conduct.

All individuals in leadership positions must ensure that every case of noncompliance with the Code of Ethics and Conduct is reported and have the duty to ensure its enforcement.

• Fulfill their employment contract with dedication, productivity, technical quality, attendance, and punctuality;
• Act honestly, fairly, courteously, and with availability and attention toward all people they interact with, internally and externally, respecting all individual differences;
• Express opinions, suggestions, complaints, criticisms, and reports with the purpose of continuous process improvement, using the appropriate internal channels;
• Refrain from engaging in any activity that, even indirectly, violates the Code of Ethics and Conduct or conflicts with Engetron’s activities, and report to their superiors or the Ombudsman any situation that may constitute an actual or potential conflict of interest;
• Respect professional confidentiality, except when authorized or required by law;
• Keep confidential the strategic information they have access to and ensure others do the same, except when authorized or required by law;
• Make proper use of Engetron’s tangible and intangible assets according to their legitimate purpose, and never use them for personal gain;
• Not obtain improper advantages arising from the position or role they hold in the company;
• Not engage in nor tolerate acts of prejudice, discrimination, threats, blackmail, false testimony, moral harassment, sexual harassment, or any conduct contrary to the principles of this Code of Ethics and Conduct, and immediately report anyone who engages in such acts;
• Respect intellectual property and acknowledge the merits of work developed by colleagues, regardless of their hierarchical position;
• Protect life, physical integrity, and the safety of people, safeguard company facilities, and preserve the environment, including the workplace environment;
• Not request, insinuate, accept, or offer any kind of favor or advantage in exchange for their professional activities;
• Maintain personal appearance and attire appropriate for the work environment in which they operate.

• Provide appropriate working conditions for all employees, enabling a balance between professional and personal life;
• Ensure workplace health and safety by providing all necessary conditions and equipment;
• Offer formal communication channels to receive and process employee suggestions aimed at improving the company’s internal processes;
• Preserve privacy rights when handling employees’ medical, functional, and personal information;
• Respect employees’ participation in labor unions and refrain from any form of discrimination against unionized employees;
• Respect and promote diversity and combat all forms of prejudice and discrimination through a transparent policy for hiring, training, career advancement, promotion, and termination. No employee or job candidate will receive discriminatory treatment based on race, skin color, ethnic origin, nationality, social status, age, religion, gender, sexual orientation, personal appearance, physical, mental, or psychological condition, marital status, opinion, political belief, or any other individual differentiation factor;
• Promote equal opportunities for all employees at every stage of the employment relationship—such as hiring, training, compensation, promotions, and transfers. Employees must be treated according to their ability to meet job requirements, avoiding any form of discrimination;
• Foster a company culture that values knowledge sharing and dissemination, promote continuous development of employees, and avoid layoffs whenever possible;
• Provide institutional safeguards and protect the confidentiality of all parties involved in ethical reports, in order to preserve rights and ensure neutrality in decision-making.

Confidentiality

The knowledge developed by Engetron constitutes a proprietary resource of the company, and each employee must ensure its protection. Improper disclosure of such knowledge may cause financial and reputational harm.

Therefore, employees and other recipients may not disclose to third parties any information related to the company’s technical, technological, or commercial knowledge, as well as other non-public information related to the company, except when such disclosure is required by law or court order.

The confidentiality obligations outlined in this Code of Ethics and Conduct remain in effect even after the end of the employment relationship.

Data Protection

All data eventually collected by Engetron and its employees during the performance of their activities shall be used solely and exclusively for providing the specific services for which the data was intended.

All data eventually collected by Engetron—whether from customers, employees, or business partners—will be used exclusively for the purpose for which it was provided and will be processed only within the limits of applicable contracts and the law.

Engetron commits to making available, confirming, deleting, or rectifying any data when requested by its owners, whether employees, customers, or business partners.

Any requests related to data processing must be made through the channel
ouvidoria@engetron.com.br, and will be duly answered within the legal deadline of 15 (fifteen) business days, after confirmation of data ownership.

Data eventually collected by Engetron will be discarded within the legal timeframe and/or when the need for processing has ended.

Guidelines

• Conduct business with honesty and transparency, building credibility with shareholders, employees, suppliers, customers, partners, government entities, the press, the communities in which it operates, and society in general, while remaining competitive with social and environmental responsibility;
• Disseminate the principles and behavioral commitments expressed in this Code of Ethics and Conduct to all interested parties, both internal and external;
• Maintain relationships with competitors based on honesty and respect, adopting explicit and declared rules regarding its competitive practices;
• Promote fair and honest negotiations, without obtaining undue advantages through manipulation, misuse of privileged information, or any similar practices;
• Prepare reports and financial statements correctly, consistently, accurately, and completely, without ambiguous information, and make its records fully transparent to internal and external audits and to the competent public authorities;
• Maintain Ombudsman offices for receiving, forwarding, and processing opinions, suggestions, complaints, criticisms, and reports of ethical violations from various stakeholders, in compliance with applicable legislation;
• Engetron provides communication channels for its customers and suppliers to submit complaints, concerns, suggestions, or reports through the emails
  altadirecao@engetron.com.br and ouvidoria@engetron.com.br. In addition, Engetron provides channels for employees to submit suggestions, complaints, and reports, always preserving the employee’s anonymity and ensuring complete impartiality in addressing the matters presented.

Engetron and its employees must establish and maintain relationships with various external audiences acting with loyalty, honesty, transparency, and due respect for the Company’s core values.

Customers

Engetron aims to maintain continuous development of solutions and services that ensure customer satisfaction with highly reliable electrical power, optimizing results, seeking customer satisfaction, committing to meeting applicable requirements, and continuously improving the quality management system.

In this regard, the company requires its employees and other recipients of the Code of Ethics and Conduct to ensure that every business relationship and customer interaction is based on honesty, professionalism, and transparency.

Employees must follow internal procedures to achieve this goal, in order to develop and maintain long-term relationships with customers, offering safety, support, and quality.

In its relations with customers, Engetron must avoid discrimination and must not misuse its contractual power in a way that harms any customer.

Engetron is committed to providing products and services described clearly and accurately, meeting technical, regulatory, commercial, tax, fiscal, and other requirements, ensuring a transparent and honest relationship with customers, in full compliance with national legislation.

Suppliers

Suppliers play an important role in improving Engetron’s competitiveness. To continuously ensure the highest level of customer satisfaction, the company selects suppliers based on their ability to deliver quality, innovation, cost efficiency, and service.

Employees must select suppliers in accordance with established procedures, considering the quality, innovation, costs, and services offered, as well as the values stated in the Code of Ethics and Conduct. They must also establish and maintain stable, honest, ethical, transparent, and collaborative relationships with suppliers.

Public institutions

Relations with public institutions must be handled exclusively by employees designated for this purpose. Such relations must be transparent and guided by Engetron’s values.

When a public institution is a customer or supplier of Engetron, actions must comply strictly with the laws and regulations governing the acquisition or sale of goods and/or services to that specific institution.

Labor unions and political parties

The company’s relationships with labor unions, political parties, and their representatives or candidates must be established within the highest principles of transparency and integrity.

Financial contributions are permitted only when expressly required or allowed by law.

Any contributions made by Engetron employees, as well as any activities performed by them, must be understood exclusively as personal and voluntary.

Communities

Engetron and its employees must maintain respectful relationships with the communities where they operate, acting in a socially responsible manner and contributing to a clean environment and a healthy, safe workplace.

Engetron does not use child labor—in other words, it does not employ individuals below the minimum legal working age. Additionally, the company is committed to avoiding business with suppliers or partners who use child labor as defined above.

Engetron opposes any form of forced labor, whether implicit or explicit, always maintaining cordial and respectful relationships with employees and ensuring full compliance with national labor laws as well as the provisions of the Collective Bargaining Agreement of the union to which Engetron is affiliated.

Relations with the media

Contact with the media must be conducted only by employees responsible for communication and marketing.

All other employees must not provide non-public company information to the media, nor have any type of contact aimed at disclosing confidential company information.

The brand is one of our greatest assets.

The brand and its representations (colors, graphics, architectural patterns, among others) must always be used in accordance with the standards defined by the Marketing department, which establishes our strategic positioning and the visual and verbal guidelines that are part of our brand.

All employees are expected to use and disclose our brand only with the guidance and approval of Marketing and the relevant Executive Board.

Engetron is present on the main social media platforms and has employees responsible for managing content and interactions with the market and society in general. However, it is important to remember that protecting Engetron’s image is everyone’s responsibility. The following behaviors are expected:

• Forward any customer complaint posted on social media to the responsible department so it can be handled appropriately;
• Do not share Engetron’s or its customers’ information or comments on social media, whether on your own profile or on third-party profiles;
• Understand that the guidelines regarding information confidentiality also apply to social media;
• Understand that any information shared is the responsibility of the employee and not of Engetron;
• Do not associate personal activities with Engetron’s name or brand;
• Do not post internal Engetron events that contain strategic and/or confidential information, images of protected internal environments, confidential data, and similar content.

Information published on the internet can be viewed by a large number of people and is not easily removed or deleted. Any disclosures must not violate Engetron’s internal policies or applicable laws.

Engetron, its employees, and other recipients commit to respecting the highest standards of integrity, honesty, and dignity in all relationships inside and outside the company.

No employee shall, directly or indirectly, accept, request, offer, or pay money, gifts, or donations, even when under illicit pressure.

Engetron does not tolerate any form of corruption involving public officials or any other party linked to or associated with public agents. Therefore, each employee must avoid situations in which personal interests may conflict with the company’s interests.

Engetron does not tolerate participation in any form of corruption or bribery, including payments or any other type of benefit granted to any customer or supplier to influence decision-making. Every employee must report to the company’s top management any approach or attempt to violate these rules.

Engetron and its employees must never be involved in activities that imply “money laundering” (receiving or contracting) or any other form of criminal activity.

The Company and its employees must, in advance, verify available information (including financial information) about business partners and suppliers, in order to understand the respectability and legitimacy of their activities before initiating any type of business with them.

Engetron employees must not accept or offer gifts, gratuities, loans, courtesies, discounts for personal transactions, trips, or any other benefits or advantages for their own gain or for third parties with whom the company maintains commercial relationships.

Engetron will offer its clients only symbolic gifts, solely for the purpose of promoting its brand. Every employee must report to the company’s top management any approach or attempt to violate these rules.

Engetron is committed to complying with the competition laws applicable in the markets in which it operates.

The Company and its employees do not engage in actions that may represent violations of competition laws (such as cartel formation, market division, production or sales restrictions, conditional agreements, etc.).

The Company is also committed to not violating the intellectual property rights of third parties.

Engetron employees must not be exposed to unnecessary risks that may cause harm to their health and/or physical integrity.

The Company is committed to effective health, safety, and environmental management, and all employees share responsibility with the Company for ensuring proper management in these areas.

Engetron and its employees commit to keeping the company’s facilities clean at all times, maintaining an organized and pleasant workplace.

The following behaviors must be adopted:

• Save energy;
• Avoid pollution;
• Continuously optimize the use of resources;
• Develop products that are increasingly environmentally compatible;
• Preserve company facilities, keeping them always clean and organized.