IDEOLOGY:

– BUSINESS: extrusion and drawing of aluminum tubes and manufacturing of derived components. – MISSION: generate value solutions in tubes, components and services through the “eyes” of customers; – VISION: expand market share and product mix with increased performance; – VALUES: Valuing People, Social Responsibility, Respect for the Environment, Care for Heritage, Awareness, Commitment, Eyes on the Customer, Search for Excellence.

PDCA – AROTUBI CONTROL PLAN:

– SUSTAINABILITY: For Arotubi, managing consciously and objectively means turning our attention to environmental, human, social and governance issues. We work to ensure socioeconomic stability and sustainability, through good practices aligned with the global scenario; – PEOPLE: Providing the professional and personal development and appreciation of each employee through good people management practices is what makes Arotubi a company with a high sense of belonging, aligned with Ideology, Mission, Vision and Values; – QUALITY: More than just customers, we have business partners. For Arotubi, in building a long-term relationship, the requirement for quality of products, processes and delivery is paramount; – COSTS: Promoting the optimization of available resources through sustainable actions, with qualified management, capable of acting critically and strategically, enables Arotubi to participate in extremely competitive markets; – SAFETY: employees are one of Arotubi’s assets. Our sense of responsibility begins with care for safety and health. Dedication to promoting an increasingly safe and healthy work environment is one of the purposes in which we evolve daily.

GOAL:

Establish the conduct that guides Arotubi’s business and relationships, through its corporate governance and that of its employees, in an ethical, transparent, professional and mutually respectful manner. This document does not cover all possible situations of ethical conflicts that may arise, however, it defines the basic principles that should guide our conduct in any situation. The Conduct Manual applies to everyone who has a relationship with Arotubi, regardless of their hierarchical position or area of activity.

GENERAL CONSIDERATIONS:

The adoption of ethical and behavioral principles by Arotubi reflects the type of organization we are part of. All employees must act in accordance with the Conduct Manual, policies, internal procedures and current legislation. Any violation of these rules will be considered a serious offense, enabling the application of legal sanctions and disciplinary measures. Whenever you are faced with what you think is a situation that has ethical or behavioral implications, before taking action, ask yourself the following questions: 1 – is it in accordance with the company’s legislation and standards? 2 – is it ethical? 3 – will it bring positive exposure to me or Arotubi? If the answer is no to one or more of these questions, DON’T DO IT! Omission is also considered an unethical attitude, subject to punishment. If you have questions or identify any situation that violates this Code and/or current legislation, contact your manager or, if you prefer, report the case on Você tem Voz. Information provided through this channel will always be treated with secrecy and confidentiality.

RELATIONSHIPS AND BEHAVIORS IN THE WORKPLACE

Our commitment is to promote an ethical, safe and healthy work environment for everyone. To achieve this, some attitudes towards co-workers are essential, such as respect, politeness and cooperation. To maintain an environment of transparency, mutual trust and responsibility at all levels, we adopt the following practices: CHILD LABOR – at Arotubi we encourage the employability of young people, through Law 10,097/200, hiring and developing them for internal positions or in preparation for the external market. SLAVE LABOR – forced or involuntary labor will not be tolerated. This includes prison, bonded, forced labor and/or other forms of labor against someone’s will or choice.

HARASSMENT, PREJUDICE, ABUSE OR DISCRIMINATION

At Arotubi we recognize and respect differences. We do not allow or tolerate any type of harassment, discrimination, prejudice or humiliating treatment between employees, service providers, customers or suppliers. We consider the following to be inadmissible:

• Preferences or favors arising from personal affinity, social or hierarchical position or length of service;
• Attitudes or words that could be characterized as moral or sexual harassment;
• Intimidation, humiliation, threats or abusive attitudes, whether through gestures, words or behavior against the moral and physical integrity of any person;
• Discrimination based on race, color, ethnicity, sex, age, marital status, religion, sexual orientation, special needs, appearance, origin, political conviction or any other form of prejudice.

INTEREST CONFLICTS

The use of an employee’s position or influence to promote private interests may generate conflict with Arotubi, due to inappropriate conduct. Cannot happen:

• Any type of favoritism, material or financial advantages that an employee receives from one of our suppliers or service providers;
• Improper use of privileged information obtained within Arotubi;
• Parallel activities that are carried out by the employee during working hours, within the premises or using Arotubi resources;
• Arotubi does not allow the sale of any products or services and consultancies on its premises, nor does such activities be carried out using company resources, by any person, regardless of relationship;
• Family relationship between employee and supplier or service provider that compromises impartiality in business;
• Carrying out, by the employee, other professional activities that may interfere with Arotubi’s business, even if carried out outside working hours;
• Any unjustifiable favoritism, directed by the employee to a specific client, to the detriment of other clients or the interests of Arotubi itself, especially when this professional maintains any social or emotional relationship with the favored person;
• That employees use their positions to request personal favors, obtain any type of gift or gift from any person, supplier or service provider;
• Receiving inappropriate gifts, giveaways or entertainment opportunities that could harm Arotubi’s business decisions. When it is not possible to reject these, they must be sent to HR for a draw among all company employees. It is permitted to receive diaries, pens and logo-marked accessories for use in internal work activities.

ANTI-BRIBERY

• The practice of bribery and corruption will not be tolerated in any way. All employees must refuse any pecuniary advantage, favors and benefits, in any form, in favor of themselves or third parties, which may represent an improper relationship or financial harm or damage to the company’s image;
• Employees must not, under any circumstances, practice or allow to be practiced conduct that constitutes an attempt or practice of bribery or corruption, such as: accepting, obtaining, financing, paying, promising, sponsoring or authorizing, directly or indirectly, any benefit, pecuniary or otherwise, in any form, in favor of oneself or anyone else.

INFORMATION SECURITY

ELECTRONIC ACCESS – the employee is solely responsible for their passwords (network, electronic media and systems) for access, which are personal and non-transferable. Never disclose them to your co-workers, this way, you guarantee the security of Arotubi’s information and data. The use of IT resources must strictly follow the guidelines of the Information Security policy. Illegal copies of software, use of pirated products and access to websites unrelated to work activities are not permitted. USE OF IMAGES – to guarantee the safety of people and preserve Arotubi’s industrial processes, the use of personal cell phones in the company’s manufacturing environment, whether by employees, third parties and/or service providers, is expressly prohibited, when unauthorized. The use of the corporate telephone must be restricted to work matters. This feature can be used for non-work related matters quickly and occasionally. Photos and filming of people or processes without due authorization from the area manager, as well as their publication on any network, are also prohibited. The use of cell phones is permitted at Arotubi’s festive events, as long as they follow the rules above.

LGPD

The LGPD applies to all companies in all sectors of the economy that process personal data, regardless of the medium (physical or digital), the country of their headquarters or the country where the data is located. LGPD is the acronym for General Data Protection Law, sanctioned in August 2018, which establishes rules for the collection, storage, processing and sharing of personal data, imposing more protection and penalties for non-compliance. SENSITIVE DATA – if information allows you to identify, directly or indirectly, an individual who is alive, then it is considered personal data: name, ID, CPF, gender, date and place of birth, telephone number, home address, location via GPS, portrait in photography, health records, bank card, income, payment history, consumption habits, leisure preferences; IP address (Internet Protocol) and cookies, among others. Our duty is to protect this data.

HIRING AND REFERENCES

RESUME REGISTRATIONS – in compliance with the LGPD – General Data Protection Law, CVs will only be accepted via registration on the Arotubi website, on the Work with Us page. For referral cases, simply use the field available on the form; RELATIONSHIP – at Arotubi we recognize that referring people is a demonstration of pride in belonging and we encourage the hiring of family members, as we understand that we are in an environment that generates trust and employability. So that Arotubi’s internal controls are not weakened, family members are not allowed to work at levels of direct or indirect subordination, in the same sector, shift or work area, thus preserving morals and ethics in internal relationships. When situations of this nature occur, the impacted employee must inform their immediate manager and the Human Resources area.

WORK PLACE – HEALTH AND SAFETY AT WORK

Arotubi considers it essential to have a safe and healthy working environment for the performance of its employees’ activities and is concerned about their balance with the environment. We constantly seek to eliminate occupational risks, minimize the environmental impacts of work activities, respecting current legislation and adopting the following actions: PGR (RISK MANAGEMENT PROGRAM); PCMSO (MEDICAL CONTROL AND OCCUPATIONAL HEALTH PROGRAM); Occupational Medicine – medical care for employees; Labor Gymnastics – objective of improving conditioning in work activities and contributing to the employee’s quality of life. SAFETY RULES – follow all safety rules and in any situation of doubt or possible risk, contact the area expert and the SESMT team. Avoid accidents! PPE – the use of PPE is mandatory in areas that pose risks, identified by SESMT, by all people who access them. For administrative employees, third parties, service providers and visitors who need to travel in the production areas, it is mandatory to use safety shoes, glasses and hearing protectors (plugs) for the time they are present in these areas. Be aware that it is your INTEGRITY that is at stake! CIRCULATION IN ENVIRONMENTS – pay attention to the traffic of vehicles and forklifts in the different areas at Arotubi. Don’t be distracted by cell phone use. ACTIVITIES WITH THIRD PARTIES – any and all activities to be carried out by third parties on Arotubi’s premises must be approved by SESMT.

WORK PLACE – ENVIRONMENTAL MANAGEMENT

For Arotubi, taking care of the environment is linked to its Mission, Vision and Values. This is evidenced through the processes applied daily, practices adopted in measuring environmental risks, recycling, waste separation and intelligent collection, preserving the health of people and the environment. SUSTAINABILITY – conscious and objective management means turning our attention to environmental, human, social and governance issues. We work to ensure socio-economic stability and sustainability, through good practices aligned with the global scenario.

CUSTOMER RELATIONSHIP

OUR CUSTOMERS – the customer is the focus of our business and the key to our success. Therefore, our commitment is to build solid and reliable relationships, improve service, and guarantee the quality and delivery time of our products. ASSURED QUALITY – by guaranteeing the quality of our products, we enable satisfaction and sustainability of the relationship with our customers. It is the responsibility of everyone at Arotubi to follow all policies and procedures related to quality throughout the value chain and constantly promote the necessary improvements in a systematic and continuous manner. In cases of quality deviations where the customer or the company may be impacted, the employee must immediately notify the person responsible for the Quality area to analyze the risk. COSTS – it is through looking at costs that we seek the competitiveness of our products without compromising the financial health of Arotubi and we also guarantee the employability of our employees.

SOCIAL RESPONSABILITY

Arotubi’s commitment and dedication are not limited to its customers. We have internal policies aimed at the economic, social and environmental development of those who, directly or indirectly, are part of our reality. As one of the bases of our values is respect and appreciation for people, Arotubi values the well-being of its employees. We carry out internal actions and events, providing support to employees with specific needs and professional development through training. In addition to working with the internal public, we work with institutions that have fundraising projects for Children and Adolescents, Sports, Elderly and Culture funds. Among the entities served are Hospital Pequeno Príncipe, Complexo de Saúde Pequeno Cotolengo, Projeto Meninos de 4 Pinheiros and almost ten years ago, we walked together to the Curitiba Festival, one of the largest cultural festivals in Latin America. Such initiatives make Arotubi increasingly stronger through a transparent and ethical relationship with all its employees, suppliers, customers and other business partners. Main social projects:

• Instituto Incanto;
• Hospital Pequeno Príncipe;
• Meninos de 4 Pinheiros;
• Instituto Compartilhar;
• Pequeno Cotolengo;
• Festival de Curitiba;
• Paróquia Sagrada Família;
• Associação de Moradores Anjos do Bem da CIC.

COMMUNICATION WITH THE EMPLOYEE

ALIGNMENTS WITH COLLABORATORS – our objective is to have information flowing at all levels, in a transparent and direct way. For more interactive communication, we practice actions with employees: – Coffee with Management: employees from different areas, monthly; – Alignment Meeting: with all employees, every six months; – Indicators Meeting: with the entire management team, monthly. MEANS OF COMMUNICATION AT AROTUBI – our goal is to have a transparent and easy to communicate work environment. The means by which employees can communicate, in addition to their leaders/managers, are:

• Communication Team – employees from different areas able to receive information, suggestions or complaints and deal with them with HR;
• Você tem Voz – channel available through suggestion boxes at strategic points in the company and link (https://forms.gle/HTTWTbLX2HjqcGYQ9), guaranteeing the confidentiality of the situation and the employee;
• LGPD email – lgpd@arotubi.com.br;
• Whatsapp HR & DP;
• In person at HR.

COLLABORATOR REPORTING CHANNEL

HOW TO MAKE A REPORT? Option I: YOU HAVE A VOICE! Write the complaint on paper and deposit it in the ballot boxes located in the factories or access the link and write your complaint; Option II: contact HR Management directly; Option III: find Management. MONITORING – Management and the Management Team are responsible for disseminating, monitoring and ensuring compliance with the Conduct Manual. When situations or suspicions of violation arise, communication must be made promptly to HR and complaints must contain as much information and evidence as possible, in order to enable the investigation of the facts. The right to report anonymously is guaranteed and, in case of identification, the secrecy of the whistleblower is guaranteed.

IF YOU HAVE ANY QUESTIONS ABOUT THIS CONDUCT MANUAL, PLEASE CONTACT HR:

WHATSAPP COMMUNICATION – (41) 99171-7691

Email: comunicacao@arotubi.com.br

At AROTUBI, privacy and security are priorities and we are committed to the transparency of the processing of personal data of our users/customers. Therefore, this Privacy Policy establishes how the collection, use and transfer of information from customers or other people who access or use our website is done.

By using our services, you understand that we will collect and use your personal information in the ways described in this Policy, under the Data Protection rules (LGPD, Federal Law 13,709/2018), the consumerist provisions of Federal Law 8078/1990 and the other rules of the applicable Brazilian legal system.

Thus, Arotubi Indústria e Componentes and Arotubi Sistemas para Gás, hereinafter referred to simply as “AROTUBI”, enrolled with the CNPJ/MF under No. 02.223.370/0001-13 and 07.857.242/0001-45, as Data Controller, is bound by the provisions of this Privacy Policy.

1. What data do we collect about you and for what purpose?

Our website collects and uses some personal data from you, in order to enable the provision of services and improve the experience of use.

1.1. Personal data provided by the holder

• In the contact form are requests, name, email and telephone for proper response. The data informed is kept on record.

1.2. Personal data collected automatically

• No data is collected automatically.

2. How do we collect your data?

In this sense, the collection of your personal data occurs as follows:

• Contact only

2.1. Consent

It is from your consent that we process your personal data. Consent is the free, informed and unambiguous expression by which you authorize Arotubi to process your data.

Thus, in accordance with the General Data Protection Law, your data will only be collected, processed and stored with prior and express consent.

Your consent will be obtained specifically for each purpose described above, showing AROTUBI’s commitment to transparency and good faith towards its users/customers, following the relevant legislative regulations.

By using AROTUBI’s services and providing your personal data, you are aware of and consent to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

At any time and at no cost, you may revoke your consent.

It is important to highlight that the revocation of consent to the processing of data may imply the impossibility of the adequate performance of some functionality of the site that depends on the operation. Such consequences will be informed in advance.

3. What are your rights?

AROTUBI guarantees its users/customers their rights of holder provided for in article 18 of the General Data Protection Law. In this way, you can, free of charge and at any time:

• Confirm the existence of data processing, in a simplified way or in a clear and complete format.
• Access your data, being able to request it in a legible copy in printed form or by electronic, secure and suitable means.
• Correct your data, when requesting the editing, correction or updating of these.
• Limit your data when unnecessary, excessive or treated in non-compliance with legislation through anonymization, blocking or deletion.
• Request the portability of your data, through a report of the registration data that AROTUBI handles about you.
• Delete your processed data from your consent, except in cases provided for by law.
• Revoke your consent, disallowing the processing of your data.
• Be informed about the possibility of not providing your consent and about the consequences of denial.

4. How can you exercise your rights as a holder?

To exercise your holder rights, you must contact AROTUBI through the email shared at the end of this page.

In order to ensure your correct identification as the holder of the personal data subject of the request, it is possible that we request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by AROTUBI will be used and stored for the time necessary to provide the service or for the purposes listed in this Privacy Policy to be achieved, considering the rights of data subjects and controllers.

In general, your data will be kept for as long as the contractual relationship between you and AROTUBI lasts. After the period of storage of personal data, they will be deleted from our databases or anonymized, except for the cases legally provided for in article 16 General Data Protection Law, namely:

I – compliance with legal or regulatory obligation by the controller;

II – study by research body, guaranteed, whenever possible, the anonymization of personal data;

III – transfer to a third party, provided that the data processing requirements set forth in this Law are respected;

or

IV – exclusive use of the controller, its access by a third party is prohibited, and provided that the data is anonymized.

That is, personal information about you that is essential for compliance with legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be maintained, despite the exclusion of other data.

The storage of data collected by AROTUBI reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions capable of guaranteeing the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and control of access to stored information.

6. What do we do to keep your data safe?

To keep your personal information safe, we use physical, electronic and managerial tools aimed at protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the processing and the risks that possible violations would generate for the rights and freedoms of the data subject collected and processed.

Among the measures we have adopted, we highlight the following:

• Only authorized persons have access to your personal data;
• Access to your personal data is done only after the commitment of confidentiality;
• Your personal data is stored in a safe and suitable environment.

AROTUBI undertakes to adopt the best practices to avoid security incidents. However, it should be noted that no website is entirely safe and risk-free. It is possible that, despite all our security protocols, third party fault issues occur exclusively, such as hacker cyberattacks, or also as a result of the negligence or recklessness of the user/client himself.

In the event of security incidents that may generate a relevant risk or damage for you or any of our users/customers, we will communicate to those affected and the National Data Protection Authority about what happened, in accordance with the provisions of the General Data Protection Law.

7. With whom can your data be shared?

In order to preserve your privacy, AROTUBI will not share your personal data with any unauthorized third party.

Your data may be shared with our business partners described on the website as partners. In addition, there are also other events in which your data may be shared, which are:

I – Legal determination, request, requisition or court order, with competent judicial, administrative or governmental authorities;

II – Case of corporate transactions, such as merger, acquisition and incorporation, automatically;

III – Protection of the rights of (simplified corporate name) in any type of conflict, including those of judicial content.

7.1. International data transfer

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries. In these conditions, in any case, your personal data will be subject to the General Data Protection Law and other Brazilian data protection laws. In this sense, AROTUBI undertakes to always adopt efficient cybersecurity and data protection standards, in the best efforts to ensure and comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will take place according to the purposes described in this instrument.

8. Cookies or browsing data

AROTUBI makes use of Cookies, which are text files sent by the platform to your computer and stored on it, which contain information related to the navigation of the site. In short, Cookies are used to improve the user experience.

By accessing our website and consenting to the use of Cookies, you acknowledge and agree to the use of a navigation data collection system with the use of Cookies on your device.

You can, at any time and at no cost, change permissions, block or refuse Cookies. However, the revocation of the consent of certain Cookies may prevent the correct functioning of some features of the platform.

To manage the cookies of your browser, just do it directly in the browser settings, in the Cookies management area.

9. Changes to this Privacy Policy

The current version of the Privacy Policy was last formulated and updated at: 12/22/2022.

We reserve the right to modify this Privacy Policy at any time, mainly due to the adequacy of any changes made on our website or in legislative scope. We recommend that you review it frequently.

Any changes will take effect from their publication on our website and we will always notify you of the changes that have occurred.

By using our services and providing your personal data after such modifications, you consent to them.

10. Responsibility

AROTUBI provides for the responsibility of agents acting in the data processing processes, in accordance with articles 42 to 45 of the General Data Protection Law.

We are committed to keeping this Privacy Policy up to date, observing its provisions and ensuring its compliance.

In addition, we are also committed to seeking technical and organizational conditions that are safely able to protect the entire data processing process.

If the National Data Protection Authority requires the adoption of measures in relation to the processing of data carried out by AROTUBI, we undertake to follow them.

10.1 Disclaimer

As mentioned in Topic 6, although we adopt high security standards in order to avoid incidents, there is no entirely risk-free web page. In this sense, AROTUBI is not responsible for:

I – Any consequences arising from the negligence, recklessness or malpractice of users in relation to their individual data. We guarantee and are responsible only for the security of the data processing processes and the fulfillment of the purposes described in this instrument. We emphasize that the responsibility for the confidentiality of access data lies with the user;

II – Malicious actions of third parties, such as hacker attacks, unless proven guilty or deliberate conduct of AROTUBI. We emphasize that in the event of security incidents that may generate a risk or damage relevant to you or any of our users/customers, we will communicate to those affected and the National Data Protection Authority about what happened and we will comply with the necessary measures;

III – Untruthfulness of the information entered by the user/client in the records necessary for the use of AROTUBI’s services; any consequences arising from false information or inserted in bad faith are entirely the responsibility of the user/client.

11. Data Protection Officer.

AROTUBI provides the following means for you to contact us to exercise your rights as a holder: email.

If you have questions about this Privacy Policy or about the personal data we process, you can contact our Personal Data Protection Officer through the following channels:

DPO:

Thaisa Demarchi