Marluvas Fair Competition Policy

PURPOSE OF THIS POLICY

This Policy aims to guide and require Marluvas Equipamentos Profissionais' internal and external collaborators to comply with Brazilian antitrust laws, especially Law No. 12,529/2011, in order to ensure the protection of free competition in their activities and prevent risks of infringements related to inappropriate conduct in relationships with competitors, while performing their duties and activities on behalf of the company.

This Policy is part of the corporate integrity actions, driven by Marluvas' ESG Committee, and complements the relevant provisions of its codes of conduct, and should be interpreted in accordance with related policies disclosed by Marluvas.

Marluvas and its business areas may adopt more rigorous procedures than those provided in this Policy, when deemed appropriate based on risk assessment, making them known to collaborators for full compliance with said procedures.

Furthermore, this Policy takes into account best corporate governance practices regarding antitrust measures.

APPLICABILITY

This Policy applies to all collaborators who work exclusively on behalf of the company's business or on behalf of clients, individually or in conjunction with partners, referred to as “Internal Collaborators,” as well as partners, suppliers, service providers, subcontractors, and consultants, referred to as “External Collaborators.”

This Policy is available at: www.marluvas.com.br/governança

DEFINITIONS

The terms used in this Policy should be considered according to the following definitions:

Administrators: statutory and non-statutory directors and board members, where applicable.

Abuse of economic power by dominant position: a dominant position is considered whenever a company is able to unilaterally or coordinately alter market conditions, or when it controls 20% or more of the relevant market. It is legitimate and healthy for any company to grow and achieve a large market share and, therefore, a dominant position. However, a company with a dominant position cannot abuse that position by engaging in practices that may discriminate against consumers, clients, and other market participants.

Cartel: an explicit or implicit agreement between competing companies to, primarily, fix prices or production quotas, divide customers and markets, or, through coordinated action among participants, restrict, impede, or distort competition and increase product prices, obtaining greater profits at the expense of consumer and customer welfare.

Competitors: companies operating in the same market segment as Marluvas.

Internal Collaborators: Marluvas administrators and employees who work exclusively on behalf of the company's business or on behalf of clients, individually or in conjunction with duly contracted partners.

External Collaborators: Marluvas partners, suppliers, service providers, subcontractors, and consultants, including sales representatives, customs brokers, lawyers, distributors, resellers, and brokers.

Competitively Sensitive Information: information that is not publicly known and that allows firm conclusions about competitors' market behavior, such as, for example, revenue volume and trends, turnover and market share, profits and losses, pricing strategies, among others.

Third Parties: any individual or legal entity contracted by a company in the holding or by Marluvas, and who has or may have any type of contact with competitors on behalf of Marluvas. Thus, for the purposes of this Policy, third parties include: sales representatives, consultants, lawyers, distributors, resellers, and brokers, as also indicated in the definition of External Collaborators.

GENERAL REQUIREMENTS

The objective of antitrust laws is to preserve a free economy, ensuring competition in the market according to fair and independent criteria. Effective competition only works if each company determines its own strategies and policies, such as pricing policy, without any involvement, discussion, or exchange of information with competitors.

Therefore, as a general rule, any discussion or agreement with competitors, in any form, with the objective or effect of impeding, restricting, or distorting competition, will violate free competition laws and this Policy.

All practices that violate free competition are prohibited and must be combated, including price fixing or sales conditions between competitors, cartels, abuse of market or economic power, predatory pricing and dumping, market division or agreements with competitors, offering illicit advantages, or any other anticompetitive practice.

Violation of antitrust laws can result in serious consequences for both Marluvas and its collaborators. In Brazil, the fine for legal entities can vary between 1% and 20% of the company's annual gross revenue, in addition to other penalties, including criminal penalties for the individuals involved, such as, for example, leniency agreements.

PRINCIPLES AND GUIDELINES

Below are the concepts and guidelines that must be followed for compliance with this Policy, based on Law No. 12,529/2011, in addition to prohibited practices and conduct according to applicable law.

1. Competitively Sensitive Information

The exchange of competitively sensitive information, referred to as “Competitively Sensitive Information,” is prohibited within the scope of commercial practices and in relationships with Marluvas' competitors, especially those related to:

• Issues related to prices, such as sales conditions, including cost elements, minimum prices, price lists, margins, calculation methods, discounts, especially if segmented by customers and suppliers, plans for price increases or reductions;
• Sales and/or service volumes;
• Market division, whether geographical or by customer;
• Information about strategic plans;
• Matters related to the composition of prices and commercial conditions of specific suppliers or customers;
• Amounts paid as commissions;
• Methods of service commercialization;
• Accounting and management results not disclosed to the market;
• Risk assessment models;
• Plans for new business development or marketing strategies;
• Any other confidential information whose disclosure harms free competition among companies in the market.

Never discuss with competitors about participation or non-participation in specific tenders or projects, or about the predetermination of who will be the "winner" of a tender or project, making agreements on the price of "winners" or "losers."

Remember: the exchange of Competitively Sensitive Information can constitute the formation of a cartel, even if you receive such information only passively.

For a cartel to be formed, it is not necessary for the agreement to be implemented or to generate effective results. Therefore, do not exchange information, not even confidentially, such as "it will only be between you and me," or in a joking manner, as what is said verbally can later become a written document by the competitor.

2. Commercial Practices

Practices that harm the exercise of free competition and are prohibited by law are not permitted in the commercial activities of Marluvas and its suppliers, such as:

• Abuse of market power or economic power;
• Unjustified price discrimination among customers;
• Dumping or predatory pricing, below the average variable cost, aiming to eliminate competitors;
• Market foreclosure for other competitors;
• Unjustified refusal to enter into commercial contracts.

3. Relationship with Competitors

In Marluvas' relationship with its competitors, in any environment, even within industry associations, the exchange of Competitively Sensitive Information that harms free competition is prohibited, in order to favor Marluvas itself or a competitor, or to harm it.

In this regard, the following practices are prohibited:

• Entering into agreements, even verbal ones and even if indicative or suggestive, with competitors, with or without the interference of an industry association, regarding price leveling, costs, operating methods or sales, standardized contractual clauses, remuneration, market division, by region or by customer, among others, as well as regarding participation, conditions and combination of results in public tenders;
• Discussion of matters involving Competitively Sensitive Information with competitors;
• Providing, without due caution, Competitively Sensitive Information to the association, even for market diagnosis or response to authorities. In this case, the confidentiality of the information must be ensured, and it must be delivered to association personnel not linked to competitors;
• Adopting initiatives aimed at price fixing, including when related to the payment of commissions to agents operating in other links of the business chain; boycotting suppliers or customers; or excluding a competitor, supplier or customer.

4. Corporate Operations

In corporate operations, such as mergers, acquisitions, incorporations, joint ventures, among others, it is prohibited to provide, receive or exchange Competitively Sensitive Information with administrators, collaborators or persons acting on behalf of the involved company, before definitive approval by CADE.

Information necessary for the business feasibility analysis is an exception, which must always be supported by a contractual instrument that ensures the confidentiality and non-disclosure of the information.

5. Information Obtained from Non-Competitors

Obtaining market information about competitors is not a problem when this information is obtained from a client or a third party who is not the competitor.

If this information is stored internally with an official character, there must be a record specifying the source.

6. Private and Accidental Contacts with Competitors

You may have contact with friends or relatives who work for competitors, or you may come into contact with competitors by accident. However, do not talk about sensitive issues that could affect or interfere with Marluvas' business or that of competitors.

7. Recruitment of Employees from Competitors

When conducting job interviews with people currently working for competitors, observe the following guidelines:

• Ask questions regarding the candidate's experience, their ability to perform the intended activity, their remuneration scheme, their current job, and the reasons for leaving, for example;
• Do not ask questions regarding the competing company or Competitively Sensitive Information that is not necessary for the recruitment process.

8. Confidentiality

The disclosure of Marluvas' strategic information to any third parties is not permitted.

In any necessary exchange of confidential information, provided it is in accordance with current legislation and without violating this Policy, the signing of a Confidentiality Agreement is mandatory.

9. Means of Recording the Exchange of Competitively Sensitive Information

For purposes of violating this Policy and competition law, the exchange of Competitively Sensitive Information is independent of the communication medium used, including informal means of communication, such as internal meeting minutes, emails, telephone, mobile text messages, notes, among others.

10. Participation in Industry Associations

Participation in industry associations, especially commercial associations, must comply with current legislation, and the association and its members must be required to:

• Pre-approve, by the Compliance officer, the names of the individuals who will participate on behalf of Marluvas and ensure that these individuals are aware of the guidelines contained in this Policy. The Compliance officer must maintain a list of the names of participants in associations in which Marluvas participates;
• Hold meetings with predefined agendas made available to all participants, and the Marluvas participant may and should refrain from commenting on or considering any competitively sensitive topic;
• Record all meetings in minutes;
• Promptly interrupt and exclude matters involving Competitively Sensitive Information from any members;
• Treat as confidential any Competitively Sensitive Information eventually requested by the association for common interest projects, including for market diagnosis or response to authorities, and, whenever possible, made available in an aggregated or consolidated form, without identifying each participating company.

If real or potential indications of any illegal act or act not in conformity with the principles and guidelines of this Policy, or with Marluvas' ethical and integrity values, committed by any collaborator, are identified, the Compliance officer must be informed immediately. This can be done by reporting via email to the leader of Marluvas' ESG Committee: emersonleao@marluvas.com.br

11. How to react if Competitively Sensitive Information is exchanged?

If Competitively Sensitive Information is discussed by a representative of a competitor, always follow this rule:

1. Ask the competitor to stop the discussion and inform participants that you are not authorized to discuss this type of matter;
2. Leave the environment, so that those present notice your departure and the reason;
3. Immediately report the incident to your direct superior, who must report it to the head of the ESG Committee.

Many jurisdictions, such as Brazil, offer immunity or reduced penalties for the first company to report antitrust violations to the antitrust authority, through Leniency Agreements. The report must be made quickly to ensure the company's priority.

For the company to evaluate whether it will make the report to take advantage of the Leniency Agreement, it is crucial that you immediately report the incident to the Compliance officer or the ESG Committee.

Remember: passive participation is not allowed and can also constitute violations of competition law.

This Policy must be disclosed to all Marluvas administrators and collaborators and will be valid from the date of its publication.

It will be available electronically at: www.marluvas.com.br/governança