Code of ethics and conduct

The Code of Conduct is available on the websites of NTA and FRAORE. It is applicable to all employees and interested parties acting on behalf of the company who under no circumstances can claim ignorance of the guidelines contained in this code.

Read carefully and learn our Code and practice it in daily work.

1 – Introduction
1.1 What is the Code of Conduct?
1.2 Objective of the Code
1.3 Who does this Code apply to?
1.4 Compliance with and communication of the Code
2 – Applicable Laws
3 – General Principles of the Code of Ethics and Conduct
3.1 Compliance with Laws and Regulations
3.2 Human Rights
3.3 Child labor
3.4 Forced Labor
3.5 Moral and Sexual Harassment and Discrimination
3.6 Equal Employment Opportunity and Labor Rights
3.7 Employee Behavior
3.8 Fighting Corruption
4 – Specific Principles of the Code of Ethics and Conduct
4.1 In the Internal Environment
4.1.1 Relationships
4.1.2 Safety, Health and Environment
4.1.3 Conflict of Interest
4.1.4 Integrity of Information and Data
4.1.5 Donations, Sponsorships, Souvenirs, Gifts, Entertainment and Hospitality
4.2 In the External Environment
4.2.1 Relationship with customers
4.2.2 Relationship with suppliers, service providers, partners and consultants
4.2.3 Relationship with governmental bodies
4.2.4 Relationship with competitors
4.2.5 Relationship with the Media
4.2.6 Relationship with the community
4.2.7 Relationship with the labor union
5 – Non-compliance with the code – Penalties
6 – Communication and reporting channels
7 – Training and auditing
8 – Annex

Introduction

1.1. What is the Code of Ethics and Conduct?

The Code of Ethics and Conduct is a document that outlines values, rules, standards, and principles that members and third parties acting on behalf of an organization must follow. Its importance lies in the establishment of standards of behavior and ways of acting in compliance with the company’s objectives.

1.2. Objective

Over more than 16 years, we have experienced many changes, but the guiding principles of the Company’s organizational culture were maintained.

Therefore, this document aims to present a set of systematized guidelines that state the Mission, Vision and Values of NTA ASFALTOS and Transportes FRAORE.

MISSION

Produce asphalt and derivatives using advanced and innovative technologies, striving for the quality of manufacturing and distribution, thus contributing to the development of Brazilian asphalt paving.

VISION

We aspire to achieve national recognition as an Asphalt Product Distributor of the highest reliability and quality, exceeding the standards established of Commercialization and Manufacturing of New Products and Logistics.

VALUES

• Reliability: We are ethical and transparent. We seek to develop strategic partnerships with customers, suppliers and employees;
• QUALITY: We continually develop new technologies for production and application of asphalts and derivatives;
• SIMPLICITY: We believe in operational simplicity and practice it as a working style. We solve problems quickly and practically;
• ENTREPRENEURSHIP: We distribute asphalt products for pioneering road infrastructure works and thus we contribute to the country’s socioeconomic growth and ensure shareholder return by producing positive economic and financial results.

1.3. Who does this Code apply to?

This Code of Ethics and Conduct outlines how we all must conduct ourselves: EMPLOYEES, THIRD PARTIES, SERVICE PROVIDERS, SUPPLIERS IN GENERAL, BUSINESS CONSULTANTS, AND CUSTOMERS.

It is a set of guidelines and rules on how to BEHAVE to AVOID actions that DISRESPECT the CURRENT LEGISLATION, company policies and attitudes that violate ETHICAL aspects.

1.4. Compliance with and Communication of the Code

It is important to communicate and explain this Code to all Employees, Customers, Third Parties, Service Providers, Partners and Business Consultants. It must be read carefully so that all doubts can be discussed with area managers or HR, using the Communication Channels here indicated.

2 Applicable Laws

This Code is applicable to both NTA ASFALTOS and FRAORE managers, employees, interns, service providers, suppliers, business partners, consultants and third parties in general. NTA ASFALTOS and FRAORE value ethics in all their relationships, which is why they seek companies, third parties, customers and employees who understand their way of doing business and are committed to observing the highest standards of ethics and integrity.

In this respect, this Code was based on the laws applicable to the line of business, activities and relationships established by NTA ASFALTOS and FRAORE, and in particular:
• Anti-Corruption Law (Law no. 12,846/13) and Decree no. 8,420/15;
• Administrative Misconduct Law (Law No. 8,429/1992);
• Money Laundering Law (Law No. 9,613/98, amended by Law No. 12,863/12);
• Competition Defense Law (Law No. 12,529/11);
• Penal Code (Law No. 2,848/40);
• Consolidation of Labor Laws (Decree-Law No. 5452/43);
• Child and Adolescent Statute (Law No. 8069/90);
• Bidding Law (Law No. 8,666/93, Law No. 10,520/2002, Law No. 12,462/2011, among others);
• General Personal Data Protection Law (Law No. 13,709/2018);
• Consumer Defense Code (Law No. 8078/90);

3 General Principles of the Code of Ethics and Conduct

This Item describes the Guidelines that NTA ASFALTOS and FRAORE consider as PRINCIPLES that should be incorporated directly into the activities of all areas and units of the Companies, as they allow the dissemination of this ethical culture to all those under this Code of Ethics and Conduct. As following:

3.1. Compliance with Laws and Regulations

We consider that compliance with the laws and regulations that both Companies are subject to is essential to achieve success and, mainly, longevity of NTA ASFALTOS and FRAORE. For this reason, all employees and other partners and suppliers in general must learn and fully comply with all laws, regulations, self-regulations and policies applicable to the business of NTA ASFALTOS and FRAORE, in order to operate to the highest ethical standards and ELIMINATE any activity that may compromise the Companies.

3.2. Human rights

NTA ASFALTOS and FRAORE repudiate any form of discrimination or disrespect, as well as any conduct that may harm the dignity of any individual.

Respect for human rights must be ensured to all individuals who interact with NTA ASFALTOS and FRAORE, regardless of race, sex, sexual orientation, socioeconomic status, citizenship, ethnicity, language, religion, political/union option, physical or mental disability and any other characteristic unrelated to job requirements.

3.3. Child labor

NTA ASFALTOS and FRAORE repudiate any form of child labor and reject any conduct, directly or indirectly, linked to this type of activity.

3.4. Forced labor

NTA ASFALTOS and FRAORE repudiate forced labor and prohibit any attitude or behavior that may violate this position within the Companies or any indirect benefit, arising from such illegal practices by all those subjected to this Code as already stated in item 1.3.

3.5. Moral, Sexual Harassment and Discrimination

NTA ASFALTOS and FRAORE prohibit any kind of discrimination (based on, but not limited to, race, color, age, religion, socioeconomic status, position, sexual orientation, political/union option or physical or mental disability). Acts which disrespect employees will not be tolerated. In the same way, NTA ASFALTOS and FRAORE prohibit any kind of harassment, exploitation, abuse or violence to physical and psychological integrity.

Expressly prohibited behaviors and attitudes:
• Forcing employees to perform personal tasks for the benefit of any other employee;
• >Moral and/or sexual harassment to employees and third parties;
• Discriminating employees and third parties due to association with unions, religion, civil societies and political parties;
• >Disqualifying, offending, harassing or humiliating, publicly or privately, any employee, third party, or persons who are on the premises of NTA ASFALTOS and FRAORE or when doing any external work on their behalf;
• Requiring unattainable goals or demanding that business/projects be completed “at any cost”;
• Making threats of any order and for any purpose;
• Nicknaming employees against their will or in a humiliating and pejorative way;
• Presenting work or ideas of coworkers without giving them credit.

3.6. Equal Employment Opportunity and Labor Rights

NTA ASFALTOS and FRAORE demand fair, ethical and respectful treatment among their employees, as well as in their relationships with customers, suppliers, service providers and third parties.

We are committed with laws regarding working conditions as well as agreements signed with unions, right of freedom of association and dialogue and adequate wages based on local market surveys.

3.7. Employee Behavior

NTA ASFALTOS and FRAORE expect their employees to carry out their professional activities in a respectful, generous and polite manner with all those who are part of their daily activities.
In addition to the attitude mentioned above and those determined by this Code, here are some important examples of disapproval:
• Trading of any product and/or service on the Companies’ premises, even off the clock;
• Use of alcoholic beverages and narcotics on the Organization’s premises during and after working hours, as well as performing work in an altered state due to the use of these substances;
• Possession and use of weapons of any kind on NTA ASFALTOS and FRAORE premises or when in transit in a Company vehicle;
• The use of vehicles owned by NTA ASFALTOS and FRAORE for personal purposes without the prior authorization of the area manager;
• The misuse of any assets of NTA ASFALTOS and FRAORE and degrading attitudes, such as using a corporate computer to disseminate images and personal texts on social networks;
• Disclosure of any information from the Companies to non-employees, except for those already public.

NTA ASFALTOS and FRAORE are also concerned with the behavior of employees in the external environment, since they carry the image of the Companies in all their actions. Listed below are important factors that employees should pay attention to:

FACTOR 1: IMAGE

NTA ASFALTOS and FRAORE, as guaranteed under the Federal Constitution, guarantee the right to freedom of expression to their employees and do not support any form of suppression of this right. Emphasizing that the aforementioned right is accompanied by the each one’s responsibility on the form of expression and behavior in the work and external environments.

In the external environment, the employees’ image is associated with the image of the Companies NTA ASFALTOS and FRAORE. In this way, although the right to freedom of expression is guaranteed, everyone must keep an integrity and respectful behavior at any time, inside and outside the Companies, in any environment, virtually or in person. Here are some suggestions on how to act in different situations that will avoid unnecessary and prejudicial exposures for everyone:
• Deal with discretion with professional matters or matters related to NTA ASFALTOS and FRAORE in public places and private events;
• Abstain from dealing with private matters in environments integrated with service to the public and customers of our Companies;
• Do not disclose images of other employees in any media without their prior consent;
• Avoid using the badge and/or uniform of our Companies during non-work hours in external environments that negatively relate to their image and brand;

FACTOR 2: UNIFORMS, BADGES AND PROTECTIVE EQUIPMENT

Uniforms and badges must be used by employees for identification and access to the Company’s premises when necessary, especially drivers and employees in the manufacturing areas.
Regarding the use of uniforms, employees are responsible for:
• Use properly, only for their purpose;
• For the keeping and maintenance, no permission for change of shape, pattern and nature of the uniform;
• Notifying the Companies of any change that makes it unfit for use;
• Complying with guidelines for proper and tidily dressed.

When required for the position and under the terms of current legislation, NTA ASFALTOS and FRAORE will provide PPE (Personal Protective Equipment), of mandatory use, provided that the care described above must be followed.

Employees are expected to be aware of the importance of how their behavior is perceived, whether in the work environment, external environment and in relation to colleagues.

3.8. Fight against corruption

The international scope of the Companies NTA ASFALTOS and FRAORE imposes continuous challenges for keeping the performance of all its employees under control, as well as the continuous inspection of outsourced service providers. The transparent day-to-day practice of our leaders along with the means of communication for guidance and training are tools used to fight corrupt business practices, bribery or offering improper advantage, through violation of the Companies’ policies. We are committed to strengthen ethical principles in all our relationships and activities, private or public.

NTA ASFALTOS and FRAORE repudiate any action or omission that results in or suggests corruption or similar practices, as we believe that our values do not constitute isolated principles of behavior for certain occasions, but a comprehensive culture of daily experience and practice.

In general, offering or promising advantages, prizes or amounts to obtain or retain business (related or not to NTA ASFALTOS and FRAORE) are strictly prohibited practices. Every employee must be aware of and comply with our policies relating to gifts.

NTA ASFALTOS and FRAORE prohibit the direct or indirect involvement of their employees, third parties, partners and business consultants and clients in harmful acts, practices and behaviors against or that imply, directly or indirectly, in damages to the national or foreign Public Administration related to corruption or that attack public property. We strongly advise our employees to act in accordance with the laws dealing with corruption, especially Law no. 12,846/13 (Anti-Corruption Law – Provides for the administrative and civil liability of legal entities for the practice of acts against the public administration, national or foreign), in the conduct of their various relationships and activities.

4 Specific Principles of the Code of Ethics and Conduct

4.1. In the Internal Environment

4.1.1. Relationship

Each employee makes a difference at work and, regardless of hierarchical position, must be respected in the activity they perform, receiving dignified, fair treatment, as well as being held accountable for their performance.

NTA ASFALTOS and FRAORE are always committed to creating a healthy environment of respect for the law and its employees, creating a culture of integrity and compliance, where ethics in commercial, social and work relationships is a mission to be pursued and a value to be upheld.

4.1.2. Security, Health and Environment

The activities of NTA ASFALTOS and FRAORE are conducted in accordance with the laws and regulations applicable to each topic. Employees, suppliers, service providers, third parties or partners are not allowed to perform their activities outside the health and safety standards determined for each operation.

In order to maintain a safe and healthy work environment, NTA ASFALTOS and FRAORE seek to disseminate and train our employees, informing third parties in order they know and comply with the rules, as well as other requirements, procedures and health and safety practices.

In particular, it is worth highlighting initiatives, which applied to activities and services, value life and the environment. As following:
• Support and encourage the activities of the Internal Commissions for Accident Prevention, as well as those carried out during the SIPATs (Internal Weeks for the Prevention of Accidents at Work);
• Permanently manage occupational health programs required by law;
• Persistently strengthen the culture of regular training for employees at all levels of the corporation;
• Reduce, reuse and recycle the waste we produce.

4.1.3. Conflict of interests

Any activities and/or situations that imply a threat to the integrity of the values, principles and missions that NTA ASFALTOS and FRAORE assume or that may raise suspicions about the integrity of our activities must be avoided.

The conflict occurs when occasionally there is a possibility that the personal and private interests of employees overlap with the business and activities of the Companies NTA ASFALTOS and FRAORE.

Some relevant measures to take to avoid any type of Conflict of Interest are described below:
• Hiring employees who have relatives in the workforce: as long as the candidate does not intend to occupy a vacancy ranking below the other employee;
• Kinship with the Companies: it will be evaluated without any preference and on equal terms with other internal and external candidates;
• External work: only those who are employed by NTA ASFALTOS and FRAORE are allowed during the employee’s working hours;
• It is forbidden to carry out external work for competitors in any business segment of NTA ASFALTOS and FRAORE and/or activities that imply knowledge transfer and methodology transfer from the Companies to third parties.
• Prohibited to request, suggest or receive advantages of any kind, using the name of NTA ASFALTOS and FRAORE, position or function to obtain benefits for your own or for others (see item on Souvenirs, Gifts, Entertainment and Hospitality);
• Prohibited to accept payment of anything of value, cash or gain any unfair advantages from customers and third parties that maintain a relationship with NTA ASFALTOS and FRAORE;
• Prohibited the use of privileged information to favor any kind of business, for your own benefit or for third parties;
• Employees are required to communicate to immediate supervisors a professional, kinship or romantic relationship with suppliers, service providers, public agents, customers or competitors of our Companies;

4.1.4. Integrity of Information and Data

NTA ASFALTOS and FRAORE obtain information from all those involved in the business, from employees, at the time of the contract, to clients, which are sometimes confidential. In this sense, NTA ASFALTOS and FRAORE use information security means that bring transparency in all negotiations and contracts signed with and by the Companies. Companies and their employees must relate according to the principles of Good Faith and Data Protection.

All data and information received by NTA ASFALTOS and FRAORE, regardless of origin, are of great relevance. Therefore, data are handled safely and responsibly. Both Companies guide the employees to comply with the General Personal Data Protection Law (Law No. 13,709/2018) in their relationships and activities.
Therefore, in terms of data integrity:

Employees are expected to

• >Comply with all rules for the protection of confidential information of our Companies;
• Keep all internal information confidential, that is, those that are not in the public domain or that are not in official materials of NTA ASFALTOS and FRAORE, including documents, newsletters, images and any type of material, whether digital or analog;
• Not to manipulate or make use of information about the business of NTA ASFALTOS and FRAORE or their customers, suppliers, partners and service providers that may influence decisions for personal benefit or generate benefit or harm to third parties;
• Disclose strategic information only to individuals who need it for the development of work at NTA ASFALTOS and FRAORE, with prior authorization from their immediate supervisor;
• Avoid discussing or working with internal information in public areas, where conversations can be overheard or data confidentiality compromised;
• Respect the intellectual property of their own and of third parties that is in the possession of NTA ASFALTOS and FRAORE, regardless of the reason, always paying attention to the ethics and applicable legislation. All data, information, materials and inventions developed internally, because of the relations between employees and the companies, are for the exclusive use and property of NTA ASFALTOS and FRAORE;

NTA ASPALTOS and FRAORE are expected to

• Ensure information security, employee protection and business protection. To this purpose, the Companies may use prevention mechanisms such as telephone recordings, security cameras, control of the use of electronic mail, audits, among others, complying with the legal limits of good faith and property rights;
• Avoid the risks inherent to information assets by undertaking actions to raise employee awareness of the content of the Corporate Information Security Policy, including by means of specific training and auditing.

4.1.5. Donations, Sponsorships, Souvenirs, Gifts, Entertainment and Hospitality

Donations and sponsorships will be allowed as long as they strictly comply with the current legislation and are expressly authorized by the Board of Directors of NTA ASFALTOS and FRAORE, and employees and other interested parties must always observe Ethics

The process for donations and sponsorships will be kept on file for accountability for anyone interested for a period of 10 years. It is important to note that NTA ASFALTOS and FRAORE do not allow donations to political parties and do not sponsor political, racial or discriminatory projects of any kind.

Negotiations with suppliers, service providers, business consultants and third parties shall not be influenced by the acceptance, offer or promise of any type of advantage, however potential or apparent. Likewise, it is also prohibited to attempt to influence customers and potential customers by any employee and/or third party acting on behalf of the Companies, both in the private and public spheres, under penalty of sanctions.

Sustainability

NTA ASFALTOS and FRAORE respect the environment and carry out operations with socio-environmental responsibility to reduce environmental impacts.

Employees must perform activities through practices that preserve the environment and promote sustainable development, as well as the proper disposal of materials and the responsible use of resources such as water, paper and energy to avoid waste.

Protection of Personal Data and Privacy

NTA ASFALTOS and FRAORE are strict regarding the privacy of information handled by the Companies, employing control methods s and processes for preserving personal data, according to the General Data Protection Law

– LGPD, nu. 13,709/18. Thus, when necessary, the sharing of information will be handled by tools that garantee respect to controls needed to ensure compliance with the LGPD.

The information obtained through the services provided by NTA ASFALTOS and FRAORE must be used exclusively for the operations, and by the tools provided by the company that supplies the data: its use in any other way or for any other purpose is prohibited.

NTA ASFALTOS and FRAORE have a strategic committee for privacy and data protection, consisting of multidisciplinary teams, which are responsible for evaluating the handling and protection of existing and future data, internal processes and the introduction of practices aimed at their improvement.

Health Safety

As a form of respect for others and self-care to avoid new infections, the use of masks is fundamental, as it works as a barrier to the prevention and spread of respiratory diseases and prevents the transmission of influenza-causing viruses, such as influenza, measles, and seasonal diseases, such as rhinovirus, which causes colds, among others. Whenever you show symptoms of a cold, flu or respiratory illness, wear a mask on the Company’s premises.

4.2. In the External Environment

4.2.1. Customer Relations

Customer satisfaction is the solid foundation that supports the existence and longevity of the business relationship with NTA ASFALTOS and FRAORE. Therefore, it is essential to serve the customer, with an emphasis on the quality of our products, safety, sincerity in the relationships, punctuality in our deliveries, innovation, honesty, social and environmental responsibility, and in compliance with current laws and technical specifications of each product.

Our products and services must be cost-effective for our customers.
For this, we must make sure that:
• Customers must be served with courtesy and efficiency and provided with quick, clear, accurate and transparent information;
• Expenses with clients are acceptable as long as they are justified by work reasons, carried out within the limits established as defined in item 4.1.5, and not implying embarrassment or need for payment;
• Do not make a commitment to the customer, which is not within the service scope.

4.2.2. Relations with suppliers, service providers, partners and consultants

NTA ASFALTOS and FRAORE believe that the relationship with suppliers, service providers, partners and business consultants should always be based on the principles of free enterprise and fair competition, considering innovation and quality in contracting.

Having ethics, transparency and honesty as values, thus allowing compliance with current laws, NTA ASFALTOS and FRAORE expect our suppliers, service providers, partners and business consultants to comply with the Companies’ policies below to maintain and perpetuate the partnership:
• Respecting employees’ rights;
• Treating employees fairly and honestly, ensuring wages, working hours and benefits;
• Respecting human rights and prohibit all forms of forced or compulsory labor;
• Ensuring that child labor is not used in any operation (except by hiring an “apprentice”, in accordance with current legislation);
• Assuming responsibility for the health and safety of its employees;
• Communicating to NTA ASFALTOS and FRAORE when there is a suspicion of violation of this Code of Ethics and Conduct or any other illicit act that occurs on the premises of the Companies or externally during the provision of contracted services, using the appropriate Channel (as provided in item 6 ” Communication and Whistleblowing Channels”);

4.2.3. Relationships with Government Agencies

NTA ASFALTOS and FRAORE seek to comply with current laws, especially those aimed at fighting corruption and collaborating with Public Administration bodies whenever necessary. This acting takes place in day-to-day practice, in the communication and consciousness of all employees, in addition to guidance to suppliers, service providers, partners and business consultants.

In the relationships with the Public Power, there is a great risk of corruptive practices. For this reason, we reinforce here the compliance with the determinations contained in item

3.8 of this Code, which deals with “Fighting Corruption” and which shall be applicable to this item.

4.2.4. Relationships with Competitors

NTA ASFALTOS and FRAORE respect free competition and free enterprise and repudiate any action that violates these principles: we believe that a healthy environment among competitors benefits everyone.

Therefore, it will not be accepted any attitude that may produce effects such as limiting, distorting or harming free competition, arbitrarily increasing profits, making combined sales in consumer relationships and authorizing the irregular formation of consortia, which may lead to the practice of unfair competition and cartel formation, being mandatory the compliance with Law no. 12,529/2011 (Competition Defense Law).
From the foregoing, it is expressly prohibited:
• Exchange sensitive and/or confidential commercial information, especially about prices, adjustments, discounts, margins, costs, customers, sales volumes and commercial strategy with competitors;
• Discuss participation, preference and objectives in any type of public or private competition;
• Discuss participation and objectives in present and future bids;
• Practice tying, that is, requiring a buyer also to buy a second product or service;
• Divide territory, customers, suppliers, points of sale, etc.

4.2.5. Relationships with the Media

NTA ASFALTOS and FRAORE are committed to effective communication with the various communication channels, in order to establish a coherent, ethical and socially responsible disclosure of information. In view of this, only certain employees are authorized to speak on behalf of NTA ASFALTOS and FRAORE and give public testimony.

NTA ASFALTOS and FRAORE are not responsible for content posted by third parties on social media.

4.2.6. Relationships with the Community

NTA ASFALTOS and FRAORE, through our employees, develop and support projects promoting the social and economic development of the communities where we are present. We also seek to value the region where we operate, fostering local entrepreneurship and local labor in the hiring processes, promoting specific training aimed at developing professional training, and collecting the due taxes.

4.2.7. Relationships with the Union

NTA ASFALTOS and FRAORE respect and recognize the legitimacy of unions, associations, class entities and any legitimate organization that complies with current legislation.

Therefore, both Companies are committed to the search for solutions to serve the parties that make up the work relationship, through a continuous and harmonious dialogue.

5 NON-COMPLIANCE WITH THE CODE – Penalties

It is of note that, once any violation of the guidelines and determinations of this Code occurs, disciplinary sanctions may be applied, including verbal warnings, written warnings, suspension, payment of fines, indemnities and dismissal for just cause.

6 COMMUNICATION AND COMPLAINT CHANNELS

In case of any doubt and/or suggestions for improvement about this Code, internal rules and policies, the interested party may contact us at ntaconduta@nta-asfaltos.com.br. The Channel will be available to any employee, supplier, service provider, contractors, customers and other interested parties.

The Whistleblower Channel is a means of communication available for employees, third parties, service providers and customers to report actions, omissions, irregularities, non-compliances, any fact that contravenes current legislation and regulations and/or the guidelines and conduct described in this Code, or actions that may cause damage to any activity of the Companies, their employees, shareholders and other interested parties.
Some examples of irregularities that should be reported:
• Failure to comply with laws;
• NTA ASFALTOS and FRAORE internal policies and rules;
• Theft;
• Fraud and falsifications in general, and any relevant information on these matters, among others.

To facilitate the analysis and treatment of the complaint, you should try to collect as much information as possible such as name of the person involved, unit, actions, time, photographs and other documents.

The communications of any violations of this Code of Ethics and Conduct can be made through the email ntaetica@nta-asfaltos.com.br: this channel ensures independence, impartiality, confidentiality and information security.

Any and all complaints or communications through this channel will be forwarded to the Ethics Committee, which will analyze the communication and subsequently submit it to the Company’s Board of Directors for the necessary measures, always respecting the adversarial system and ample defense.

It is essential to act responsibly when making reports, which must be consistent, truthful and, if possible, with evidence.

7 TRAINING AND AUDIT

NTA ASFALTOS and FRAORE will frequently promote training related to the content of this Code, so that employees or consultants, suppliers and service providers will be able to clarify doubts about any subject of this instrument.

The review and maintenance of this Code is in the responsibility of the Human Resources department and will be carried out whenever it deems necessary to update it.

8 ANNEX

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