CODE OF ETHICS AND CONDUCT

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THE VANCOUROS GROUP, committed to the adoption of ethical and transparent behaviors and aiming to ensure that its activities and services comply with the best practices of the market, establishes this Code of Ethics and Conduct ("Code").

This Code represents the effort of VANCOUROS GROUP to standardize its criteria and values and assure the commitment of its professionals with the integrity and suitability of the services provided.

Overview

The present Code describes mandatory conduct in economic and commercial relations between VANCOUROS GROUP, its suppliers, partners and employees. In order to ensure that VANCOUROS GROUP establishes relationships with a degree of integrity and ethics that permeate the group's performance, recipients who already maintain or intend to maintain a commercial and/or labor relationship with any companies that are members of VANCOUROS GROUP must read this Code in full and declare their knowledge and consent to the fulfillment of its provisions.

Ethical objectives of the Code

(i) Reduce the subjectivity of personal interpretations of ethical principles;

(ii) Formalize and institutionalize a reference for the professional conduct of the Company's partners and employees, including the ethical management of actual or apparent conflicts of interest, becoming a standard for the Group's internal and external relationship with its stakeholders, whatever: shareholders, customers, employees, syndicate, partners, suppliers, service providers, competitors, society, government and the communities where it operates;

(iii) Ensure that the daily concerns of VANCOUROS GROUP with efficiency, competitiveness and profitability include ethical behavior; and

(iv) Ensure the adoption of corporate sustainability practices.

Working Practices

In the exercise of your position or function, each employee and/or professional hired by the VANCOUROS GROUP, shall:

(i) Maintain a posture of honesty, integrity, respect, loyalty, efficiency, transparency and impartiality, which should guide your relationship with the companies of the VANCOUROS GROUP and its stakeholders;

(ii) Not to participate in transactions and activities that may compromise your professional integrity or discredit your public image, as well as the image of the VANCOUROS GROUP;

(iii) To exercise your professional activities with competence and diligence, seeking technical improvement and permanent updating, and encourage all those involved to adopt such conduct;

(iv) Be strictly professional and impartial in the treatment of the public;

(v) Maintain behavior that leaves no room for discrimination or embarrassment, including moral and sexual harassment, in particular in the subordinate‐parent relationship;

(vii) Work in the pursuit for the maximization of the value ofthe vancouros GROUP companies.

(viii) Not to use the power inherent in the position or function in obtaining favors or personal services from subordinates;

(ix) Promote a culture, through leadership, in which conduct based on ethical principles is recognized, valued and taken as an example by all employees;

(x) Ensure that the activities d the VANCOUROS GROUP are developed taking into consideration the local community and the environment, seeking to maximize the use of resources and minimize any negative impacts arising from its operations;

(xi) Adopt irreprehensible conduct in relation to any form of corruption, in its relationship with suppliers, customers, public servants or any other public of interest;

Compliance With Legislation

Each employee and/or collaborator of the VANCOUROS GROUP shall, within the scope of its activities:

(i) Comply with the laws and regulations applicable to the business of the VANCOUROS GROUP and the commercial practices in force;

(ii) Observe anti-corruption and corporate governance rules;

(iii) Observe federal rules and guidelines for the processing of personal data, as well as the privacy policies and internal regulations of the VANCOUROS GROUP on the subject.

Code Adherence Responsibility

All employees and collaborator of VANCOUROS GROUP are responsible for adhering to this Code, including the liability of pofissionais for failures in the exercise of due supervision and in the investigation of violations of this Code of Ethics and Conduct by their subordinates that can be reasonably verified by the professionals.