CODE OF ETHICS AND CONDUCT

This Code aims to establish a set of principles, values ??and rules of action for all Cosmopak managers and employees, in terms of professional ethics, taking into account the criminal rules relating to corruption and related infractions and risks of exposure of the company to these crimes, with a view to generating sustainable value in the economy and society through science and technology.
This Code of Ethics and Conduct is thus established in good faith, and reciprocally accepted, which is governed by current legislation and the following clauses:

1. SCOPE

The provisions of Cosmopak's Code of Ethics and Conduct are applicable to all employees as well as to all those who act on behalf of and in the service of Cosmopak, regardless of employment status.

2. OBJECT

2.1. This Code of Ethics and Conduct defines a set of principles, values ??and rules of action for all managers and workers in matters of professional ethics, taking into account criminal norms relating to corruption and infractions related crimes and the risks of exposing the entity to these crimes.
2.2. For the purposes of this Code, the following terms and expressions will have the meaning indicated below:
- Code of Conduct: set of principles that govern Cosmopak's activity and rules of an ethical and deontological nature to be observed by members of the company's bodies and by all its employees, among themselves and with third parties;
- Collaborators: workers, managers and office holders of corporate bodies, regardless of the nature of their legal-employment relationship;
- Corruption and Related Offenses: crimes of corruption, improper receiving and offering of advantages, embezzlement, economic participation in business, concussion, abuse of power, malfeasance, influence peddling, laundering or fraud in obtaining or diverting subsidy, subsidy or credit , provided for in the Penal Code.

3. PRINCIPLES AND OBJECTIVES

3.1 Cosmopak uses the following principles as a reference and inspiration to accelerate innovation and entrepreneurship:

• Rigor;
• Integrity;
• Transparency;
• Confidence;
• Collaboration;
• Proximity;
• Creativity.

3.2 Cosmopak absolutely repudiates the practice of any conduct that, directly or indirectly, may be related to acts of corruption, in all its forms, including extortion and bribery, basing its actions on principles of responsibility, demand, respect and compliance with the law.
3.3 Within this framework, it approved an anti-corruption policy, an essential tool to prevent both Cosmopak and the entities with which it interacts from engaging in practices that are contrary to the law, ethical principles and conduct.
3.4 The objectives of this policy, which are contained in this Code, are, among others, the following:
3.4.1 Make known to employees, customers, public entities, suppliers and, in general, the entire community, the set of principles, values ??and rules by which they should guide their actions, taking taking into account the criminal rules relating to corruption, related offenses and risks of exposing the company to these crimes;
3.4.2 Foster growing relationships of trust between employees, customers and suppliers and strengthen Cosmopak's elements of cohesion, cooperation and ethics;
3.4.3 Clarify with employees the rules of conduct that they must observe, through their decisions, behaviors and attitudes, in a continuous and scrupulous manner, both in their reciprocal relationships and in the relationships that on behalf of Cosmopak, establish with third parties;
3.4.4 Ensure to partners, customers, suppliers and others that Cosmopak fulfills the duties of supervising and controlling its activity by establishing appropriate measures to prevent and reduce the risk of committing corruption crimes and that performs surveillance and control duties with a view to avoiding misconduct that implies criminal liability for society;
3.4.5 Identify the sanctions that can be applied in case of non-compliance with the rules of conduct.

4. RESPONSIBLE FOR ANTI-CORRUPTION COMPLIANCE FUNCTION

4.1 By decision of Cosmopak's Board of Directors, a person responsible for the Anti-Corruption Compliance Function will be appointed, who will be responsible for the implementation, operation and compliance with the anti-corruption management system.
4.2 The person responsible for the Anti-Corruption Compliance Function will monitor this Code, interpret it and clarify doubts, as well as take appropriate measures to resolve and mitigate actions or omissions that constitute or may constitute corruption.
4.3 Any employee may contact the person responsible for the anti-corruption compliance function, via email, contatoanticorrupcao@cosmopak.pt to request clarifications regarding a specific situation or information on any subject related to this Code or the anti-corruption management system. 4.4 To submit a complaint of corruption or any other situation that may present an irregularity or violation of the rules contained in this Code, the reporting channel available on the Cosmopak website must be used. 4.5 The contact details of the person responsible for the anti-corruption management system will be disclosed through the internal and external communication channels available at the company, namely through the official Cosmopak website.

5. CONFLICTS OF INTEREST AND PERSONAL RELATIONSHIPS

5.1 Cosmopak employees have the duty to perform their duties independently, avoiding placing the company in situations that could be considered a threat to its impartiality and suitability.
5.2 The adoption of, among others, the following measures constitutes preventive measures for the fulfillment of the duty of independence by employees:
5.2.1 Do not intervene in decision-making processes that directly or indirectly involve organizations with which they collaborate or have collaborated;
5.2.2 Do not intervene in decision-making processes that involve, directly or indirectly, people with whom they are or have been linked by ties of kinship or friendship;
5.2.3 Do not participate or perform functions in organizations in which the activity to be carried out may conflict with the functions performed at Cosmopak.
5.3 Whenever there are family or emotional ties between two people who work at Cosmopak, it must be communicated to the person responsible for the Anti-Corruption Compliance Function through the means provided for this purpose (Annex I – Draft Conflict of Interest Declaration), so that it can determine the possible need to change the assignment of projects to the people involved in order to avoid possible conflicts of interest.

6. OFFERS

6.1 The offering of gifts, entertainment, travel and hospitality must be preceded by a rigorous suitability analysis, so that they are not perceived as indirect means of corruption, and must always comply with the following rules:
6.1.1 Request approval of the offer to Cosmopak's Board of Directors with justification for the same;
6.1.2 Reasoned approval of the offer by the Board.
6.2 The direct or indirect acceptance of any type of gifts and of any value intended to influence any employee in non-compliance with their obligations and the direct or indirect favoring of the person or entity that grants them in the context of contracting goods or services.
6.3 In other cases, that is, when the offer does not imply the breach of obligations or the direct or indirect favor of the person or entity that grants them, the rules that must regulate the acceptance of gifts are as follows :
6.3.1 Goods, services or any advantages (including Christmas gifts) with an individual or combined value exceeding R$ 250.00 or equivalent to another currency cannot be accepted annually for personal benefit , suppliers or physical or legal entity that has had or intends to have commercial relations with Cosmopak;
6.3.2 The gift must be voluntary, cannot have been previously requested and cannot generate expectations of reciprocity;
6.3.3 The purpose of the gift must fit within traditional festive (for example: Christmas, Easter) or personal congratulations, such as birthdays, constituting a small attention or courtesy and must be appropriate and proportionate to the circumstances, admitted by usage and custom;
6.3.4 Gifts must be received at the workplace and not at the employee's private home or that of family members or loved ones;
6.3.5 Whenever a gift, good or service is received with an estimated unit value exceeding R$150.00, it must be communicated to the person responsible for the Anti-Corruption Compliance Function;
6.3.6 The previous restriction does not apply to offers of goods or services, such as travel, meals, accommodation or shows, that are attributed by third parties to the recipients of this Code due to the exercise of their position, within the scope of its representation functions and in the interests of Cosmopak, as long as previously validated by Cosmopak Management;
6.3.7 The acceptance of gifts from individuals or legal entities is prohibited when they are in the process of selecting and contracting the supply of goods and services to Cosmopak, especially when the recipient participates in the decision-making process;
6.3.8 The offering or receipt, under any circumstances and regardless of the value, of cash, bank checks, gift certificates and others regardless of the amount is prohibited;
6.3.9 The giving of gifts to public servants and authorities is prohibited;
6.3.10 Gifts received in an institutional context that makes their refusal impossible and that do not meet the acceptance requirements must be accepted institutionally, but refused in a personal capacity, in which case they must revert to the property of the Cosmopak that will give it the appropriate purpose, notably distributing through social institutions.
6.4 All other forms of offers must be communicated to the person responsible for the Compliance Function.
6.5 Invitations to events or other activities organized by suppliers or others are considered to have been made to Cosmopak, and must therefore be communicated to the person responsible for the Anti-Corruption Compliance Function (conformidadeanticorrupcao@cosmopak.pt), being responsible to the Board the fate to be given to them.
6.6 The following are excluded from the rules set out above:
- Gifts received and invitations made by partners or by a company controlled by Cosmopak;
- Meals eaten in the context of a current professional relationship, whenever considered reasonable in the context in which they take place.

7. FRAUD, CORRUPTION AND/OR OTHER IRREGULARITIES

7.1 Whenever Cosmopak employees become aware of or have reasonable suspicions of the occurrence of corruption activities or related infractions, as well as other irregularities, they must report them via email to canaldenuncias@cosmopak .br or even through the reporting channel available on the Cosmopak website.
7.2 The complaint referred to in the caput, when communicated via email, must be accompanied by the model contained in ANNEX II to this Code – Draft Communication of a specific situation of non-compliance or potential fraud , duly completed, containing all the elements and information that are considered useful for evaluating the situation and determining the facts.
7.3 In accordance with the provisions of Law no. 93/2021, of December 20, the confidentiality of the identity or anonymity of the complainants and the confidentiality of third parties mentioned in the complaint are guaranteed, and access to unauthorized persons is prevented.
7.4 The reporting of situations of fraud, corruption and/or other irregularities cannot serve as a basis for the initiation of any disciplinary, civil or criminal procedure, nor for the adoption of discriminatory practices that are prohibited under the terms of labor legislation.
7.5 Failure to comply with the rules contained in this Code by any worker or manager will be considered a serious infraction, which, depending on the degree of guilt of the offender and the severity of the infraction , may lead to the opening of disciplinary proceedings and the application of one of the following disciplinary sanctions:
a) Unregistered reprimand;
b) Recorded reprimand;
c) Financial penalty;
d) Loss of vacation days;
e) Suspension from work with loss of salary and seniority;
f) Dismissal for just cause;
7.5.1 Failure to comply with the rules contained in this Code may also lead to administrative or civil liability for offenders, and also, depending on the severity of the infraction and the culpability of the offender, give rise to criminal sanctions;
7.5.2 The crimes of corruption and related offenses covered by this Code are punishable, depending on the legal framework, with fines and imprisonment of up to 12 years
. 7.6 The Board of Directors is responsible for knowing and deciding on situations involving violations of the Code of Ethics and Conduct by employees.
7.6.1 The Board may also, while safeguarding confidentiality and respecting the rights and guarantees of employees, request the collaboration of other internal Cosmopak departments, whenever justified.

8. HARASSMENT AND NON-DISCRIMINATION

8.1 Situations that may be considered to cause a danger of harassment and discrimination at work must be reported in writing, via email addressed to canaldenuncias@cosmopak.pt or, even, through the communication channel. reports available on the Cosmopak website.
8.2 The complaint must be supported by detailed information regarding facts and means of evidence, and the victim, place and date of the occurrence(s) must be identified.
> 8.3 The confidentiality of the procedure is ensured regarding the reporting person, the person reported, the content of the complaint, the means of testimonial, documentary or expert evidence, covering the steps taken or to be taken, so that all The people involved must act with the necessary secrecy to protect the dignity and privacy of each one, and no information must be disclosed, seeking to guarantee the exemption, equality and transparency of the entire procedure for all people involved.< br > 8.4 The reporting person and the witnesses indicated by him/her cannot be subject to disciplinary sanctions based on statements or facts contained in the process triggered by harassment, intimidation or discrimination at work.
8.5 Disciplinary proceedings will be initiated whenever there is sufficient evidence of acts capable of constituting harassment and/or discrimination at work.

9. THE IMPORTANCE OF COMMUNICATION

9.1 Cosmopak promotes a healthy communication environment that encourages the formulation of questions about ethics and compliance and that provides the possibility of identifying and reporting possible violations of ethics.
9.2 In this sense, the act of communicating knowledge or well-founded suspicion of behavior incompatible with the Code constitutes a duty for each of its recipients.

10. WHO AND HOW TO CONTACT

10.1 In order to facilitate compliance with this Code, Cosmopak has duly publicized channels, through which doubts can be submitted about the interpretation of the anti-corruption policy and the law related to it, as well as for the communication of any event capable of framing a situation of corruption.
10.2 Requests for clarification will be managed and resolved through a transparent and objective procedure, safeguarding confidentiality, the identity of the people and the conduct subject to participation.
10.3 Communications must be written and sent to the following email address: contatoanticorrupcao@cosmopak.pt
10.4 If there is a complaint to be reported about any element of Cosmopak, the person who intends to make the complaint must use the reporting channel on the Cosmopak website.
10.5 The aforementioned Cosmopak communication channel ensures the strictest confidentiality of the information conveyed, and the rights of access and rectification to data are also guaranteed, in compliance with legal regulations.

11. INQUIRIES / REPORT

11.1 Once the communications identified above have been received, the head of the Compliance Function, together with other elements, notably from the Legal area, proceeds to investigate the facts considered pertinent.
11.2 For the purposes of investigating the facts, the following steps may be taken, among others:
a) Hearing of the agent who identified the possible irregularity;
b) Listening to the reported agent, who is unable to obtain information about the identity of the reporting agent, and also listens to other entities involved;
c) Carrying out other measures that are considered appropriate;
d) Provision of information considered appropriate to the agent who reported the situation, to the reported agent and to other entities involved.
11.3 Cooperation in investigations is the duty of the recipients of this Code, including towards external entities that support the steps taken.
11.4 The fundamental rights of the accused, notably the defense of their good name, privacy and the right to file a complaint for slanderous reporting, cannot be harmed in any case.
11.5 For each infraction, a report is drawn up identifying the rules violated, the sanction applied, as well as the measures adopted or to be adopted, particularly within the scope of the internal control system.

12. NON-RETALIATION

Cosmopak will not tolerate any form of reprisal against anyone who, in good faith, has reported knowledge or well-founded suspicion of behavior incompatible with the principles contained in this Code.

13. CONSEQUENCES IN CASE OF VIOLATION OF THE CODE OR ITS ABUSIVE USE

13.1 Recipients of the Code are bound by the rules contained therein.
13.2 Violation or non-compliance with the general rules of conduct reflected in this Code, in addition to not being tolerable, constitutes a disciplinary infraction punishable under the terms of the disciplinary regulations in force at Cosmopak and the CLT, without prejudice to civil and administrative liability criminal or other that may occur.
13.3 If it is detected that an act or omission inconsistent with the provisions of this Code has been committed by a business partner or supplier, Cosmopak will make every effort to assess the extent to which preventive actions have been implemented to avoid that such behavior may occur again in the future, with the possible repercussion of this circumstance on commercial relations or partnerships with them being assessed in this context.

14. FINAL PROVISIONS

14.1. Interpretation:
The interpretation of the provisions of this Code will be in accordance with the legal and regulatory standards in force, and they can never be interpreted in a more restrictive sense than legally provided.
14.2 Changes and Revision:
14.2.1 This Code may only be changed by decision of the Board of Directors.
14.2.2 Cosmopak's Code of Ethics and Conduct must be reviewed every two years, and may also be reviewed at an earlier time if deemed necessary.
14.3 Term:
14.3.1 Cosmopak's Code of Ethics and Conduct comes into force on the day following its approval by the Board.
14.3.2 Except when a different date is stipulated, changes to this Code come into force on the fifth business day following their approval.
14.4 Advertising:
The Code of Ethics and Conduct is disclosed internally and published on the Cosmopak website.

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