POLICY OF INTEGRITY AND ETHICS

Chapter I - The Target Audience of This Policy

‍

Article 1 - This policy applies to all officers or directors, boards, committees, employees,

interns, young apprentices, outsourced workers, and anyone else with whom Élin Duxus maintains or comes

to maintain a commercial relationship, including employees, customers, partners, suppliers and other audiences of

relationship.

Article 2 - This document, henceforth a policy, is part of the individual employment contract with Élin Duxus,

henceforth company. The guiding action contained therein extends to all employees, without hierarchical distinction.

Sole Paragraph - Compliance with this policy remains mandatory for the entire duration of the relations

with the company, by any individual or legal entity, in labor relations and/or commercial relations, not

no one is allowed to claim their ignorance.

Article 3 - Any collaborator will only be integrated after positive indication of knowledge of this policy.

Article 4 - Like employees, no partner, client, or anyone who maintains a relationship

commercial with the company, you may claim ignorance of the provisions of this policy.

‍

Chapter II - Principles and Values

‍

Article 5 - Élin Duxus values respect for ethics in the conduct of its business, through the adoption of

good market practices. This policy is intended to guide Élin Duxus Professionals, as well as

competitors, customers, suppliers and other partners on how to relate, through good business practices

of protection of workers' rights, of compliance with applicable legislation, and of ethics in the conduct of

business, as well as respect for the principles and regulations that guide market relations, without prejudice

free competition, the environment and the fight against corruption. The principles and values of this political policy are:

• Human rights, as a fundamental principle;

• Ethics, as a fundamental principle and prerequisite for mutual trust;

• Legality, defined as acting always in accordance with the laws;

• Morality, defined by conduct guided by standards of decorum, loyalty, honesty, and probity in

always seeking the common good;

• Efficiency, as the best possible application of resources, aimed at reducing waste, quality, speed

and productivity;

• Meritocracy, as a form of measurement and evaluation

• Equality, as a form of treatment of individuals, and any form of discrimination is inadmissible

social, cultural, ethnic, sexual, racial, age, religious, by philosophical or political conviction, sexual orientation,

gender identity, marital status, physical and mental condition, origin, level of education, education, education,

appearance or nationality;

• Harmony, as a basis for managing teams, regardless of position or function;

• Combating corruption, as a way of perpetuating the best interests of society;

• Social and environmental responsibility and preservation of the environment, in order to perpetuate nature and

its limited resources;

• Childhood, as a way to protect society from child labor;

• Work, as a basic way of valuing participation for well-being, as well as a rejection of practices

analogous to slavery;

• Image, as a way of defending the integrity and vision of the company by the internal and external public; and

• Reliability, as a way of honoring the commitments made.

Article 6 - All company initiatives must be based, when applicable, on the content of this policy,

respecting it in its entirety and not allowing any internal rule that contravenes it.

‍

Chapter III - The Relationship Between People

‍

Article 7 - The relationship between people, defined as collaborators, clients, guests, or attendees

In the company for any other reason, even as a visitor, you must always be respectful and cordial.

Article 8 - Interpersonal relationships or relationships in the form of groups must not be a cause for isolation or

impediment of social access by other people who do not participate in the same group, except for reasons of

confidentiality, which must be treated with greater rigor and caution.

Art. 9 - Bullying or harassment practices of any kind are not tolerated under any aspect.

Article 10 - Relationships between people, whether professional or personal, must be backed by trust and

respect and issues, when restricted, must be treated in this way in both areas.

Sole Paragraph - Respect for personal relationships should not be treated as an incentive to the absence of opinions

and debates, which are fundamental tools for social relationships. However, the appropriateness is noted

of these discussions for appropriate times and places.

Article 11 - The personal relationship must not be considered an impediment to non-compliance with rights

or obligations, legal or ethical, relating to the attitudes of third parties.

‍

Chapter IV - Anti-Corruption and Anti-Bribery

‍

Article 12 - Élin Duxus, through its principles and policies, acts to combat corruption in a way that does not allow

any conduct that may constitute undue advantages or prejudice to free competition, such as offering

of bribes, bribes, facilitation payments, illegal donations, and undue commission payments, being the

same behavior expected from all your business partners. Élin Duxus also does not tolerate any

illegal practices such as private corruption, kickbacks, extortion, fraud, obstruction of investigation, influence peddling,

among others.

Article 13 - Élin Duxus business partners must comply with all laws, rules and regulations

anti-corruption and anti-bribery that apply to Élin Duxus operations.

‍

Chapter V - Conflict of Interest

‍

Article 14 - Élin Duxus is committed to avoiding any type of situation that may generate conflict

of interests. The company expects its business partners to adopt similar behavior. Nesse

context, Élin Duxus' business partners must ensure that there is no conflict of interest

when interacting on behalf of or together with Élin Duxus. In addition, business partners commit

to immediately report to Élin Duxus any situation that may give rise to a conflict of personal interest or

economic.

‍

Chapter VI - Defense of Free Competition

‍

Article 15 - Antitrust laws have as their main objective, worldwide, to prevent and punish infractions

to economic orders, in order to promote free competition, freedom of initiative, suppress the abuse of

economic power and protect consumers. Élin Duxus conducts its business with strict observance of

current antitrust legislation in the places where it operates. In this way, Élin Duxus prohibits and combats everything

and any practice that violates free competition, including but not limited to the setting of prices or conditions

commercially sensitive between competitors, exchange of sensitive information, abuse of market power. Os

Élin Duxus' business partners must also act in compliance with competition laws

that apply to Élin Duxus operations.

‍

Chapter VII - Relationship with Competitors

‍

Article 16 - Élin Duxus' relations with its competitors are guided by transparency, through

decisions based on objective and not personal criteria. Élin Duxus condemns all commercial practices

that are aimed at the formation of a cartel or even that may limit or impair market competition, such as

price combination, agreement on trading conditions, negotiations to alternate winners in bids, and

division of clients, not excluding other forms and procedures for this purpose.

Article 17 - Élin Duxus' business decisions are independent and not related to interests

of your competitors. Élin Duxus also condemns the use of a dominant position to impose terms of

exclusive negotiation for clients. Applicable competition laws must be respected by

all parties who wish to maintain business relations with Élin Duxus. Emphasizing that several of the infractions

Competitive companies imply responsibility not only of the company, but of the individuals involved, not

If there is a need for the existence of guilt on the part of the offender, it is sufficient that they have as their object or can

produce effects that affect free competition.

Article 18 - To curb anticompetitive practices, Élin Duxus requires confidentiality of your information

commercials. They must not be shared, whether orally, in writing, formally or informally, any

competitively sensitive information, such as: costs (including those relating to employee salaries and others

labor benefits), price, price change, discount policies; purchase and sale terms and conditions;

strategy and bids in public tenders, profit margin, costs, target audience, sales markets, strategies of

sales and marketing, customers, and other information. In addition, no tool should be used that

can prove the identity of Élin Duxus's competitors or any other sensitive information in tenders

public.

‍

Chapter VIII - Relationship with Business Partners

‍

Article 19 - Élin Duxus recognizes that in order to continue to conduct its business with the highest

standards and integrity, legality and ethics it is fundamental to establish healthy, transparent relationships,

sustainable and integrated with its Business Partners. In the development of this relationship and in the selection of your

partners, such as suppliers, service providers, representatives, Élin Duxus impartially considers,

objective, technical, professional, legal and ethical criteria. Élin Duxus expects its Business Partners to

commit to the establishment of ethical and legal management, in accordance with good business practices

described in this and other Élin Duxus Policies, as well as in its Code of Ethics and Conduct. To Élin Duxus

encourages its Business Partners to establish an integrity program internally and to design a

code of ethics and conduct. Élin Duxus's relationship with his Business Partners must be guided

in an objective, honest, transparent, loyal relationship, with mutual respect and collaboration. The Partners of

Businesses must commit to the veracity of the information they submit to Élin Duxus, whether during

the negotiation of contracts, amendments or during the contractual term.

‍

Chapter IX - Relationship with the Law

‍

Article 20 - The law, in its broadest sense, defines relations between individuals and legal entities and seeks to resolve conflicts.

Respect for the law is fundamental and observed by the company in all its aspects.

First Paragraph - Respect for the law is not limited to labor or business relations, but expands to

people's relations with society, also focusing on good morals.

Second Paragraph - Respect for the law begins with pursuing its compliance instead of seeking its

not applicability.

Article 21 - Observance of the law also occurs through intolerance against those who violate it, so that they are not tolerated

any non-compliance with the Law, in any commercial relationship between the company and its employees,

suppliers, customers, and partners.

Article 22 - This policy complies with the provisions of the laws in force and applicable to the Élin Duxus business and may be

amended at any time, in order to adapt to possible changes or updates to said Laws.

‍

Chapter X - Of the Relationship with Society

‍

Article 23 - The company seeks to develop products that generate returns to society, whether in the form of

jobs, whether in the form of income or in the form of technology. This is the return to society. The people

they must reflect on what return they make to society.

Article 24 - No practice harmful to society is tolerated, even in commercial relations. Such practices

(cartel, bribery, corruption, fraud, money laundering crimes) besides being the subject of the legislation, they also corrode

the values that underpin social culture.

‍

Chapter XI - Relationship with the Environment

‍

Article 25 - The environment is part of the company's decision-making process and must be part of the processes

individual.

Article 26 - Whenever appropriate, preservation, economic and environmental impact reduction practices shall prevail

in decision-making.

Article 27 - The consumption of disposable materials, plastics and other everyday single-use materials is discouraged,

respecting legal reservations. Porcelain mugs and selective waste are good examples to follow.

Single Paragraph - The use of more durable materials must be accompanied by an equal need for maintenance

and cleaning.

Article 28 - The intended environmental and preservation practices (environmental program), but not limited, are:

• Garbage reduction and garbage separation, encouraging employees to deposit them in their bins

appropriate;

• Appropriate disposal of electronic waste through partner companies that provide detailed reports

about proper disposal;

• Reuse of paper and drafts avoiding unnecessary waste contributing to the environment;

• Periodic maintenance policy for company equipment, preventing equipment from malfunctioning

operation wastes energy;

• Policy for the use of recycled paper (environmentally friendly);

• Anti-waste water policy, with conscious use of water;

• Conscious use of energy resources, including efficiency and the need for conditioning

of air.

‍

Chapter XII - Ethics Channel

‍

Article 29 - Everyone who maintains any type of contact with the company must be aware that the attitudes and

behaviors of the professionals involved are in accordance with the principles and values of Élin Duxus. That's a

your commitment! Therefore, whenever you notice an attitude that does not seem correct, consult our Policy of

Integrity and Ethics and the other specific policies for each case. If you notice that something is wrong, report it at

our ethics channel immediately.

Article 30 - Élin Duxus will not practice or tolerate any form of retaliation against anyone who makes a complaint or

good-faith reporting regarding offenses against the company's principles and values.

Article 31 - For this communication, you must use our ethics channel made available on our site, at

“Contact => Subject => Ethics Channel” link.

Article 32 - The complete confidentiality of the information posted on the ethics channel is also guaranteed.

‍

Chapter XIII - Violation and Investigation of Irregularities

‍

Article 33 - If Élin Duxus is aware of evidence of an irregularity (through complaints,

as a result of the monitoring/auditing or in other ways), Élin Duxus will initiate an internal investigation in

templates of the company's internal procedures. The purpose of the investigation is to analyze the facts, to verify

if the information obtained is true, gather evidence and provide defense opportunities to the investigator. Nos

cases in which the reports are substantiated and constitute a violation of Élin Duxus policies and processes,

disciplinary measures will be appropriate in relation to Élin Duxus Professionals and contractual measures, including

termination of the contract will be appropriate in relation to Business Partners. In addition, it will evaluate

the need for possible communication to the competent authorities.

‍

Chapter XIV - Penalties

‍

Article 34 - The following penalties apply to employees who violate the rules of this policy:

a) verbal warning;

b) written warning;

c) suspension; and

d) dismissal, for just cause.

Sole Paragraph - Penalties are applied depending on the seriousness of the transgression.

Article 35 - For others interested in the knowledge and application of this policy, in the event of transgressions,

the administrative and/or judicial measures appropriate to each specific case will be invoked.

‍

Chapter XV - Of the General Provisions

‍

Article 36 - Each employee will receive a copy of this policy upon hiring.

Changes will be made public to employees by making this policy available digitally.

Article 37 - For other interested parties, this policy will be maintained digitally on the company's website, to

conference whenever necessary.

Article 38 - This policy may be replaced by another, whenever the company deems it appropriate, at

consequence of a change in the social legislation or of an update

‍