Informed Consent to the Code of Ethics and Conduct

CEO\'s Message

Dear Orange Soul Colleagues,

In keeping with our value of Integrity, which states that \\\"Ethical conduct, character, and honesty are non-negotiable, and we guide our practices in compliance with the laws, rules, policies, and guidelines, where it is important not only to be right, but also to appear right,\\\" this Code of Ethics and Conduct was prepared to guide our employees and partners in the conduct of our business, while also demonstrating to society our ethical and transparent way of working.

We sought to bring our way of being into this manual, showing that respect goes far beyond simply treating others well; it means providing an environment in which everyone is welcomed in the best possible way in their individuality.

Reading this manual is of the utmost importance so that the conduct of our business is aligned with our philosophy of integrity. It is a place to clarify questions and will serve as the guide for us to maintain our highest level of compliance across all interfaces of our company.

If you have any questions about any point in our Code of Ethics and Conduct, the People Management team or your immediate leader will be ready to assist you.

Warm regards,

Vinícius Lamego
CEO and Director of Operations

Our Mission

To develop and provide our customers with complete solutions, with the highest level of quality, ensuring safety and excellence in the use of our equipment, tools, and services.

Introduction

Our Code of Ethics and Conduct (the \"Code\") is the guiding foundation for the attitudes expected of everyone who works or operates on behalf of Ritz.

Each professional\'s commitment and responsibility to uphold and maintain the highest ethical standards in the performance of their activities is the fundamental premise of this guide.

Our professional practice is grounded in compliance and adherence to our six values.

Our Values

The values of Respect, Integrity, Continuous Improvement, Courage, Genuine Active Care, and Passion are the foundation of our organizational structure and the standards of conduct to be followed at Ritz.

Who It Applies To

All employees who work at the company, regardless of position or function, including its administrators.

All business partners, including interns, apprentices, temporary workers, third parties, fixed or occasional service providers, suppliers, sub-suppliers, representatives, distributors, customers, and all other audiences that have a relationship with the company or are acting in the name of or on behalf of Ritz.

Safety

The lives of the people who work with us and who use our products in the course of their work are our most valuable asset.

We make safety, physical health, and mental health our priority by:

• Complying with safety laws, regulations, and guidelines,
• Pursuing the goal of zero harm every day,
• Promoting a culture of genuine active care in safety internally,
• Investing resources to make our environment even healthier and safer,
• Creating management programs to improve the effectiveness of our procedures,
• Investing in the qualification of our leadership and our employees.

General Guidelines

At Ritz, we uphold the basic premise of the Universal Declaration of Human Rights that “all human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act toward one another in a spirit of brotherhood.”

Accordingly, we reinforce that within the company every human being is entitled to enjoy the rights and freedoms set forth in this Declaration, without distinction of any kind, whether of color, sex, language, religion, political or other opinion, national or social origin, wealth, birth, or any other condition.

Every human being has the right to life, liberty, and personal security.

No employee or business partner shall be held in slavery or servitude, nor shall anyone be subjected to torture or to cruel, inhuman, or degrading treatment or punishment.

Everyone at Ritz is equal before the law and is entitled without any discrimination to equal protection of the law. Everyone is entitled to equal protection against any discrimination in violation of this Declaration and against any incitement to such discrimination.

No one shall be subjected to interference with their privacy, family, home, or correspondence, nor to attacks upon their honor and reputation.

We declare that at Ritz every human being has the right to freedom of thought, conscience, and religion; the right to freedom of opinion and expression; the right to work; the right to free choice of employment; the right to just and favorable conditions of work; and the right to rest and leisure, including reasonable limitation of working hours and periodic paid holidays.

In the exercise of their rights and freedoms, every human being shall be subject only to such limitations as are determined by law solely for the purpose of securing due recognition and respect for the rights and freedoms of others and of meeting the just requirements of morality, public order, and the general welfare in a democratic society.

We are also committed to the rights of children and adolescents, and we reaffirm that “It is the duty of the family, society, and the State to ensure to children and adolescents, with absolute priority, the rights to life, health, food, education, leisure, professional training, culture, dignity, respect, freedom, and family and community life, as well as to protect them from all forms of negligence, discrimination, exploitation, violence, cruelty, and oppression.”

Workplace Relationships

Between Employees and the Company

The general guidelines of our Code must be observed by all employees in their relationships while serving and representing Ritz.

Our interactions must be guided by our six values, especially through deep respect for diversity, differences, individuality, plurality, and each individual\'s preferences.

There is no room at Ritz for discrimination, intolerance, violence, hate speech, bullying, or any kind of harassment, whether inside the work environment or outside it while serving the company, such as on business trips, at external meetings, or when participating in business-related events.

Ritz repudiates any hate speech, intolerance, disrespect, violence, harassment, or threats made by any of its employees or business partners, whether directly or indirectly through different means of communication, including messaging apps, emails, social media, and others.

The company will never condone attitudes that violate its general guidelines and values.

Use of Legal Drugs, Illegal Drugs, and Weapons

It is not permitted to work under the influence of alcohol or drugs, nor to carry, consume, acquire, distribute, manufacture, deliver, or sell illegal and/or intoxicating substances on company premises or while serving the company.

The use of prescribed medication that may compromise a professional\'s safety and integrity and/or impair their judgment must be reported to the company so it can be assessed by the occupational medicine area.

It is not permitted to carry, handle, or use weapons of any kind on company premises. The use of any company tool, equipment, or utensil for purposes other than its intended purpose, in acts of violence, is also prohibited.

Conflicts of Interest

Conflicts of interest are professional situations in which our private interests interfere with our actions, decisions, and ability to exercise impartial judgment, potentially conflicting with the interests of the company.

Some examples of conflicts of interest are:

• favoring relatives and friends in professional transactions,
• using confidential and privileged information for personal benefit,
• obtaining private advantages, privileges, and favors in the exercise of professional duties,
• having a family member and/or someone from your personal relationship as a direct subordinate on your team,
• performing another professional activity, second job, or income-generating activity during working hours at Ritz,
• maintaining personal relationships with or having relatives in competing companies, suppliers, etc.

It is important that, in the face of the situations above and others not limited to them, we use our best judgment not only to avoid engaging in any practice that constitutes a conflict of interest, but also to avoid any suspicion of practices that conflict with Ritz\'s interests.

If you are in doubt about whether a practice is or may be a conflict of interest, the People Management area or any member of the Executive Board may support you.

With Our Customers and the Market

We are driven by our mission to develop and provide our customers with complete solutions, with the highest level of quality, ensuring safety and excellence in the use of our equipment, tools, and services.

We reinforce that the quality standard reflected in our brand is sustained by our pursuit of continuous improvement in the quality management system, ensuring compliance and excellence in customer service through effective processes and qualified, engaged professionals.

Products manufactured by Ritz must comply with all laws and regulations for use in their respective markets.

We negotiate with integrity and fairness, and we compete in the market based on the merits and differentiators of the products we manufacture and market and the services we provide.

We deal honestly with our customers, suppliers, distributors, representatives, employees, business partners, competitors, and other stakeholders.

Our team must never distort facts, omit information, misuse privileged information, or use manipulation to gain an advantage when conducting business on behalf of Ritz.

The selection of our business partners is based on technical criteria related to quality, reliability, safety, service level, and compliance with our control and conduct standards.

We encourage our suppliers and service providers to comply with legal, labor, environmental, and safety standards, with emphasis on combating unlawful or criminal acts (corruption, influence peddling, fraud, money laundering, smuggling, among others), and we do not tolerate any form of degrading labor (slave, involuntary, forced, or child labor), in order to maintain alignment with Ritz\'s Code of Ethics and Conduct.

Business Courtesies

We must not accept giveaways, gifts, or courtesies from customers, suppliers, and business partners that represent significant commercial value, violate Ritz\'s values, or may cause embarrassment to the company or the professional involved.

Gifts offered with values above R$ 200.00 (two hundred reais) must be politely declined or submitted to the Executive Board for evaluation and determination of the appropriate handling.

Likewise, we will not offer giveaways, gifts, or courtesies of significant, luxurious, or extravagant value that may influence the business relationships we establish, affecting business decisions or judgment.

Anti-Corruption

We respect laws that prohibit bribery and other acts of corruption. Ritz has zero tolerance for public and commercial corruption. We will not tolerate the offering, authorization, or receipt of bribes, kickbacks, facilitation payments, or any other improper payment intended to obtain or retain business for the company.

We will not accept, give, or promise anything that could be interpreted as an intention to improperly influence a commercial or governmental transaction. The use of third parties to do what Ritz itself is prohibited from doing is also forbidden.

Violations of anti-corruption laws may result in criminal prosecution as well as significant financial penalties.

External Communication

Employees and business partners are not authorized to speak on behalf of Ritz without authorization from the Executive Board. Communications with the press and other external media will only be carried out by qualified people appointed for this role.

With Ritz Itself

Financial and Results Information

We are committed to integrity and accuracy in the analysis, determination, recording, and timely disclosure of information about our business. At Ritz, we will never sacrifice integrity for profit.

All of our records and accounting books must reflect assets, liabilities, revenues, costs, and expenses in accordance with accounting principles accepted under local law.

We are cooperative and transparent during any type of audit, inspection, inquiry, or investigation carried out internally or externally, and our employees must never improperly interfere with or influence these processes.

Fraud

We repudiate any fraudulent, deceptive, or bad-faith attitude intended to harm or deceive someone or obtain an illegal or unfair advantage. Examples of fraud include document, brand, and product forgery; illegal entry of foreign products; use of false identity; sending false payment slips; theft of card data; and similar acts.

Protection of Company Data and Assets

We have a duty to protect Ritz\'s assets, property, and intellectual property. We must use company resources with care, responsibility, awareness, consistency, and professionalism, and protect them from theft, robbery, or damage caused by improper use.

Industrial and commercial secrets, business plans, pricing models, innovation projects, technical drawings, confidential financial information, customer lists, material and supplier lists, as well as other important information, must be protected with rigor and care.

We must ensure that the information to which we have access remains restricted in use and shielded from improper appropriation. Protecting our confidential information is essential to our competitive advantage.

All intellectual content we produce within the company is its property, and its external disclosure requires
prior approval.

Any activity or work carried out on behalf of the company in an external environment and that is not part of the routine duties of the position, such as classes, lectures, brand case presentations, or the presentation of materials containing company information and know-how, must respect the confidentiality limits of Ritz\'s information and be submitted for prior approval by the Executive Board before being carried out.

Even after your employment or partnership relationship with Ritz ends, you remain obligated not to use, disclose, or provide confidential information or the company\'s intellectual property.

Protection of Data and Information

All Ritz employees are required to comply with the General Data Protection Law (LGPD) and with the company\'s Data Protection Policy.
Ritz is committed to the careful handling of personally identifiable information and to protecting such information so that it is not lost, misused, accessed without authorization, disclosed, altered, or destroyed.

Employees who have access to personal data may use it only for a specific professional purpose, protecting its confidentiality.

Communication and Information Systems

The company provides several tools to facilitate the work of its employees, such as access to email, computers, network folders, smartphones, mobile phones, printers, telephones, messaging applications, videoconferencing tools, and other communication channels. These tools are the property of Ritz and must be used in a manner that respects our values and our company\'s guidelines.

Never use these tools improperly or without the necessary authorization, do not provide their resources to third parties, and never use the company\'s communication channels for inappropriate, offensive, defamatory, obscene, or harassing activities.

Email and the other communication channels are for professional use, and personal use must be limited.

The company reserves the right to monitor and control the use of its resources and communication channels whenever necessary.

Social Media

The recording of images of company premises without authorization from the Executive Board is not permitted, nor is the taking and disclosure of images of other employees and business partners without their knowledge and consent.

Conduct on social media must follow principles of responsibility and professionalism, in order to respect and preserve the reputation of the organization and those who work in it, and in compliance with the guidelines set out in this Code.

With the Environment and the Community

All our activities are carried out in compliance with environmental legislation and standards in order to promote the preservation of nature and biodiversity.

We are committed to the sustainable development of our business, acting responsibly, optimizing the use of natural resources, and minimizing environmental impacts.

This commitment is reinforced by our environmental operating license, our AVCB (Fire Department Inspection Certificate), and the implementation of high environmental impact programs such as:

• Selective collection with proper waste disposal;
• Self-monitoring of liquid, atmospheric, and noise emissions;
• Management of chemical products with risk monitoring and adoption of preventive measures; and
• Awareness actions that promote the preservation of natural resources.

We recognize our role in supporting the transition to a more sustainable world by integrating environmental, social, and corporate governance aspects into our products and into how we operate in the market.

We seek to engage with the community where we are located in order to promote citizenship initiatives that positively impact the lives of society and families, whether through philanthropy, donations, or social projects.

Employees are not permitted to make donations or support social actions on behalf of the company without proper authorization from the Executive Board, reinforcing that our involvement in this type of community support will be voluntary, apolitical, and unrelated to private interests.

We respect our employees\' right to participate in political, union, and party activities; however, such involvement is personal, outside working hours, carried out with their own resources, and without any connection to Ritz.

Compliance with the Code

This guide sets out the guidelines and ethical standard of conduct to be followed by everyone who operates at Ritz, while serving and representing it. If any situation you experience raises questions, demonstrates a potential conflict, or creates suspicion of an ethics violation and is not covered in this document, seek clarification and additional guidance from a member of the Executive Board or the People Management area.

Failure to comply with this Code of Ethics and Conduct, applicable laws, or any Ritz policies and guidelines may result in potentially serious consequences, including loss of business, restrictions on conducting business (such as suspension from or exclusion from bidding processes), civil and/or criminal liability, monetary fines, damage to the company\'s reputation, and, in extreme cases, may even affect the continuity of our business.

Any employee who violates the principles of this Code of Ethics and Conduct is subject to the disciplinary measures below, which will be applied in accordance with local laws and the severity of the violation:

• Training,
• Warning,
• Suspension,
• Dismissal,
• Other legal measures.

In the case of business partners, failure to comply with this Code may result in termination of contracts, partnerships, and service agreements.

How to Raise Concerns and Report Potential Violations?

Ritz promotes a culture of transparency, openness, and dialogue. Our environment fosters engagement, respect, and diversity, while also demanding the highest level of rectitude, compliance, and ethics.

If you are faced with a suspicious situation, have any doubt about an attitude or procedure, have witnessed a violation of the Code, or wish to make a report, it is important that you feel encouraged to report the issue through one of our help channels.

Reported situations will be received seriously and professionally and assessed with responsibility and neutrality, regardless of the channel chosen to submit the report.

Channels for Reporting Violations of the Code

The available options for reporting a situation related to ethics and conduct are:

• Your Immediate Supervisor;
• Any Member of the Leadership Team;
• Any Member of the People Management Area;
• Any Member of the Executive Board;
• Our Ritz Ethics Channel, administered by our partner \"Ouvidor Digital\".

How to Use the Ritz Ethics Channel?

Ritz has partnered with the company Ouvidor Digital to provide all employees and business partners with access to the Ritz Ethics Channel, an external, impartial, neutral, and specialized platform that operates 24 hours a day, 7 days a week, to receive reports of concerns, suspicions, and complaints of violations of our Code of Ethics and Conduct.

You may use this Ethics Channel and submit your report through the following means:

• Web App / Website (also available in Brazilian Sign Language) which may be accessed from any device (smartphone, tablet, computer, etc.) at https://canal.ouvidordigital.com.br/ritz
• WhatsApp through the number (31) 98947-7889 (not available for calls or video calls, messages only)
• Telephone Call through the number 0800 591 2070.

Regardless of the channel used, you will receive a protocol number to track your report. You may choose to remain anonymous or make your identity available, which will help facilitate the investigation process.

Ethics reports will be forwarded to the Executive Board, preserving the identity of the reporting person when the complaint is anonymous, and an investigation process will be initiated to verify the reports, analyze information, and conduct interviews with the parties involved and witnesses, if applicable.

After the full analysis of the facts, an action plan and the appropriate handling of the case will be defined, and feedback will be provided to the person who reported the situation. Even in situations where no violation of any kind is proven, feedback will still be provided to the reporting party.

Retaliation Is Prohibited

Employees and business partners must feel safe to report any type of situation, concern, or suspicion of a violation of the Code of Ethics and Conduct, without fear of reprisals or retaliation.

Our non-retaliation stance is fully aligned with our values and is a Ritz commitment to you. In return, we trust that any employee or partner faced with a concerning situation will report in good faith a circumstance that deserves investigation and help us keep our environment free from ethical and conduct deviations.

Statement of Commitment

You are receiving the Ritz Code of Ethics and Conduct, and a complete reading of it is essential.

This guide contains the rules of ethical conduct to be observed by you and the values that must be considered in all your relationships while serving or representing the company.

By signing this statement, you express your commitment to follow all the guidelines established in the Code and acknowledge that your conduct must be guided by the highest ethical and professional standards set forth in this document.

You also declare that you are aware of your responsibility to respect it, value it, and ensure its compliance.