Code of Conduct

Yes. It's natural that in the personal relationships, employees have contact and even family members who work for competitors or suppliers. However, to protect both the employee and Raízen, it is necessary that the situation be disclosed and any potential conflicts or interest avoided. B reporting it, you can receive guidance on how to avoid conflicts and manage the situation.

Yes. This situation could be a potential, actual, or perceived conflict of interest, depending on Raízen's relationship with the financial institution. You should report the situation in the Conflict of Interest Disclosure Tool so that the case can be evaluated and any preventive measures adopted to protect you, your sibling, and the company.

Gifts and hospitality above the values indicated as acceptable in the Code of Conduct and without violation of the prohibitions provided therein must be registered in the Gifts and Hospitality Reporting Tool. In this specific case, regardless of the value, as there is a potential or apparent conflict of interest, it is necessary to register the situation in the Conflict of Interest Reporting Tool, so that your immediate superior and the Compliance area may evaluate if, by accepting the ticket, a conflict situation could occur and, with preventive measures, you, your friend, and Raízen are protected.

Yes. The situation is a potential conflict of interest, because if the employee from your team becomes your tenant, decisions regarding promotion or termination may be influenced by the financial obligation they will have with you as a result of the lease. Therefore, before making a decision about the lease, report the case in the Conflict of Interest Tool to receive specific guidance on alternatives to avoid a conflict of interest.

This is bribery even if, in this case, the supplier is not offering a cash payment. Bribery occurs when someone promises an undue advantage, which may be financial resources, services, or goods, to obtain favorable treatment to the detriment of third parties or even Raízen's interests.

Yes. Considering the link with the owner of one of the companies participating in the bidding process, it is recommended that the leadership of the process be transferred to another employee. Additionally, the situation must be registered in the Conflict of Interest Tool, for transparency regarding the activities performed up to the moment of the process transfer.

In general, this means that we should not involve ourselves in situations where an ordinary person would have good reason to question our objectivity or ability to be impartial regarding the business decisions made at the company.

If you assess that refusing the gift could be offensive to the supplier, the gift with a value above that provided for in the Code must be reported in the Gifts and Hospitality Tool so that the possible acceptance may be appraised by your immediate superior and Raízen's Compliance area.

You can always refuse a gift or hospitality, with a thank-you note, under the justification that Raízen seeks not to encourage this practice. If the gift is inappropriate in any way, notify your immediate manager who will guide you on how to proceed.

Although technical visits may occur in the context of a negotiation such as this, the offer of a weekend stay for the employee responsible for the negotiation and their family is outside of what would be expected for a technical visit to evaluate a corporate event space. The situation may generate a conflict of interest and even be configured as bribery. As a rule, gifts and hospitality offered in the course of a negotiation process should not be accepted. Report the occurrence to your immediate superior, who will evaluate the necessity of a technical visit in this specific case.

You must register the gift offer in the Gifts and Hospitality Reporting Tool, so that the Compliance area may evaluate potential risks of the offer being interpreted as bribery of a government official.

No. You must refuse the offer to avoid a conflict of interest, since as reported he is still a supplier to the company and serves your area. The situation must also be registered in the Conflict of Interest Reporting Tool, to ensure transparency and that your future business decisions are not questioned due to an apparent conflict of interest.

The acceptance of small gifts or other favors from a client may be permitted, but you must always follow the rules defined in the Gifts and Hospitality section of the Code of Conduct. In particular, you must never allow gifts and hospitality, offered or received, to influence business decisions, or give someone else reason to suspect that there may be an influence. The exchange of gifts and hospitality during negotiation periods is prohibited and, if the gift or hospitality exceeds the maximum indicative values of the Code of Conduct, you must register the offer or receipt in the Gifts and Hospitality Tool, so that your superior and the Compliance area can evaluate whether you may proceed.

First, bear in mind that the participation of Raízen employees in association meetings where competitors are present must occur only for the discussion of general topics related to Raízen's sectors of activity. Under no circumstances should competitively sensitive information, such as price, production capacity, production cost, storage capacity, among others, be shared among the participants. You must also ensure that you have specific authorization to represent Raízen in such forums, have completed the online and in-person antitrust compliance training, and participate only in meetings with a defined agenda.

This is a prohibited practice! Make it clear to the competitor's employee that Raízen operates in compliance with antitrust laws and cannot negotiate market division. For further guidance, read the Antitrust Compliance Policy.

No. You must never exchange or receive competitively sensitive information, such as price, production capacity, production cost, logistics capacity, storage capacity, among others, from competitors. In this case, immediately delete the message sent and inform the group that you are taking this measure, as competitively sensitive information must never be exchanged between competitors. For further guidance, contact the Legal Department.

Integrity is a Raízen Business Principle. Therefore, we will always compete ethically and within the rules. Inform the Legal Department of any cases of unlawful conduct you are aware of, so that any appropriate measures may be evaluated.

Raízen's Legal Department can help you evaluate whether the commercial partnership is viable, define its operational mechanism, and structure the operation. Before moving forward with negotiations with the competitor, seek assistance from the Legal area.

Knowing suppliers and business partners is fundamental to protect Raízen and its employees from improper conduct by third parties that could negatively impact the company's activities. Thus, it is necessary to ensure that the company operates legally, observing the Raízen Business Principles. In this case, contact the Compliance area so that an analysis of the provider can be conducted and, if there is real doubt about the company's conduct, Raízen must stop using its services

No. Obtaining information about a competitor by misrepresenting your identity or inducing a competitor's employee or a third party to disclose confidential information is improper. Gathering information about our competitors is a legitimate business activity only when done in a legal and ethical manner.

No. You must never discuss prices or other competitively sensitive information, such as price, production, business strategies, among others, with competitors. The fact that the competitor is a friend and the conversation takes place during a private lunch does not change the rule. To protect yourself and Raízen, you must report the request to the company's Compliance area.

No. This is known as a cartel operation, which is illegal and violates antitrust laws. You must never participate in conversations of this type and, if you are at a meeting where such discussions are taking place, you must leave immediately, ensuring that your departure has been recorded. To protect yourself and Raízen, you must report the situation to the company's Compliance area.

No. The use of intermediaries, as well as the lack of concern regarding the price to be paid, may be indications that the transaction will be used to conceal the illicit origin of funds. As a rule, you must ensure that the source of a payment is the beneficiary of the transaction under negotiation or verify the relationship between the payer and the beneficiary. In case of doubt, contact the Compliance area for guidance on how to act in the specific case.

Due to the impossibility of tracing the origin of funds in cash transactions, Raízen does not accept payments in specie. Therefore, advise the customer that payment for the operation must be made via bank transaction, the source of which must be a bank account owned by the customer or, subject to specific analysis, by a company proven to be linked to the customer.

Yes. The use of an unknown intermediary may be a cover for money laundering activities. Contact Raízen's Compliance area so that the situation can be evaluated.

Yes. Diligence is required when hiring any third party, but in cases where the service provider will represent Raízen in activities related to the public administration, the third party must undergo an integrity audit conducted by the Compliance area.

Raízen recognizes the right of its employees to run for public office. However, depending on the situation, political activity may create a conflict of interest with the activities performed at the company. Therefore, you must register your intention with your immediate supervisor and Raízen's Compliance area, so that a risk analysis of the specific case can be conducted.

You must verify, with the support of the Legal Department, if the payment requested by the public official is an official fee from the public agency for the priority review of processes; if that is the case, the payment may be made. Raízen does not make payments to obtain illegal or undue advantages under any circumstances; therefore, in case of doubt, seek guidance and familiarize yourself with the content of Raízen's Anti-Corruption Policy.

It is recommended that you consult the company's Legal Department so they can evaluate the labor issues reported in the media in the past and how the company conducts its labor relations today. As a rule, be cautious when closing deals on behalf of Raízen and always seek—regardless of whether there is negative news or not—to inform yourself about how suppliers, customers, and partners conduct their business. The ultimate responsibility for what this third party does on behalf of Raízen is yours; make no mistake about it!

Raízen's import and export operations, as well as the related financial flows, are subject to certain international trade restrictions imposed by entities such as OFAC and the UN. Therefore, it is recommended that you stay up to date on existing sanctions, which are periodically disclosed by the Legal Department, and perform the necessary screenings of companies and individuals, in accordance with the procedures set forth in the Policy for Sanctioned, Boycotted, or Embargoed Countries, Individuals, or Institutions.

Although your intention is good, leave it to the Corporate Communications department to provide an official response to the media outlet, safeguarding Raízen's image and reputation. You can help by forwarding the news to the Communications area, which will take the appropriate measures.

You must not publish any Raízen information that has not already been publicly disclosed by the company itself. Furthermore, avoid sharing photos of company facilities, especially production units, to prevent the undue disclosure of processes or strategic business data. We do, however, encourage you to share, comment on, and post content produced by Raízen and released on the company's official social media channels.