Code of Policy and Ethical Conduct

First, we emphasize that, when we mention ABA Infra Group, we are mentioning the eight companies that are part of it: Eudmarco, FCA Log, Adonai, Adonai East, Toronto, Argemil, Atlantis, Concais, Contermas, and Pier Mauá.

The general rules presented in this Code must be followed by all Managing Officers, Employees, service providers, third parties, and by any person who may act on behalf of the ABA Infra Group and its subsidiaries, as they present elements considered essential that must be followed in the relationships established with the different audiences for the creation of successful partnerships.

The Code of Policy and Ethical Conduct considers the following audiences, although it is not limited to them: shareholders and investors, trade associations, trade unions, banks, customers, employees and other internal audiences, community and society, competitors, suppliers, Government, regulatory bodies and the press.

It is of paramount importance that everyone understands and abides by our Code, in addition to all company policies and standards, laws, and regulations where we operate.

If any employee has any doubts about the correct way to act or interpret any point of the Group Code, they should ask their Manager or the Human Resources Department for guidance.

If you are a service provider, you should contact your company representative or seek help from your contract manager.

ABA Infra Group counts on the collaboration of everyone so that this Code of Policy and Ethical Conduct is practiced daily.

Our mission is to undertake with excellence prioritizing ethics and safety and carrying out innovative operations.

Our destiny is to be among the main companies in the infrastructure and port logistics, fuel, and tourism sectors.

And we intend to follow this, following the values of making a difference, acting ethically, and building partnerships based on trust.

We at ABA Infra Group are based on the following principles:

– Achieve recognition from Customers, the State, and Society;

– Provide services with quality, punctuality, innovation, and safety;

– Keeping employees engaged and motivated;

– Guide management towards results, profitability, and competitiveness;

– Employ innovative solutions with appropriate technology;

– Practice integrated and participatory management;

– Act with ethics and citizen responsibility.

Respect, legality, impersonality, morality, and efficiency are basic principles and highly valued by ABA Infra Group. Any type of disrespect among its employees is not tolerated in any of the Group’s companies.

Employees must have behaviors that follow our basic principles with all the different audiences they deal with in their routine, inside or outside their work environment, ensuring the confidentiality of confidential and relevant information to which they may have access, not using it to obtain advantages for their own, even if they no longer belong to the staff of ABA Infra Group.

Everyone must comply with the rules, laws, regulations, and procedures, acting transparently and with integrity, regardless of the function held or the area of activity, and it is forbidden to use their function within the ABA Infra Group to influence decisions that favor interests (own or third parties) that cause damage to any of the Group’s businesses.

At ABA Infra Group, we value the diversity of employees to build a team. We always seek to build a work environment with a productive and creative focus, promoting equal opportunities, and meritocracy, and seeking to ensure that our employees act in a harmonious and respectful manner for all the characteristics and options of everyone, regardless of their differences.

In the same way that we expect respect from our employees, we seek to promote a respectful, welcoming, dialogue, and safe environment for our employees, with management practices aimed at preventing accidents, equipment, and safe installations in terminals and offices. We encourage everyone to adopt responsible behavior and we do not accept that the attitude of a person (whether employee, supplier, or customer) puts their own health and safety and that of other employees at risk.

The ABA Infra Group respects and promotes Human Rights and does not condone practices such as discrimination, sexual exploitation of children and adolescents, child labor, and degrading and forced or slave-like labor.

Healthy, fair, and sustainable relationships with customers and suppliers are valued by ABA Infra Group.

For this, it is essential that everyone complies with the legislation and that there is the fair treatment between our suppliers and their employees.

We encourage relationships with suppliers to be built ethically. Therefore, receiving gifts and presents is authorized by ABA Infra Group, provided that it does not occur to influence decisions or obtain undue advantages and that there is formal approval from our Board of Directors.

ABA Infra Group, as well as the companies that are part of it, have official channels on social networks, and only they can represent the companies.

Employees who choose to register on social networks must act on their own and with private resources. When publishing their opinions, they must act in a totally personal manner, without associating the companies, not disclosing information or any opinion that compromises the Group or the companies.

Social network profiles associated with ABA Infra Group or companies should only be used by the area responsible for authorizations and publications in the media.

ABA Infra Group guides its employees to promote its services in a clear and true way, not authorizing any form of favoring its stakeholders (whether they are suppliers, customers, or representatives of the public power) and repudiating any form of corrupt conduct, whether bribery, deviations, granting of undue advantages, among others.

In addition, we do not accept the alteration of our documents and records or the omission of the truth to obtain any type of privilege or advantage.

Anyone can report cases of violations of the Code of Policy and Ethical Conduct.

To do so, you must communicate the fact to your superior or forward the complaint to the Conduct and Ethics Committee. The information and/or complaints received will be treated confidentially and the identity of the informant will be preserved. Violation of any conduct or practice is subject to a penalty upon evaluation by the Conduct and Ethics Committee and will be subject to the application of current Brazilian laws.