S2B Energia

The ethical principles set out in the Code of Conduct provide a general framework for guiding the proper conduct and conduct of S2B.

S2B requires that all employees of the Company, including directors at all levels, adhere to these ethical principles in their work and are personally responsible for compliance with the Code of Conduct. This Code of Conduct encourages and requires all producers, suppliers and subcontractors, as well as business partners, to act responsibly in accordance with these ethical principles.

S2B is committed to operating in accordance with the principles of sustainable development and responsibility, and to understanding the long-term benefits for its own operations and stakeholders. As part of its responsible operations, S2B complies with applicable laws and regulations in all of its areas of operation.

2.1. Compliance with laws and regulations

In all its activities, S2B complies with applicable laws and regulations and monitors changes in legislation. All employees must comply with the laws and regulations applicable to S2B's operations and employee duties.

2.2. Fair competition

S2B supports fair competition and does not condone unfair practices in order to compete or win trades. S2B complies with applicable competition laws.

S2B employees may not engage in any illegal activity that restricts competition.

2.3. Anti-corruption activities and gifts

S2B does not condone corruption or bribery in any form, neither in the private nor in the public sector. S2B employees may not accept, directly or indirectly, gifts, rewards or other benefits or expressions of hospitality that may influence business decisions that promote or ensure business. Employees may give or receive personal gifts or expressions of hospitality of nominal value if such giving or acceptance of gifts and expressions of hospitality is permitted by law and regulation. For example, accepting travel tickets or accommodation costs from a third party is not acceptable.

2.4. Conflicts of interest

Employees are required to be loyal to S2B's business. Employees shall use their best endeavors to avoid situations that could create a conflict between the interests of an S2B employee or other stakeholders, family members or relatives of the employee, or companies controlled by them. Conflicts of interest can be very different and benefits vary from financial interests to other personal interests.

Examples of conflicts of interest include:

• Participation in the activities of companies competing with S2B in some form.
• Use of S2B business plans and other trade secrets for purposes other than S2B's promotion.
• Use of S2B's working time and resources for purposes other than promoting S2B's operations.

All forms of fraudulent activity are prohibited in S2B. Actions contrary to this principle will be evaluated internally and, if necessary, reported to the authorities.

S2B treats its employees, customers, suppliers and other stakeholders fairly and cooperates with them. S2B respects its contractual obligations and business arrangements.

S2B protects and handles confidential materials and information with care. S2B also carefully protects and handles confidential information received from its suppliers and stakeholders.

Employees may not disclose or use confidential information (such as trade secrets or confidential personal information) for their own benefit or for the benefit of anyone other than S2B.

S2B has put in place security and data protection guidelines, policies and controls that it is committed to following. S2B takes security and data protection seriously and takes steps to prevent them from being compromised.

If S2B employees have any questions regarding the interpretation of or compliance with this Code of Conduct, they should contact their supervisor. Additional instructions on compliance with the Code of Conduct may be provided in separate guidelines.

Violation of this Code of Ethics by an S2B employee may result in termination of employment or other appropriate sanction. The violation may be reported to the appropriate local authorities if S2B suspects that the employee's actions are also in violation of applicable law. S2B considers that the company and all its employees have an obligation to suspend or prevent activities that may harm S2B's customers or S2B's brands. Employees are therefore expected to report such actions.