Anti-Bribery and Anticorruption Policy

This corporate policy ("Policy") is intended to provide guidelines to PRODOIST, as well as any other person or entity working for or on behalf of PRODOIST, with respect to combating bribery and corruption, in addition to the definitions contained in the Compliance Policy, our Code of Ethics and Conduct.

This policy applies to all PRODOIST employees, as well as any other person or entity working for or on behalf of PRODOIST, located in Brazil or abroad (individually a "Person" and collectively "Persons").

All Persons must ensure that their actions on behalf of PRODOIST meet the same standards of integrity expected of PRODOIST employees.

It is the responsibility of the Compliance Officer to clarify any doubts related to this Policy, establish the procedures necessary for its implementation and to verify and communicate the rules established in this Policy. It is the responsibility of all PRODOIST employees to comply with the guidelines established in this document.

• Prohibits all forms of bribery and corruption. Company employees or third parties acting on its behalf must not offer, pay, give or promise anything of value promise anything of value to any person, company or government agency in exchange for an improper advantage.
• Prohibits payment of anything of value whenever the official suspects that the payment or thing of value may be provided to a third party for improper improper purposes.
• Prohibits inducing any individual to act unlawfully or improperly.
• Prohibits the receipt of things of value to obtain undue advantage under any pretext.
• Encourages and guides any person, internal or external, to report suspicions or weaknesses in the system, in a confidential and complete investigation process. and complete.
• Requires compliance with anti-corruption laws in all jurisdictions.
• Requires compliance with the system requirements.
• Ensures that there will be no reprisal for raising concerns, suspicions, or denial of activities with more than a low risk of bribery.
• Prohibits receipt of gifts, benefits and hospitality that could reasonably be perceived as bribery.
• It is committed to continuous improvement of the system.
• Upon receiving a denunciation, whether by report or through the Denouncement Channel, the Compliance Officer must initiate the treatment and investigation within a maximum period of 2 days. maximum of 2 days.

In case of doubt about the perception of compliance of any item, the Compliance Officer or the Board of Directors must be communicated, which will analyze and respond to the employee.

PRODOIST has appointed a Compliance Officer, responsible for checking, investigating and managing the entire system, reporting directly to the Board of Directors. He has full authority and independence under the anti-bribery management system.

Failure to comply with the policy and system requirements may result in administrative and criminal sanctions.

Last updated on 02/09/2021 08:29:28.