ANTI-CORRUPTION POLICY

1. Letter from the Managing Director

In the following pages, you will learn about our Code of Ethics and Conduct, which brings together a set of ethical principles and rules of conduct that guide our business and our company’s decisions. Thus, we seek to promote and consecrate our values, guiding our activities and allowing us to be a company recognized for the respect and ethics practiced on a daily basis.

This code of ethics gathers the set of guidelines that guides the behavior of the company’s employees, supervisors, managers, and directors. Just like social life, the code is not something static, established once and for all. The critical look at the practice and on the code itself will allow revisions and transformations to be made, over time, in the direction of the desired goals.

END ZAYA believes that the values and practices reflect high ethical and moral standards, which seek to ensure credibility, preserving the image of the company and its clients.

If you have any doubt about a situation being considered prohibited or not by END ZAYA, or become aware of any action that violates the ethical principles and conduct of this Code, an email should be sent to ouvidoriaendzaya@hotmail.com, reporting the occurrence, informing in detail the fact occurred, so that appropriate measures can be taken. Remember, say no to corruption in all its forms.

Paulo Cesar
Managing Director of End Zaya

2. Objective

END ZAYA has a policy of zero tolerance to acts of corruption. The exercise of professional activities and business affairs must always respect the laws and regulations in force, as well as the internal rules and policies of the company.

This Policy aims to ensure that all employees acting on behalf of END ZAYA comply with the Anti-Corruption Law No. 12,846/13 of August 1, 2013, as well as anti-bribery and anti-corruption legislation applicable in Brazil and the countries where they perform non-destructive testing services.

3. Reference Documents

– Federal Law 12,846 of 08/01/2013 – Anticorruption Law

4. Application

It applies to all its managers, employees, or anyone acting on behalf of the company.

5. Guidelines

The Anti-corruption Policy is a formal document that establishes mechanisms to prevent, detect, and respond to corruption, as well as conduct, monitoring, and action guidelines, encompassing awareness campaigns and training for employees and the entire public to which this policy applies, aimed at combating acts or attempts at corruption. Therefore, it is everyone’s duty to observe the following guidelines:

• Participation in any form of corruption or bribery, including payments or other ways of conferring benefits to any responsible party, originating from a public or private institution, aimed at influencing decision-making in non-compliance with the legislation in force, is prohibited;
• It is forbidden and intolerable for END ZAYA, not only the direct participation in acts of corruption, bribery or payment of bribes, but also the knowledge, encouragement or any indirect participation in illicit acts previously named;
• Make accounting records and supporting documentation transparent, faithfully reflecting the transactions made by the company, to ensure that its assets are not misused;
• Do not finance, sponsor, fund or in any other way subsidize or support the practice of illicit acts and irregularities.

6. Money Laundering

The crime of money laundering is the act of concealing or disguising the illicit origin of goods or values that are the proceeds of crime.

END ZAYA conducts its activities in accordance with the national and foreign laws applicable to the fight against Money Laundering and condemns all forms of corruption, direct or indirect.

7. Non-compliance and Consequence

It is the obligation of all END ZAYA employees to know and understand the content of this Anti-Corruption Policy, as well as to obey all the rules provided herein. Any violation of the rules and/or guidelines of this Anti-Corruption Policy will result in the application of appropriate disciplinary measures, which may include termination.

8. Reporting Channels

It is essential that anyone immediately report any acts or suspicions of non-compliance with this Anti-Corruption Policy. Questions or reports on this policy can be made through the Reporting Channel at (21) 97100-2866 (WhatsApp) or email: ouvidoriaendzaya@hotmail.com.

9. Final Disposal

The Anti-Corruption Policy will come into effect on the date of its approval by the Board of Directors of END ZAYA and the guidelines of conduct contained therein will be made known to all employees through the Declaration of Receipt and Commitment.