VISION

To be at the forefront of initiatives and the construction of a new technological narrative for the physical and digital asset printing and management segment during the global digital transformation of businesses.
 

MISSION

To be a business transformation agent through strategic management technology, applied to digital, physical, and electronic documents, with an emphasis on the continuous improvement of organizational processes.
 

VALUES

• Constant pursuit of innovation;

• Respect for the community and the environment;

• Virtuosity in our execution;

• Proactivity in our work environment.
   

CODE OF CONDUCT, ETHICS, AND INTERNAL REGULATIONS
 

SCOPE

The rules and guidelines established in this Code/Regulation apply to all employees of the PRINTER DO BRASIL Group companies, without distinction of role, profession, hierarchical level, or any other kind.

OBJECTIVES

• To establish rules of conduct between the Company and its Employees, Contractors, and Third-Party Workers to increase work efficiency (delivery), improve relationships with clients, suppliers, and partners, as well as preserve and develop its image in the market and society.

• To raise employee awareness about the importance of ethical, dignified, and committed conduct, always acting in accordance with the laws, rules, internal regulations, standards, and values established by Printer do Brasil in the performance of their duties.

• To adopt procedures and postures that ensure the Printer do Brasil Group maintains its compliance status at all times.
   

SUMMARY

PART 1 – CODE OF CONDUCT AND ETHICS I. Basic Principles and Compliance II. Conflict of Interest III. Anti-Corruption IV. Anti-Money Laundering V. Responsibility for Observing Rights and Mutual Respect VI. Work Environment VII. Relationship with Clients, Suppliers, and Competitors VIII. Environmental Protection IX. Responsibility for Compliance

PART 2 – COMPLIANCE POLICY I. Objective II. Definitions III. Compliance Guidelines IV. Guidelines for the Compliance Program V. Pillars of the Compliance Program VI. Complementary Documentation VII. Final Provisions
 

PART I – CODE OF CONDUCT AND ETHICS
 

I. BASIC PRINCIPLES AND COMPLIANCE

The principles guiding this code are directly associated with our values and objectives. Printer do Brasil's pioneering spirit is based on a trajectory of success and achievements as a solid and reliable organization.

Our principles are:

• Client Satisfaction;

• Commitment to the quality of services provided;

• Valuation of human capital;

• Exemplary conduct.

Our Compliance Policy has the following basic guidelines:

• Maintain high standards of integrity and ethical and moral values, through the dissemination of a culture that emphasizes and demonstrates to all employees the importance of Compliance in all business aspects;

• Ensure compliance with applicable laws and regulations issued by national and foreign bodies and agencies, and adherence to established internal policies, norms, and procedures;

• Guarantee an internal control structure that leads to an understanding of the main risks incurred by the company, with a view to ensuring that they are identified, assessed, monitored, controlled, and mitigated efficiently and effectively;

• Maintain the Compliance Program aligned with best practices, which should be periodically reviewed and updated, so that any identified deficiencies are promptly corrected, ensuring its effectiveness and efficiency;

• Align the Compliance Program with the objectives established by the company and with the periodic review of business strategies and instituted policies;

• Ensure the existence of responsibility assignment and delegation of authority, observing the hierarchical structure established by the company, guaranteeing appropriate segregation of duties, in order to eliminate conflicting responsibility assignments, as well as reduce and monitor, with the required independence, potential conflicts of interest existing in the areas;

• Ensure the consistency and timeliness of information relevant to decision-making or that affects the company's activities, through a reliable, timely, understandable, and accessible communication process for the external public and employees;

• Maintain control and contribute to the efficiency and improvement of tools within the company's Compliance environment, namely: the Code of Ethics; the Code of Conduct; the Individual Employment Contract.

• Regularly conduct communication and training processes for this Policy, its respective procedure, as well as the Code of Conduct and Ethics and other Compliance documents, for all interested parties.
   

II. CONFLICT OF INTEREST

In the course of performing our activities, it is important not to get involved in situations of conflict of interest. Therefore, we must live up to the high degree of trust that Printer do Brasil places in our integrity, not allowing our personal or financial interests to override the company's interests. Our decisions must be based on honesty, respect, and integrity.
 

III. ANTI-CORRUPTION

We define corruption as the abuse of power conferred on someone for their own benefit. In other words, corruption means offering, receiving, promising, or granting any kind of advantage to any person as an incentive to act dishonestly.

In this sense, we are individually and collectively responsible and fully committed to the Brazilian Anti-Corruption Law No. 12,846/13, which provides for the administrative and civil liability of legal entities for acts against public administration, national or foreign.

For this reason, in their relationships with clients, suppliers, partners, and governmental bodies, the conduct of Printer do Brasil employees must be governed by the principles of ethics and legality, and they are expressly prohibited from:

• Making and/or receiving any improper, dubious, informal, or illegal payments from the public or private sector, as well as favoring, by granting undue benefits or outside usual commercial practices, certain clients and suppliers, to the detriment of others.

• Receiving favors, gifts, gratuities, or any kind of benefit from clients or suppliers, except for items of small value. In any case, the fact must be promptly reported by the employee to their hierarchical superior for the adoption of any necessary measures, if applicable.

• Offering, giving, or promising any privileges, gratuities, or advantages to public officials or equivalents to cause them to perform, omit, delay, or influence official acts;

• Soliciting or receiving, directly or indirectly, any privileges or advantages from public officials due to their position or function;

• Offering favors and gifts or covering travel and entertainment expenses for public officials or agents;

• Making, offering, or accepting favors with the intent of illegally and unethically obtaining or maintaining contracts, licenses, and/or government approvals.

Printer do Brasil respects free competition and does not condone cartelization, price-fixing, industrial espionage, or any other measure that interferes with free competition.
 

IV. ANTI-MONEY LAUNDERING

Money Laundering is a process that seeks to disguise the nature and source of money associated with an illegal activity by introducing these funds into the economy in a way that appears legitimate and/or so that their origin or owner cannot be identified.

The Printer do Brasil Group is committed to combating and not tolerating corruption in any of its forms, including extortion and bribery. It adopts all tools and mechanisms for preventing money laundering to avoid the use of its resources for "money laundering" purposes, in addition to firmly and determinedly saying no to business opportunities that conflict with this commitment. We adopt ethical, integral, and transparent principles in relationships with public and private agents.

All members of the Printer do Brasil Group must comply with laws and regulations addressing Money Laundering in all spheres where they operate.
 

V. RESPONSIBILITY FOR OBSERVING RIGHTS AND MUTUAL RESPECT

Employees, suppliers, and service providers must guide their actions by mutual respect, teamwork, and transparency. No type of prejudice or discrimination based on ethnicity, origin, sexual orientation, political or religious conviction, or harassment of any nature, including moral or sexual, will be allowed. It is everyone's commitment to ensure the preservation and correct use of Printer do Brasil's assets.
 

VI. WORK ENVIRONMENT

Relationships in the workplace will be based on respect, trust, and transparency, in accordance with Title VIII of the Internal Regulations.
 

VII. RELATIONSHIP WITH CLIENTS, SUPPLIERS, AND COMPETITORS

Our employees must constantly seek to anticipate and satisfy client needs through products and services, working with a high level of quality.

The competitiveness of the services provided and marketed by Printer do Brasil is the differential that must motivate us to always stay ahead of the competition and must be exercised based on fair competition. Therefore, no comments or actions that may directly or indirectly affect the image of competitors should be made.
 

VIII. ENVIRONMENTAL PROTECTION

The environmental management program developed by Printer do Brasil aims to reduce waste that could contaminate our planet, as well as the environmentally appropriate disposal of involuntarily produced waste. Commercial success, sustainability, environmental protection, and social responsibility are elements that must be balanced.
 

IX. RESPONSIBILITY FOR COMPLIANCE

The application and successful use of this Code of Conduct and Ethics depend on everyone's effort to comply with the principles described herein. Each employee is responsible for their own conduct and is obligated to report any violation of this code. No employee may claim ignorance of the guidelines contained in this code, under any hypothesis or argument.
 

PART II – COMPLIANCE POLICY
 

1. OBJECTIVE

This Policy establishes Compliance principles, guidelines, and functions at all levels of the Printer do Brasil Group, as well as all companies linked to the Group, in addition to disseminating the Compliance culture and practice, demonstrating the importance of understanding and complying with legal, regulatory, normative, and procedural determinations, both external and internal. The main objectives of implementing the Printer do Brasil Group's Compliance program are:

• To allow companies to be guided by standards and models of conduct and practice aimed at preserving ethics and integrity;

• To protect the image of the Printer do Brasil Group and all companies linked to the Group, inhibit the occurrence of internal or external fraud, and keep the company away from the risk of suffering penalties from regulatory bodies, judicial authorities, and other public authorities;

• To support the organization regarding local regulations, as well as specific policies and norms of the sector in which it operates, seeking to maintain the highest ethical standards;

• To prevent the company from promoting corruption or violating free competition, whether directly or indirectly, in all its areas and levels of operation.
   

2. DEFINITIONS

In the institutional and corporate sphere, Compliance is the set of disciplines aimed at complying with and enforcing legal and regulatory norms, policies, and guidelines established for the business and activities of the institution or company, as well as preventing, detecting, and addressing any deviations or non-conformities that may occur. The term Compliance originates from the English verb "to comply," which means to act in accordance with a rule, an internal instruction, a command, or a request.

Being in Compliance means being in conformity with legislation, regulations, norms, and procedures, external and internal, and with corporate principles that ensure best market practices and Corporate Governance, seeking to mitigate the risk of "Non-Compliance."

Risk of "Non-Compliance" is defined as the risk of compromising the integrity of the Printer do Brasil Group and its affiliated companies due to non-compliance with applicable national and foreign legislation and regulations, external or internal norms, which may lead to legal and/or regulatory sanctions, or even financial losses and other damages, especially to the Group's image.

Compliance Program is a program aimed at preventing and/or identifying conduct that is not in conformity with the rules (legislation, regulations, norms, and procedures, external or internal), identifying risks and/or causes, and acting preventively and/or correctively, also promoting a culture that encourages compliance with established rules and ethical conduct, guided by the principle that "doing the right thing is the best."
 

3. COMPLIANCE GUIDELINES

3.1. Disseminate high standards of integrity and ethical values, through the dissemination of a culture that addresses the importance of conformity within the Printer do Brasil Group; 3.2. Disseminate the principles, guidelines, and conduct established in the Code of Ethics, Compliance, and Internal Regulations of the Printer do Brasil Group and affiliated companies; 3.3. Protect the reputation of the Printer do Brasil Group, maintaining the trust of business partners, suppliers, service providers, employees, and clients; 3.4. Establish and implement a "Compliance Structure" which will be responsible for managing the Printer do Brasil Group's Compliance Program, ensuring independent and autonomous management, with a segregated function, in order to guarantee impartiality and fairness in all its actions; 3.5. Ensure full access to any information, prompting and supervising investigations when the "Compliance Structure" deems it necessary, as well as, in response to complaints from the "Whistleblower Channel," establishing meetings with the Group's Senior Management; 3.7. Ensure, to the members of the "Compliance Structure," confidentiality in the exercise of their function, as well as maintaining the anonymity of those involved, protecting their integrity; 3.8. Provide the "Compliance Structure" with the minimum necessary resources (material and human) for the proper performance of its function.
 

4. GUIDELINES FOR THE COMPLIANCE PROGRAM

4.1. Manage the implementation of the Printer do Brasil Group's Compliance Program, as well as its maintenance and continuous improvement, considering the program's pillars; 4.2. Ensure free and immediate access to senior management and regulatory and/or supervisory bodies, to effectively manage risks and irregularities or violations detected due to non-compliance; 4.3. Ensure the implementation, execution, and compliance with the Printer do Brasil Group's Compliance rules and procedures; 4.4. Guide and assist in risk mapping (risk analysis), as well as in defining and implementing actions to eliminate and/or mitigate these risks; 4.5. Guide and assist in identifying causes and countermeasures, as well as monitoring their implementation to correct non-conformities and/or improvements identified in the Compliance Program; 4.6. Safeguard and guide on good governance practices and other sectors of the Group.
 

5. PILLARS OF THE COMPLIANCE PROGRAM

Pillars of the Printer do Brasil Group's Compliance Program:

1. Senior Management Support; It is important to highlight that the implementation of a Compliance program requires the full adherence of the company's directors. Senior management must support and be involved in the planning and execution of actions. Likewise, it is necessary to rely on a Compliance specialist, who will be responsible for the implementation of the entire project. In addition, senior management will regularly assess the implementation and functioning of the program, taking appropriate measures to correct implementation deviations and to improve the program.

2. Risk Assessment; Risk assessment, also called Compliance Risk Mapping, is one of the most important steps in implementing an integrity program. This is because it is where all potential risks and their impacts for the organization to achieve its objectives are identified. Once identified, they will be classified according to their degree, so that it is possible, with proper management, to accept, control, mitigate, and transfer the risk.

3. Code of Conduct and Compliance Policies; The Printer do Brasil Group will make available its Code of Ethics, Compliance, and Internal Regulations. It contains all policies to be adopted in the company, not only to maintain compliance with laws but also to ensure a culture of integrity and valuing ethical behaviors.

Policies, norms, and procedures to be created and/or revised for the implementation and proper functioning of the Compliance Program, as well as the good business of the Printer do Brasil Group, will be identified and prioritized. The following aspects will be observed: 3.1. Policies, norms, and procedures will be available physically and/or electronically to everyone, according to the needs of each employee, supplier, service provider, and client, for the proper performance of their tasks; 3.2. The elaboration and/or revision of policies, norms, and procedures will be prioritized considering the need for adaptation to the implementation of the Compliance Program and the operational needs of each involved area; 3.3. The language used in policies, norms, and procedures will be clear, objective, and easy for everyone to understand; 3.4. A standardization system will be implemented, where documents, their types and hierarchies, approval levels, as well as storage, distribution, revision control, and training will be defined and managed by the "Compliance Structure"; 3.5. The "Compliance Structure" must elaborate all priority norms and procedures for the implementation and functioning of the Compliance Program.

4. Internal Controls; The Printer do Brasil Group will create control mechanisms to ensure that risks are minimized, both internally and externally. Accounting and financial records themselves are examples for transparently reflecting the business reality, as well as all probative documents, investigations, and partner analyses, minimizing business risks.

With each monitoring, investigation, or change in the internal or external environment, an assessment will be made to identify improvement points that should be implemented in the Compliance Program. Furthermore, at least semi-annually, an assessment will be made to identify problems that were dealt with but continued to occur ("chronic problems") and opportunities that were identified through the acquisition of new knowledge and the development of the program itself. These assessments will be conducted by the "Compliance Structure," documented and approved by the Printer do Brasil Group's Senior Management, and then implemented and evaluated for their effectiveness.

5. Training and Communication; The Compliance Program aims to help people "understand what is right and understand why doing the right thing is better." Thus, it is necessary to keep people informed about the Compliance Program from the beginning of its implementation and, especially, when it is fully operational. To this end, an internal communication plan will be created, using existing communication tools or others, if necessary. A Compliance training plan will also be created, considering the following points: 5.1. Identify relevant Compliance training, based on the Code of Ethics, Compliance, and Internal Regulations, mapped risks, applicable concepts, and various topics that the Compliance Program deems interesting to deepen the knowledge of Printer do Brasil Group employees; 5.2. Training can be developed internally or externally, and in various application formats, according to the needs of the Printer do Brasil Group; 5.3. For each training, the target audience will be defined, depending on the topic covered and the needs of the sector, however, all training will be available to all employees of the Printer do Brasil Group, if interested; 5.4. Training can be in-person or remote; 5.5. Senior management will regularly evaluate participation (program completion) and knowledge retention, efficiency, and effectiveness of the training.

6. Whistleblower Channels: Once employees are aware of the importance of Compliance, they need active whistleblower channels to report violations of the Code of Ethics.

A Whistleblower Channel will be established, accessible in various ways, open to all employees, suppliers, service providers, and clients of the Printer do Brasil Group and companies linked to the Group, so that they can anonymously or non-anonymously report conduct or behaviors that are not in accordance with the company's Compliance Program (external or internal laws, regulations, norms, and procedures).

All complaints will be registered and evaluated, according to specific rules and procedures to be defined during the implementation of the Compliance Program.

THE PRINTER DO BRASIL GROUP WILL GUARANTEE CONFIDENTIALITY THROUGHOUT THE INVESTIGATION AND CASE ANALYSIS PROCESS, MAINTAINING THE ANONYMITY OF THE WHISTLEBLOWER AND THE INVESTIGATED PARTY UNDER ALL CIRCUMSTANCES, AVOIDING ANY TYPE OF RETALIATION AGAINST THE PARTIES INVOLVED.

RELIABILITY – ANONYMITY – INVESTIGATION – SANCTION

Channels: Email: compliance@printerdobrasil.com.br Website: www.printerdobrasil.com.br/canal-de-denuncia Phone: (41) 3387-8613

Possible infractions to be reported:

• Active or passive corruption by an employee/supplier or client;

• Theft, fraud, or bribery;

• Violation of our Code of Ethics and Internal Regulations;

• Violation of Environmental Laws;

• Violation of Human Rights;

• Violation against your or another's physical and moral integrity;

• Sexual harassment, discrimination, or racism.

7. Internal Investigations; All received complaints will be investigated according to specific rules and procedures for this purpose, which will be developed during the implementation of the Compliance Program. The investigation will be conducted by an internal or external investigator, depending on the seriousness or need for specialization for the investigation, being monitored at all times by the Compliance manager and senior management.

The investigation should be limited to ascertaining the facts, fully determining whether improper conduct occurred, who was involved, and under what circumstances. The investigation will always be independent and based on facts and data.

The main objectives of the investigation are minimizing risks, identifying opportunities for improvement, protecting the company's image, and clarifying the facts.

The Printer do Brasil Group will not disclose the details and decisions made resulting from the investigation process. A summary, with key statistics related to investigations, such as: number of complaints, types, results, and applied sanctions, may be periodically communicated. This point will also be defined in a specific norm, to be developed during the implementation of the Compliance Program.

Investigation Process: Complaints will be received directly at the email: compliance@printerdobrasil.com.br, which will have its first analysis by the Compliance manager, who will separate the complaints by degree of complexity and importance. After separation, they will be presented to Senior Management at monthly Compliance meetings, and the meeting may be convened outside of the scheduled date in extraordinary cases due to their importance. The meeting will initiate, if applicable, the internal or external investigation. The investigated party will be guaranteed the right to due process and ample defense.

After hearing the interested parties and collecting evidence, a new meeting will be established with Senior Management, who will decide if conduct contrary to the company's Compliance policy occurred and, if so, will apply the sanction corresponding to the seriousness of such conduct.

Sanctions may include warnings/penalties and/or termination of the employee, always in light of current labor legislation.
 

8. Due Diligence

Due Diligence does not eliminate any risk but plays a fundamental role in providing the Printer do Brasil Group with as much information as possible about the threats and opportunities involved in the business. Due Diligence is the process of collecting various types of information about a company that may be acquired, merged, or potential business partners, as well as clients of the Printer do Brasil Group, always aiming to minimize risks.

Types of Due Diligence:

• Integrity Due Diligence

• Environmental Due Diligence

• Financial Due Diligence

• Accounting Due Diligence

• Technological Due Diligence

• Intellectual Property Due Diligence

• Labor Due Diligence

• Real Estate Due Diligence

• Legal Due Diligence

• Valuation Due Diligence

Some platforms used for Due Diligence:

• http://www.tjsp.jus.br/ and other courts

• https://www.trf3.jus.br/ and other courts

• [link suspeito removido]

• http://receita.economia.gov.br/

• https://www.serasa.com.br/

• https://www.detran.sp.gov.br/ and other departments
   

9. Auditing and Monitoring

The last of the pillars of a Compliance program deals precisely with its maintenance. It must be continuous, always assessing whether it is being well executed and whether people are, in fact, committed to the norms, that is, whether each of the pillars is functioning as expected.

Monitoring will be done in a disciplined, planned, and documented manner, seeking simplicity, objectivity, and, preferably, using already available resources, indicators, and instruments. All identified problems must be prioritized and addressed (causes defined, countermeasures established, and monitoring of implementation and results obtained).

Senior Management will evaluate each monitoring, defining and/or complementing the countermeasures, in order to correct and/or improve the effectiveness of the program.

Eventually, or as needed, Senior Management, on its own initiative or at the request of the "Compliance Structure," may request an audit of the program, which will be carried out by a third party, internal or external to the Printer do Brasil Group. A report will then be produced detailing the methodology used, strengths or points of compliance, identified problems and their causes, and recommendations. After approval, the recommendations will be implemented.
 

6. COMPLEMENTARY DOCUMENTATION

• Code of Ethics, Compliance, and Internal Regulations – Printer do Brasil Group

• Law nº 12.846/2013

• Law nº 12.683/2012

• Decree 8.420/2015

• Law nº 6.404/1976

• BACEN Circular 3.681/2013

• BACEN Circular 3.865/2017
   

7. FINAL PROVISIONS

A Compliance Program does not guarantee that laws, norms, and procedures will be followed. This can only be achieved when each employee of the Printer do Brasil Group and companies linked to the Group complies with laws, norms, and procedures when performing their tasks, every day. For this reason, it is of fundamental importance that everyone understands the importance of this program and dedicates themselves to their work, performing it with ethical conduct and integrity.

In this way, we will maintain the Group's internal and external processes in the best possible way, following ethical standards with our partners and clients, always aiming to avoid risks and deliver the best of the Printer do Brasil Group.