Supplier Code of Ethical Conduct

Mission, Vision and Values

Mission
Contribute to the development of agribusiness, adding value, respecting the environment, and improving the lives of communities.

Vision
To be a leading company in sustainable development.

Values
  1. Integrity: Be ethical, fair, and consistent in thought, speech and action.
  2. Respect for the environment: Be a benchmark in socio-environmental management
  3. Simplicity: Focus on the essentials, encouraging agility and streamlining.
  4. Humility: Demonstrate respect for all people, maintaining common sense in professional and personal relationships.
  5. Participatory management: Encourage participation, promoting recognition and professional growth, and involve people in important company processes.
  6. Commitment: “Fly the flag”. Be passionate and proud of your work and strive for the company’s success.
  7. Innovation and entrepreneurship: Retain creative, participatory, bold, talented, and enthusiastic people in the Company, who make a difference in the competitive market.
  8. Respect for our partners: Cultivate good business relationships, maintaining our commitment to being a company admired and respected by all.

Table of Contents
1. Introduction
2. Business Integrity
3. Socio-environmental Commitments
4. Supplier Commitment
5. Commitment to the AMAGGI Supplier Code of Ethical Conduct

Supplier Code of Ethical Conduct

1. Introduction

We are AMAGGI, one of the largest vertically integrated agribusiness companies in Latin America, uniquely positioned throughout the agribusiness value chain, operating since 1977. We are a major producer of agricultural commodities, sourced grains, processors, and traders, with operations and offices in Brazil, China, Norway, the Netherlands, Switzerland, Argentina, and Paraguay, as well as one of the largest grain logistics operators in Brazil. We are also producers of renewable energy.

Business performance, however, is not our sole purpose. We recognize that sustainable growth can only be achieved in partnership with society and through operations conducted ethically, responsibly, and with social and environmental awareness.

We place great value on our reputation, credibility, and the principles of legality, ethics, transparency, and integrity. These principles guide our actions and strengthen our position as a solid and trustworthy company before all stakeholders, including customers, suppliers, employees, authorities, regulatory agencies, and society at large. AMAGGI expects its SUPPLIERS to act with integrity, ethically, and sustainably, in compliance with national and international legislation, where applicable, and AMAGGI’s policies, standards, administrative, legal, and internal procedures. Therefore, through this Supplier Code of Ethical Conduct Agreement (“AGREEMENT”), AMAGGI establishes the guidelines to be followed by all its SUPPLIERS.

2. Business Integrity

  2.1. Suppliers must, in exercising their activities, adopt ethical conduct, in strict compliance with applicable laws, respect for human rights and the environment.

  2.2. Suppliers must comply with all laws and regulations applicable to their activities and take appropriate action when they become aware of irregularities committed by suppliers that may compromise AMAGGI’s interests.

  2.3. AMAGGI suppliers must also ensure the selection of their business partners, who must act in compliance with current national and international legislation, especially, but not limited to, the Law nº 12.846/2013 (Anti-Corruption Law).

  2.4. Suppliers are responsible for any losses arising from the practices and actions of their business partners that may affect, or do affect, AMAGGI.

  2.5. The Supplier represents and warrants that it is aware of, complies with, and will continue to comply with personal data protection legislation, in particular the Brazilian Civil Rights Framework for the Internet and the Brazilian General Data Protection Law (LGPD), as well as applicable international data protection laws. The Supplier further ensures that all necessary authorizations and consents have been duly obtained from the data subjects.

  2.6. All matters concerning AMAGGI and relevant stakeholders must be treated with secrecy, confidentiality and protection of intellectual property rights.

  2.7. AMAGGI values the confidentiality of all its information, so suppliers must ensure that all restricted and confidential information to which they have access is used within the scope of their duties and limited to people who need to receive the information for the purpose of carrying out their activity and must restrict its use to specific purposes.

  2.8. AMAGGI does not tolerate any act related to corruption and strives for meritocracy and fair competition in the markets and demands that the same behavior be adopted by its suppliers.

  2.9. AMAGGI suppliers are prohibited from promising, offering, authorizing or giving, directly or indirectly, any payment or undue advantage to a public or private sector agent, or to a third party related to them, that may influence any act or decision to promote their own interests or those of AMAGGI.

3. Socio-environmental Commitments

  3.1. AMAGGI has public socio-environmental commitments and ESG (Environmental, Social, and Governance) goals, which guide its business on topics such as combating deforestation and climate change, ethics and transparency, and respect for human rights. Therefore, the company works to ensure that its suppliers join its efforts towards a sustainable and responsible value chain.

  3.2. Therefore, AMAGGI demands cordiality, respect, dignity and honesty in relationships between its members and suppliers, regardless of any hierarchical position, role or function.

  3.3. No one may be subjected to abuse or harassment of any kind. When hiring suppliers, no harassment or threats of any kind are tolerated.

  3.4. AMAGGI suppliers must not practice acts of prejudice or discrimination against people, whether based on race, color, sex, ethnicity, social class, age, physical characteristics, nationality, disability, marital status, sexual orientation, union participation, party affiliation or political conviction.

  3.5. AMAGGI respects and promotes human rights in its operations and in its value chain, and its suppliers must adopt the same principles.

  3.6. AMAGGI suppliers must not allow or condone the use of forced and/or child labor, the sexual exploitation of children and adolescents, and human trafficking, in any process related to their activities.

  3.7. AMAGGI will not establish or maintain a business relationship with suppliers that use irregular and/or illegal child labor practices or that subject their employees to degrading or slave-like conditions. AMAGGI encourages suppliers to use the “Dirty List of Slave Labor”, published periodically by the Ministry of Labor and Social Security, as a tool for analyzing subcontracting decisions.

  3.8. AMAGGI’s suppliers must provide their employees with decent working conditions regarding working hours, health, and safety, always in compliance with labor laws. AMAGGI requires its suppliers to strictly comply with labor laws and observe current collective agreements and conventions, thus fulfilling all their legal obligations, without this implying any relationship with AMAGGI.

  3.9. It is also the duty of AMAGGI’s suppliers to ensure compliance of their activities with applicable environmental laws, as well as the absence of illegal deforestation in their operations or any indication of land use conflict that disrespects, especially, the rights of indigenous peoples and traditional communities.

  3.9.1. Compliance with socio-environmental criteria and institutional commitments adhered to by AMAGGI, such as the Soy Moratorium and the Eradication of Slave Labor Pact, among others, for maintaining business with the company must also be guaranteed by its suppliers.

  3.9.2. Furthermore, AMAGGI encourages its suppliers to stimulate the local economy, strengthening the development of the communities where the company operates.

  3.9.3. AMAGGI can conduct specific training on policies, commitments and procedures (environmental, social and governance) mainly for those who act on its behalf and who may cause Compliance risks for AMAGGI.

  3.9.4. If the Supplier identifies, suspects, or becomes aware of any potential violations of this Agreement, AMAGGI’s policies and procedures, or applicable laws, the Supplier must report them to AMAGGI through the communication channels or confidential reporting mechanisms described below:

• Website: https://www.amaggi.com.br/en/confidential-channel/
• Telephone: 0800 647 0004
• E-mail: canalconfidencial@amaggi.com.br

4. Supplier Commitment

4.1. The SUPPLIER declares and guarantees the following:
  a) Is aware the policies and procedures related to its partnership with AMAGGI, and can access the company’s ESG commitments and goals on the website www.amaggi.com.br;

  b) Neither the Supplier nor its representatives, officers, directors, or board members, whether directly or indirectly, are under investigation because of allegations of bribery and/or corruption, nor have they been convicted or indicted on charges of corruption or bribery. Furthermore, they are not listed by any governmental entity, nor known or suspected to be engaged in terrorism and/or money laundering activities;

  c) The Supplier does not engage in, nor does it tolerate, the use of child or adolescent labor in its activities, except in cases permitted by law. The Supplier must also repudiate such practices in its subcontractors. Furthermore, the Supplier shall comply with all conditions and requirements established under the Brazilian Federal Constitution, including, for example, the prohibition of employing individuals under the age of 18 in night work, hazardous, or unhealthy activities, as well as the prohibition of employing individuals under the age of 16, except as apprentices starting at the age of 14;

  d) Its third parties and external agents — including, but not limited to, suppliers, attorneys-in-fact, agents, distributors, consultants, lawyers, and customs brokers — do not violate or infringe any provision of Anti-Corruption laws;

  e) It is not or has not been involved in or subject to any judicial, administrative or investigative proceeding, pending or completed, related to any alleged or actual violation, including under any Anti-Corruption Law, and there is no issue, fact or circumstance that could give rise to an investigation, inquiry or proceeding, and it is not conducting any internal investigation in relation to any Anti-Corruption Law;

  f) Implements and maintains an internal system of accounting controls and accounting books and records that accurately reflect the reality of its transactions and that comply with Anti-Corruption laws;

  g) Did not (i) offer, promise or make a payment or transfer, directly or indirectly, of any bribe, discount, compensation, advantage or any other illicit payment or improper advantage to any Official or third party that could result in a violation or potential violation of any Anti-Corruption Law;

  h) Has not been banned, listed as unfit, prohibited or limited from contracting with any Government Authority, nor is he/she subject to any economic or operational restriction or penalty imposed by a Government Authority.

  i) Will keep all documents, licenses and authorizations legally required for the performance of its activities up to date and valid, including, but not limited to, documents related to occupational health and safety, those required by environmental legislation, among others required legally and/or by AMAGGI in the contracting fronts;

  j) Will comply with the Supplier Code of Ethical Conduct rules.

4.2. All AMAGGI suppliers must comply with the rules of this Term of Ethical Conduct for AMAGGI Suppliers.
If it is proven that a supplier or one of its employees has failed to comply with or observe the provisions of this Agreement, AMAGGI reserves the right to take measures it deems necessary to defend its interests, always considering the severity of the violation that occurred.

Anti-Corruption Law means any and all laws, regulations or orders issued, adopted, promulgated or validly enforced by any Authority in Brazil or in other jurisdictions applicable to the Parties and their affiliates, on anti-corruption, anti-bribery, fraud, money laundering, boycott, electoral, government procurement and contracts, conflicts of interest involving the government or anti-terrorist financing, including, to the extent applicable to these offenses and provided for in Decree-Law No. 2,848/1940, Law No. 8,429/1992, Law No. 12,846/2013, Decree No. 8,420/2015, Law No. 8,666/1993, Law No. 9,504/1997, Law No. 12,813/2013, Law No. 12,529/2011, Law No. 9,613/1998, Law No. 13,260/2016 and Law No. 13,810/2019 in Brazil, the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act of 1977 (FCPA), all as amended.

5. Commitment to the AMAGGI Supplier Code of Ethical Conduct

  5.1. I declare that I have received, read, am aware of and agree with all the guidelines and obligations that make up this AMAGGI Supplier Ethical Conduct Agreement, which reflects the commitment to ethical principles of integrity, good faith and transparency.

  5.2. I commit to fully comply with this Agreement in all actions carried out on behalf of AMAGGI and acknowledge that any breach of this AGREEMENT, whether by myself or through my employees, constitutes a serious violation. I understand that I may be subject to the sanctions provided by law or those outlined in AMAGGI’s disciplinary procedures. AMAGGI reserves the right to take any measures it deems necessary to protect its interests, considering the severity of the violation.