The procedures described herein are complementary to the Conduct and Values guidelines that ACR practices.

Objective

This Integrity Policy aims to define the procedures established to prevent any actions that could be characterized as active or passive corruption in relationships with public or private companies, or as unfair competition.

Scope

It is the responsibility of each ACR employee, as well as third parties acting on its behalf, to know the Conduct and Values upheld by the company and to follow the guidelines outlined in this Integrity Policy.

1. Bribery

Bribery involves promising, offering, or paying an authority, ruler, public official, or private professional any amount of money or other favors to cause the person to act unethically in their professional duties. ACR’s policy prohibits any act that constitutes bribery.

2. Procurement and Bidding Procedures

Local purchasing decisions are made based on merit and not by exerting undue influence over public or private company employees. Procurement standards include specific rules regarding ACR's purchasing and selling procedures, including the submission of documents and information in bids. Offering any product or amount that may imply an interest in obtaining advantages during negotiations is strictly prohibited. It is also forbidden to engage in any actions that could be characterized as fraud in public tenders or bid manipulations. Mechanisms are in place to prevent the acquisition of unregistered, unlicensed, or unauthorized products and to avoid partnerships with companies that do not comply with legal obligations.

3. Business Partners, Representatives, Suppliers, and Other Third Parties

Corrupt payments through intermediaries and any payments to third parties with knowledge that part or all of the payment will directly or indirectly go to a public official are prohibited. All business decisions must be merit-based. ACR verifies whether its business partners are associated with corruption practices (even if not yet convicted) or listed in the General Comptroller’s Registry of Ineligible and Suspended Companies (CEIS). Establishing relationships with such companies should be avoided.

4. Endorsement of Third Parties

ACR does not endorse third-party services to benefit its operations.

5. Gift Policy

ACR's Integrity Policy includes guidelines on employee conduct in commercial relationships, procurement, bidding, contributions, accounting controls, competition relationships, and more.
Recommendations on accepting or offering gifts are outlined to prevent these actions from representing obligations or rewards for business transactions.

Acceptable Gifts:

• Gifts valued at no more than R$ 50.00, displaying the donor's logo/brand (e.g., agendas, pens, calendars, etc.);
• Invitations to lectures, events, workshops, or seminars not exceeding R$ 400.00 per person, lasting no longer than one day, and limited to three times a year with the same partner.

Unacceptable Gifts:

• Illegal or inappropriate gifts or those given in inappropriate locations;
• Meals related to business operations;
• Cash, equivalents, personal services, or loans;
• Events or meals where the partner is not present.

This policy aims to prevent future discomfort between ACR and its suppliers or clients.

6. Political Contributions

ACR does not make contributions to any political party or maintain any affiliation with them.

7. Union Contributions

No contributions are made to union members or entities controlled by unions.

8. Philanthropic Contributions and Donations

Such contributions are only made after ensuring that the funds do not have commercial interests or promote favoritism. Donations must be made to legal entities, not individuals, and only to institutions registered per local legislation. Institutions’ backgrounds and donation purposes are reviewed beforehand.

9. Accounting Obligations and Controls

ACR maintains detailed, accurate, and correct records of operations and asset disposals via an external accounting firm. The use of falsified documents, invoices, or fraudulent accounting entries is prohibited. Adequate internal and external control systems ensure operations comply with applicable legislation.

10. Anti-Corruption Sanctions

Criminal Responsibility and Civil Penalties:
Legal entities and individuals can be held accountable for corruption crimes. Personal fines cannot be paid by employers.

Civil Liability and Damages:
Besides criminal liability, individuals and entities involved in corruption may face civil lawsuits and be required to compensate affected parties.

Suspension or Exclusion:
Entities may be barred from conducting business with governmental or public administration clients.

Internal Sanctions:
Fraud or bribery by employees is punishable and may result in dismissal or civil/criminal charges.

11. Whistleblower Channel

ACR has a whistleblower channel on its website for employees, clients, or others to report irregularities related to internal procedures, ethics, human rights, and the environment. Reports can be submitted anonymously or with personal identification, which will remain confidential. Submit reports at https://www.acr1.com.br/canal-de-denuncia.

12. Unfair Competition

Unfair competition includes activities against ethical practices or economic rights that eliminate competition, dominate markets, or arbitrarily increase profits.
ACR prohibits practices such as:

• Using market power to restrict production or increase prices;
• Pricing products below cost to eliminate competition;
• Colluding with competitors to fix prices;
• Making false statements about competitors;
• Employing deceptive means to divert clientele;
• Unauthorized use of competitor trade names or confidential information.

Final Considerations

This Policy aims to guide employees in preventing misconduct without restricting their professional responsibilities within permissible limits. It will be reviewed annually or as needed to comply with legal updates.