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Ethics and Compliance Center

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Ethics and Compliance Center

Knowledge base

We are proud of our commitment to conduct our business with the highest standards of honesty, integrity and respect for people and to demonstrate to clients, investors, business partners and public servants of the direct, local and foundation administration, as well as the holders of elective office , that confidence in the SRM business conglomerate is justified. SRM’s Compliance Program aims to keep the company adhering to internal and external laws, regulations and regulations, always ethically in its professional conduct, consolidating the governance, efficiency and sustainability of the business. The Program has the commitment of the Board of Directors and is disseminated by all hierarchical levels of the parent company and its subsidiaries.

Ensuring that all employees know, commit to and practice SRM’s ethical standards is our primary responsibility with the Code of Ethics and Professional Conduct implemented within the company. The SRM Code is not a final document, because as we are constantly evolving, it also tends to be modified as new ethical or moral issues arise to be discussed in our work environment, but should be used as a guide for our actions and decisions regarding moral conduct. Failure to comply with internal legal or regulatory provisions results in disciplinary sanctions, according to the severity of the occurrence, its circumstances and the level of participation of each party, as described in the Compliance Policy.

DOWNLOAD CODE OF ETHICS

The Compliance Program was implemented at the end of 2017 and its main actions were:

• Establishment of the Ethics Committee: composed of the Executive Directors and the Compliance Manager, and other participants may be invited. This committee discusses the main issues of implementation and maintenance of the Compliance Program, as well as addressing issues of the Complaints Channel;

• Creation of the Ethics and Compliance Center: it gathers in a single portal the Denunciations Channel as well as all information related to our Culture and Ethics Program.

• Publication of the Code of Ethics and Professional Conduct (in Portuguese, Spanish and English) and Compliance Policy: reinforces the company’s positioning with issues related to ethics and integrity in conducting the business, as well as our relationship with the different publics and customers;

• Implementation of the Complaints Channel: channel dedicated to the communication of attitudes that are in disagreement with our Culture and Ethics Program or that may affect our commitment to good anti-corruption market practices.

• Structuring of Money Laundering Prevention training (in Portuguese and Spanish): compulsory training for employees who join the company, conducted on the online platform of the corporate university.

To ensure the professional integrity of our work environment, we must exercise our ethical principles daily, as individuals and as a company, this is precisely our intention with UniSRM compliance training. During the integration of all the employees of SRM, the Human Resources team presents the Code of Ethics and Professional Conduct, the Compliance Policy and the training of PLD – Prevention of Money Laundering, which is available to all through the SRM Portal (Intranet) in the UniSRM section. The employee by use instead:

1. Know the ethical standards of the company, dedicating its first day to SRM integration;

2. Commits to the presented standards, signing the term of commitment and exemption of conflicts of interest;

3. Verify your knowledge and effectiveness of the training by responding to the online test at the end of PLD training.

The maintenance of the Compliance Program is as important as its implementation and it is with this commitment that SRM conducted the following actions:

• Creation of Mr. Ethics, mascot of the Compliance Program that discloses, bi-weekly, ethical dilemmas of the professional context of the employee;

• MR. Challenge campaign Ethics, dedicated to the recycling of knowledge of PLD training in UniSRM for all employees, including Peru and Chile;

• Maintenance of the compliance knowledge base.