Aldoro: Pigmentos metálicos

Ethical Conduct

1. OBJECTIVE AND INSTITUTIONAL COMMITMENT

Aldoro Indústria de Pós e Pigmentos Metálicos Ltda. reaffirms its commitment to conducting
business with integrity, transparency, and social and environmental responsibility. This policy
establishes essential ethical guidelines to protect our reputation, strengthen trust with our
stakeholders, and ensure compliance with national and international laws.

2. SCOPE

This policy applies in full to Aldoro. It mandatorily covers:

  • All directors, managers, employees, temporary workers, interns, young apprentices,
    third-party service providers, suppliers, representatives, and business partners
    throughout our supply chain.

3. STRATEGIC GUIDELINES

We go beyond strict legal compliance by taking a proactive approach to prevent ethical risks and
ensure integrity in all our operations, and we are committed to:

  • Anti-Corruption and Bribery: Adopt a zero-tolerance policy against corruption. It is
    strictly prohibited to promise, offer, pay, donate, or authorize financial or material
    benefits to public officials or private entities. Corporate gifts must be given in strict
    accordance with common sense and must never influence business decisions.

  • Conflict of Interest: Ensure that personal interests do not interfere with professional
    decisions. It is mandatory to disclose situations that give rise to conflicts, such as hiring
    relatives, engaging in competing side activities, or using company assets for personal
    purposes.

  • Fraud: Ensure complete truthfulness and accuracy of accounting and financial records.
    It is strictly prohibited to omit, falsify, or tamper with reports, receipts, expenses, or
    entries in the systems with the intent to conceal results or achieve fraudulent goals.

  • Money Laundering: Prohibit any involvement in the concealment or integration of funds
    of criminal origin. The company strictly prohibits the hiring of professionals, service
    providers, or partners involved in illegal activities and money laundering.

  • Data Protection and Privacy: Ensure complete security and confidentiality in the
    handling of personal data belonging to employees, customers, suppliers, and partners.
    Our business practices operate in strict compliance with the guidelines of the General
    Personal Data Protection Law (LGPD – Law No. 13,709/2018).

4. CORPORATE GOALS AND MATERIALITY INDICATORS

To ensure that our ambitions are measurable and trackable, we will continuously monitor
progress toward the following goals through 2027, established based on the company’s available
resources:

  • Anti-Corruption Goal: Train 100% of employees involved in government and business
    relations in practices to prevent corruption and bribery.

  • Conflict of Interest Goal: Collect and review 100% of transparency disclosures and
    potential conflict of interest statements annually upon hire and through periodic
    updates.

  • Fraud Audit Goal: Ensure that 100% of accounting entries are traceable and supported
    by valid supporting documents for audit purposes.

  • Third-Party Approval Goal: Assess the reputation of 100% of new business partners and
    service providers to eliminate risks of money laundering and criminal activities.

  • Information Security Goal: Record zero data breach incidents under the LGPD
    regulations.

5. GOVERNANCE, MONITORING, AND TRANSPARENCY

Governance, day-to-day management, and monitoring of this policy’s implementation are the
joint responsibility of the Ethics Committee and the Administrative and Financial Department.

Those responsible are tasked with:

1. Identifying the best tools to facilitate the practical fulfillment of each commitment.

2. Submitting and reporting on ethical performance and annual compliance indicators
directly to the General Management.

This policy will be widely disseminated to employees and external stakeholders through internal
channels (intranet, bulletin boards), in-person awareness training sessions, and digital
publication on our institutional website.

The document will be regularly reviewed and updated by the management team to keep pace
with new market trends, legal changes, and the constantly evolving expectations of our
stakeholders.

6. CHANGE CONTROL

Date Version Description/Items Charged Author/Reviewer Approved by
August 6, 2026 1.0 First version of the Policy Environment and Administrative-Financial General Management