SUSTAINABILITY AND SOCIAL AND ENVIRONMENTAL RESPONSIBILITY POLICY

In this policy we express our principles, strategies and guidelines for sustainability and social and environmental responsibility.

OBJECTIVE

The purpose of this policy is to ratify our commitment to the pursuit of sustainable development; to formalize COBRA METAIS’ sustainability and social and environmental responsibility strategy; and to specify the guidelines for improving our social and environmental risk management strategy and practices.

STAKEHOLDERS

Our sustainability and socio-environmental responsibility policy observes the principles of relevance, proportionality and efficiency and is based on:

Respect for and protection of human rights through the promotion of diversity, financial inclusion and the fight against child and slave labor, the criminal exploitation of prostitution and the sexual exploitation of minors;
Ethical and transparent stance, adopting fair operating practices and providing timely, accessible and appropriate information to the specific needs of Stakeholders;
Socio-environmental risk management is identified as a component of the various types of risk to which we are exposed;
Continuous development of the relationship with its Stakeholders;
Rational use of natural resources.

1. SUSTAINABILITY STRATEGY AND SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

Our management of sustainability and social and environmental responsibility is guided by two strategic focuses:

Social and Environmental Risks and Opportunities

Searching for business opportunities and managing socio-environmental risk, taking into account market trends, regulations, demand from members and society.

Dialogue and Transparency

Building relationships of trust to improve our business and generate shared value.

2. RESPONSIBILITIES

Company areas

Observe both adherence to the guidelines and principles of this policy and the voluntary commitments applicable to the development of its activities and processes.

Administrative Management

Keep this policy up to date;

Clarify doubts about the interpretation of the principles and rules of this policy and related policies;

Assisting the areas in drawing up action plans to mitigate risks arising from non-adherence to this policy and related policies, as well as monitoring the progress of these plans.

Develop training on this policy;

3. SUSTAINABILITY GOVERNANCE AND SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

Management of the Principles and Guidelines of this Policy

Monitor social and environmental risk in accordance with this policy and the related policies, which describe the specific procedures to be adopted;

Continuously incorporate the principles of this policy into the organization’s management processes and related policies;

Communicate pertinent information to its Stakeholders in a clear and transparent manner;

Encourage the conscious use of financial resources;

Comply with corporate guidelines and policies for preventing money laundering and combating corruption and fraud.

Products and Services

Apply sustainability and socio-environmental responsibility criteria in the product and service approval process;

Identify business opportunities that promote social and environmental benefits;

Adopt, observing the principles of relevance and proportionality, specific procedures for products and services subject to socio-environmental risk management, taking into account legal requirements, the use of financial resources and exposure to socio-environmental risk.

Relations with the Internal Public

Disseminate the culture and promote practices that value diversity and equity in the workplace and that favor a good organizational climate;

Incorporate principles of sustainability and socio-environmental responsibility into training for the company’s employees.

Supplier Relations

Promote the development of suppliers with regard to sustainability and social and environmental responsibility;

Evaluate and monitor requirements for contracting suppliers, so that they comply with the principles of this policy.

Fair Competition and Antitrust Policy

The New Brazilian Antitrust Law (NLAB), Law No. 12.529, which replaces Law No. 8.884/1994, structures the Brazilian System for the Defense of Competition (SBDC) in its article 1 and provides for the prevention and repression of infractions against the economic order, guided by the constitutional dictates of freedom of initiative, free competition, the social function of property, consumer protection and repression of the abuse of economic power.

Therefore, according to the new law, “concentration acts that imply the elimination of competition in a substantial part of the market, that may create or strengthen a dominant position or that may result in the domination of a relevant market for goods or services will be prohibited”.

Free competition is identified constitutionally as one of the general principles of economic activity, as set out in art. 170, item IV of the Federal Constitution. The infra-constitutional regulation is found in Law 12.529 of November 30, 2011, which came to structure the Brazilian System for the Defense of Competition, providing for the prevention and repression of infractions against the economic order. The Cobra Metals company operates according to the principles of equality and in accordance with current legislation.

Relations with society

Supporting market mechanisms, public policies and initiatives that promote improvements for society and mitigate social and environmental challenges.

Environment

Promoting efficiency in the consumption of energy and natural resources;

Promote the proper management and disposal of waste and effluents generated in its internal activities;

4. DECLARATION OF SOCIAL RESPONSIBILITY

The company Cobra Metais Decorativos Ltda. undertakes, by means of this corporate commitment, to adhere to the principles set out below, taking into account the characteristics of the business and privileging market conditions, and with the intention of establishing plans to achieve the following objectives:

Child labor

The company, in accordance with international labor standards, does not engage in or support the use of child labor (under 18 in places subject to real or presumed danger and not under 16 in non-hazardous facilities). The company complies with the Industrial Apprenticeship legislation, hiring young people in the apprentice category to fulfill the quota, observing the reduced working hours applicable to the professional qualification and the remuneration proportional to the reduced working hours.

Forced labor/ Modern slavery

The company must not engage in or support the use of forced labor. Workers will not be able to have their documents withheld or be forced to make deposits as a condition of being hired.

Health and safety

The company must provide a safe and healthy working environment, including access to drinking water, clean toilets, the necessary individual and collective safety equipment and training in its use, taking appropriate measures to prevent accidents and damage to health.

It also undertakes to develop, plan and implement work practices that prevent the health and safety of its employees.

Freedom of association and the right to collective bargaining

The company respects and encourages the right of all employees to form or join trade unions, as well as to bargain collectively, ensuring that there are no reprisals.

Discrimination and harassment

The harassment and discrimination policy is fundamental to guaranteeing a fair and respectful working environment for all our company’s employees. Harassment and discrimination are unacceptable and harmful behaviors that violate human rights and can cause psychological and emotional damage to employees. It is important for all employees to know that the company will not tolerate any kind of discrimination or harassment, whether based on gender, age, sexual orientation, ethnicity, religion or any other personal characteristic.

Our harassment and discrimination policy aims to prevent, detect and resolve these behaviors, creating an inclusive and safe working environment. To this end, the company undertakes to:

Provide training and awareness to employees on the negative impacts of harassment and discrimination, as well as on applicable laws and regulations.
Promptly investigate any reports of harassment or discrimination and take appropriate disciplinary action against offenders.
Guarantee the confidentiality of all complaints and protect whistleblowers against any retaliation or reprisal.
Ensuring that all employees are treated with respect and dignity, regardless of their hierarchical position, gender, age, sexual orientation, ethnicity, religion or any other personal characteristic.

Cobra Metais is committed to creating a work environment free of harassment and discrimination. Adherence to this policy is the responsibility of all employees, and it is essential that everyone works together to ensure that the company is a fair, safe and respectful place to work.

Working hours

The company must not require workers to routinely work more than 44 hours a week with at least one day’s rest during this period and a maximum of 12 hours of paid overtime a week. They must comply with the legislation and rules of their field of activity, actively helping to reconcile their professional and personal lives. The company can use the mechanisms provided for in the Collective Agreement of the Graphics Category to compensate for hours and/or to amend “bridging” holidays.

Remuneration (salaries and benefits)

The company must ensure that the wages paid meet the local minimum standards and must always be sufficient to meet the basic needs of the workers, trying to adapt to market standards, allowing for some extra income and that they are convenient for the workers.

Ethics in recruitment and selection

It is extremely important that the recruiter is impartial and does not judge people. Ethics and empathy are essential to evaluate candidates fairly, without privileging or disadvantaging a professional because of their personal beliefs and values. Selection programs with an ethical approach must involve all levels of the organization, otherwise they will not achieve their macro objective of seeking greater homogeneity in the way ethical issues are conducted.

Working women's rights

The company must ensure that the main women’s rights contained in labor laws and social security regulations, as well as those listed from Article 372 of the CLT onwards, are applied to women’s work, except where they conflict with the special protection established by specific regulations and also by ensuring compliance with the clauses set out in the collective bargaining agreement for the category.

Diversity, equity and inclusion

Ensuring the inclusion of people of different ages, races and ethnicities, abilities and disabilities, genders, religions, cultures and sexual orientations. However, this also includes people with diverse backgrounds, experiences, skills and knowledge. The company must take individual needs into account, while at the same time readjusting organizational structures to take into account the disadvantages that minority groups face.

Minority and indigenous peoples' rights

The company must ensure that minority rights are governed by the principle of equality and non-discrimination, with no minimum set of rights. It is possible to observe that, in addition to the rights common to all people (such as the right to life, freedom of expression, the right not to be subjected to torture, among others), minorities have certain basic rights – the right to exist, the right to identity and the right to positive measures.

Rights to land, forest, water and compulsory eviction

The company must ensure that people have the fundamental right to freedom, equality and the enjoyment of adequate living conditions in an environment of such quality as to enable them to lead a dignified life, enjoy well-being and be solemn bearers of the obligation to protect and improve the environment for present and future generations Art. 225. Everyone has the right to an ecologically balanced environment, an asset of common use to the people and essential to a healthy quality of life, imposing on the public authorities and the community the duty to defend and preserve it for present and future generations.”

Biodiversity rights, land use, deforestation, soil quality and animal welfare

Cobra Metals recognizes the importance of preserving biodiversity, sustainable land use, preventing deforestation and animal welfare. We are committed to using raw materials from suppliers who follow sustainable and ethical practices with regard to production, land use, deforestation and soil quality. We also encourage our employees and business partners to adopt responsible practices with regard to the environment and animal welfare. We are open to collaborating with organizations that work to defend biodiversity, the sustainable use of land and animal rights, looking for ways to contribute to the preservation of the environment and respect for living beings. We believe that it is our responsibility to act sustainably and to ensure that our activities comply with environmental and ethical standards.

Policy on the use of public or private security forces:

Purpose: The purpose of this policy is to define the guidelines for the use of public or private security forces by the company, guaranteeing the protection of the company’s assets, employees and visitors.

Authorization for use: The use of public or private security forces can only be authorized by a high-ranking company official, after careful assessment of the need and the alternatives available.

Training: All employees involved in the use of security forces must be properly trained and instructed in their responsibilities and security procedures.

Responsibility: The company is responsible for ensuring that the security forces used act professionally and ethically, respecting human rights and the laws in force.

Relations with the police: The company must maintain good relations with the police authorities and work closely with them in the event of emergency situations.

Monitoring: The company should periodically monitor the use of security forces, evaluating their efficiency and identifying possible improvements.

Anti-Bribery Policy, Illegal Acts and Protection against Retaliation

The company must fight corruption in all its forms, including extortion and bribery. This Policy prohibits: the offer, promise, authorization or payment of money or Anything of Value, directly or indirectly through a Third Party Intermediary, to a Public Authority or natural or legal person, to secure any Improper Advantage.

It is important to note that the main anti-corruption laws, including Brazilian ones, prohibit such payments in cash or Anything of Value, regardless of whether they are made directly or indirectly through Third Party Intermediaries.

The term “Anything of Value” is broad and may include any item of monetary value, including, without limitation, the following:

Cash or cash equivalent (including gift cards);
Benefits and favors;
Provision of services that would otherwise have to be paid for or purchased;
Present;
Employment or consultancy opportunities;
Donations to charities;
Political contributions;
Medical, education or living expenses; or
Expenses for travel, meals, accommodation, shopping or entertainment.

Whistleblowing Policy

Cobra Metais’ whistleblowing policy aims to create a safe and ethical environment for its employees, business partners and others involved in its activities. Anyone who becomes aware of inappropriate, illegal, unethical behavior, harassment or any other improper practices can immediately report it to the company, anonymously and securely, without fear of retaliation or punishment, using the means available in its electronic system. Complaints are received by a committee and the company undertakes to investigate all complaints received with confidentiality, impartiality and transparency, taking the necessary measures to correct irregularities when identified. This whistleblowing policy guarantees the anonymity of the employee who makes the complaint, so that they feel safe in reporting any inappropriate behavior or harassment situations, helping to preserve the company’s integrity and reputation.

Intellectual Property and Copyright

Intellectual property consists of patents, trademarks, reproduction rights, trade secrets, domain names, industrial designs, logos, market data and customer lists, as well as any information classified as confidential. The company’s intellectual property must be protected from misuse, misappropriation or use for personal gain. The same care and respect must be exercised with regard to the intellectual property of third parties.

Our products

The pieces produced by Cobra Metais Decorativos Ltda. are developed to meet the expectations and needs of our customers and cannot be divulged or exposed because they are confidential, so failed parts will have to be scrapped.

Cobra Metais Decorativos Ltda. does not produce pieces that have not been authenticated and copyrighted by the client.

5. PROTECTION OF PERSONAL DATA

For the purposes of this Clause, the defined terms “Database”, “Personal Data”, “Processing” and “Data Subject” shall have the meaning attributed to them in Article 5 of Law No. 13,709 of August 14, 2018, as amended.

Cobra Metais Decorativos Ltda. expressly declares that it complies with the legislation and regulations relating to the protection of Personal Data, as in force and applicable (“Regulations”).

Duty of secrecy and information security

Cobra Metais Decorativos Ltda. undertakes to keep strictly confidential any information, industrial or commercial secrets or ideas of a confidential nature of the other Party to which it has access (“Confidential Information”) and to employ the same means as they use to protect their own confidential information, as well as to require the persons they involve in the development of the projects to respect the confidentiality of this information.

Company Assets, Resources and Information

Cobra Metais’ assets, resources and information must be protected and used for the business and benefit of the company and never for personal advantages or interests. It is forbidden to disclose information of any kind about the Company and third parties, including its customers and suppliers, that is not classified as public. It is forbidden to photograph inside the work areas (photographing documents, equipment, taking selfies, group photos). Such an attitude is punishable by disciplinary action. Only authorized persons are allowed to take technical photographs of the work.

Internet, E-mail and Social Media:

The internet and e-mail are made available by Cobra Metais for work communication. It is not permitted to use electronic systems, the internet, e-mail or social media to transmit, receive or download content that is detrimental to the performance of work activities or the interests of the Company. Social media, at work or anywhere else, must not be used to expose private or confidential Company information, nor is it permitted to post content that exposes the image of the Company, its products or its members. Computers and servers, including e-mails sent or received, are the property of Cobra Metais and will not be considered private content, except when required by specific legislation.

6. FINANCIAL RESPONSIBILITY

Section 1: Core Values

1.1 Integrity: Our company is committed to conducting business in an ethical and transparent manner in order to protect the reputation and long-term success of the company.

1.2 Confidentiality: The company’s financial information is confidential and must be handled responsibly and respectfully.

1.3 Transparency: Our company is committed to providing accurate and clear financial information to all interested parties.

Section 2: Ethical Behavior

2.1 Laws and regulations: All finance employees must strictly comply with the relevant financial laws and regulations and act ethically in all financial transactions.

2.2 Conflicts of interest: Finance employees must avoid conflicts of interest and inform management immediately if they become aware of any potential conflict.

2.3 Intellectual property: The company’s intellectual property, including financial information, must be protected and used appropriately.

Section 3: Risk Control

3.1 Risk identification: The finance department must continuously identify and assess the company’s financial risks.

3.2 Control measures: The financial area must implement adequate risk control measures to guarantee the integrity and accuracy of financial information.

Section 4: Clear communication

4.1 Financial reports: The financial area must provide accurate and clear financial reports to all interested parties.

4.2 Transparency: The financial area must answer questions and provide additional information in a clear and transparent manner.

This policy is a statement of our commitment to ethics and financial transparency and will be reviewed periodically to ensure its relevance and effectiveness. Any violation of this policy will be dealt with appropriately.

7. EXPORT CONTROLS AND ECONOMIC SANCTIONS

Objective: To ensure compliance with international export laws and regulations, as well as economic sanctions imposed by government agencies, in order to protect the company’s integrity and avoid financial and reputational sanctions.

Scope: The policy applies to all employees, contractors and service providers of the company who are involved in export activities or who have access to confidential information about them.
Legal compliance: The company undertakes to strictly follow all applicable export laws and regulations, including the list of prohibited parts and export restrictions, as well as economic sanctions imposed by government agencies.
Training: The company will provide adequate training to employees involved in export activities to ensure understanding and compliance with applicable laws and regulations.
Background checks: The company will carry out background checks to ensure that it is not in breach of any export sanctions or restrictions.
Responsibilities: All employees involved in export activities are responsible for immediately informing management of any suspected violation of export laws and regulations.
Monitoring: The company continuously monitors export laws and regulations and economic sanctions to ensure current compliance.
Consequences: Any violation of export laws and regulations or economic sanctions can result in financial penalties, fines and damage to the company’s reputation. The company may take disciplinary action against any employee who violates this policy.

This policy is a formal statement by the company regarding export controls and economic sanctions and should be reviewed regularly to ensure its relevance and effectiveness.

REVISION HISTORY

REV.	DATE	DOCUMENT	AMENDMENT ISSUED BY
0	04/05/2021	Initial Issue	Elaine Veiga
1	12/12/2022	Inclusion of topics 4 and 5	Elaine Veiga
2	03/02/2023	Inclusion of topics 6 and 7	Elaine Veiga