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Compliance

Commitment to integrity, everywhere

Aurea, committed to integrity, ethics and respect for laws and regulations, has established this Compliance Policy to guide its operations and relations with all stakeholders. This policy reflects our commitment to a safe working environment, ethical business practices, and a positive impact on the community and the environment.

Scope

This policy applies to all employees, including senior management, employees, suppliers, partners and any third party related to Aurea's operations.

Human Rights and the Environment

Workers’ health

Aurea ensures the well-being, physical and mental health of its employees, complying with all applicable Regulatory Standards (NRs) and providing the necessary Personal Protective Equipment (PPE). We maintain an active Internal Accident Prevention Committee (CIPA) to promote a safe working environment.

Compliance with Labor Laws

We respect current labor laws, rejecting child labor and ensuring decent working conditions. We fight any form of forced or compulsory labor.

Tolerance, Inclusion and Women’s Rights

Aurea promotes an inclusive work environment, making no distinction on the basis of color, race, religion or sexual orientation. We firmly defend women’s rights, repudiating any kind of violence or discrimination and making ourselves available to all female employeeswho need help, as well as removing employees who violate these laws.

Relationship with the Environment and Society

We are committed to ecological practices, aiming to obtain ISO 14001 certification, reflecting our commitment to environmental sustainability and social contribution.

Anti-corruption

Fighting Corruption and Fraud

Fighting corruption and fraud (Camargo Correa)

Aurea adopts an uncompromising stance against corruption and fraud, following Law 12.846/2013 and similar legislation. We define corruption as any act harmful to the public or private administration, including bribery and obtaining undue advantages.

Important Concepts (kroton)
  • Corruption: Acts harmful to the public or private administration, at any level: municipal, federal or state.
  • Injurious Act: Unlawful actions that go against the law and cause damage.
  • Thing of Value: Includes money, gifts, entertainment, travel, job offers, sponsorships and other economic advantages.
  • Bribery: A proposal to exchange something of value in favor of some favorable decision for some company or participant

Anti-trust

We maintain fair competition by providing customized solutions without transferring sensitive information between competing clients. We practice fair prices, avoiding agreements that are detrimental to free competition.

Relationship with our Competitors

We practice a fair and reasonable pricing policy, ensuring the competitiveness and health of the market without getting involved in price-fixing agreements. This principle reaffirms our dedication to free competition and business ethics.

Relations with distributors and representatives

We provide our distributors and representatives with exclusive rights to our products and services, cultivating long-lasting and reliable partnerships and promoting a fair and transparent commercial environment.

Servicing companies that compete with each other

Our commitment to fairness leads us to offer the same unit values to all competitors, ensuring transparency and fairness in the treatment of companies that compete with each other.

Non-Disclosure Agreement (NDA)

Our Non-Disclosure Agreements are strictly in line with applicable laws and regulations, protecting our clients’ confidential information, as well as details of our projects, which are treated as Aurea’s intellectual property.

Exclusivity policies

We have implemented clear exclusivity policies, reaffirming our commitment to confidentiality and specialized attention to the needs of our clients and partners, reinforcing our commitment to excellence and integrity in all our actions.

Antitrust Policy

General guidelines

Aurea is dedicated to full compliance with antitrust legislation, vehemently opposing the formation of monopolies, cartels and any practices that could jeopardize free competition. These principles are fundamental for all employees, according to our Code of Ethics & Conduct, and include:

  • Promoting fair competition, avoiding participation in activities that harm consumers, the public administration or society.
  • Refraining from any relationship with competitors that could lead to price adjustments, production limitations, division of markets or sales territories, or any attitude that undermines healthy competition.
  • Avoid agreements with competitors that restrict competition or the freedom to do business with suppliers, or that involve the presentation of fictitious offers.
  • Do not acquire or use confidential information from competitors inappropriately.
Specific Guidelines

Some special guidelines should be followed when faced with situations that could lead to
bring competitive risks, namely:

  • Be careful at meetings with trade associations and events where competitors are present, ensuring that discussions remain in line with antitrust practices.
  • In meetings with competitors, review the invitation, agenda and minutes to ensure that the principles of this policy are respected.
  • Abandon discussions or meetings that deviate into topics harmful to competition or that practice inappropriate conduct, reporting this to Aurea’s compliance department.
  • In the event of receiving unsolicited documents or information from competitors, notify AUREA compliance immediately.
  • Immediately interrupt any dialog with competitors about prices, markets or clients, reporting such occurrences to AUREA’s compliance department.
  • If there is a possibility that your business activities may constitute a dominant position or impose restrictions on competition, consult a specialist in order to understand the impact of your actions on the market and ensure compliance with antitrust laws.
  • Consult experts whenever there are doubts about the dominant position in the market or about impositions that restrict competition, to ensure compliance with antitrust laws.
  • Report suspicions of practices or procedures that violate free competition, guaranteeing the integrity of our operations.
  • Avoid any form of communication with competitors, unless there is a legitimate business justification and such interaction does not violate antitrust laws.
  • It is forbidden to discuss or exchange information with competitors about sales strategies, prices, marketing, production capacity, new products, research and development (R&D).
  • Ensure that a reliable third party is present at meetings with competitors, such as a member of a trade association or a technical expert from a university or regulatory body with a reliable reputation.
  • Never take part in agreements that seek to fix prices, distribute clients or territories.
  • Don’t use inside information acquired from competitors to gain undue advantage in the market. It is imperative that any competitor information used in our strategy is in the public domain.
  • Do not impose exclusive purchasing conditions or supply obligations that include guarantees of loyalty discounts, excessive price charges or discriminatory practices between our customers and partners, unless there are clear and legitimate justifications for such actions. Special attention should be paid if the company has a dominant position in the market, such as a share of 20% or more.
  • Commit never to participate in fraudulent tenders or engage in any activity that could compromise the principles of fair competition.
Policy with Competing Clients

Given AUREA’s expertise in the radioprotection sector, it is common for us to serve clients who are direct competitors. This condition demands maximum transparency and a strict confidentiality policy from us to assure customers that their critical information and technologies will not be exposed or used against them. Like this:

  • We clearly communicate our policy of absolute confidentiality, reinforcing our commitment to privacy and information security.
  • We evaluate and respect clients’ demands for separate service teams or any other specific needs relating to competition.
  • In the case of requests for exclusive service, we carry out a careful analysis to determine the viability of this exclusivity, detailing the terms of this relationship, including duration and market coverage.

This approach reaffirms Aurea’s commitment to business ethics, fair competition and unconditional respect for customers’ rights and the current regulatory environment.