Code of Ethics and Conduct

Polo Surgical is committed to the highest ethical standards, basing its business activities and relations on the principle of transparency and integrity.

1. FUNDAMENTAL PRINCIPLES

Legality – The activities routinely performed by all partners and employees must always be in accordance with the legal provisions of our area of operation, ensuring that our business follows high ethical standards, within strict compliance with applicable laws.

Transparency – We are committed to providing accurate and correct information about the product or service to be provided, respecting the relationship between supplier and consumer, always considering health care, improving the quality of life and protecting the economic interests of our end client.

Search for Excellence – Polo Surgical is in constant search for continuous improvement and excellence through the permanent monitoring of performance indicators, the evolution of its processes, training and qualification of its employees.

Commitment to Quality – All of us who work at Polo Surgical have a commitment to life, which is also expressed through the quality of our products and services. In all our activities we must ensure compliance with Quality policies and procedures, guaranteeing our customers, patients and regulatory agents the high standard of safety and effectiveness of our brand.

Accounting – Our accounting books are detailed to reflect the reality of each payment and expense. All entries will be accurate, honest and made so that the company will comply with legal and regulatory obligations. No employee or director will sign and distribute, nor allow others to sign and distribute on behalf of the company, any documents or statements in which the declarant suspects them to be false.

2. WORKING ENVIRONMENT AND LABOR RELATIONS

Discrimination and Harassment – It is the duty of all of us to take care that there is no form of discrimination or harassment within the work environment or in working relationships with each other, whether based on race, age, color, religion, or any other that may exist. In this way, all Polo Surgical employees are assured of dignified and respectful treatment in the work environment.

Use of alcohol, illegal drugs and possession of weapons – Polo Surgical does not admit that its employees are under the effect of alcoholic beverages, drugs or substances that may alter or cause misbehaviour during the working day. In business trips, events and meals, there must be common sense in the consumption of alcohol. In any case the consumption of illegal drugs is strictly prohibited.

It is forbidden to smoke in work areas and/or environments equipped with air conditioning, including corridors, in addition to places not allowed for security reasons.

Weapons of no kind are allowed on the Polo Surgical premises.

Company assets – Company properties constitute the company’s assets, and we must use them only in the development of the business activities for which they are intended, avoiding the unmotivated deterioration of them.

3. INSIDE INFORMATION

Confidential information – The confidential information to which we have access by virtue of our employment or commercial relationship with the company may not, under any circumstances, be disclosed to third parties without prior written authorization, nor may it be used for purposes of personal benefit.

It is also our commitment not to disclose information that is not in the public domain and that may be useful and give undue advantage to the competition or that would harm Polo Surgical and its clients.

Protection of confidential information – Polo Surgical employees are responsible for maintaining the confidentiality of medical information of patients to which they have access in the processes of authorization or care of surgical procedures.

Proper use of social media – Polo Surgical does not allow its employees to share or disseminate images or videos related to their professional activities on its social networks. Documents and digital files owned by the company, including corporate e-mails, must be protected and their content used only in favor of the company’s business and interests, or when required by the competent authority.

Use of passwords – Polo Surgical recognizes the importance of providing employees with passwords for personal and exclusive use to ensure the protection of corporate data and, consequently, the continuity of business. For this reason, it is strictly forbidden to share access passwords, and employees are informed of this prohibition through training conducted by HR when integrating new employees.

4. INTERACTIONS WITH THIRD PARTIES

Negotiations – Negotiations between Polo Surgical and clients, suppliers and any others must respect the legal precepts, being forbidden to obtain undue advantages through manipulation, omission, inappropriate use of privileged information, incorrect disclosure of facts, or any other type of negotiation or inappropriate practice.

Contracts – Our relations with service providers or third parties will be, whenever possible, formalized in writing. Such contracts will guarantee the compliance with the applicable legislation and the best practices of the law in force, also assuring the right to perform independent audits and to contract rescission in case the other contracting party does not comply with the pertinent legal regulation.

Payments – We at Polo Surgical will not make any undue payments to customers, suppliers, service providers, individuals or entities, especially those who act in public administration, nor will we request or accept any undue payments from suppliers, customers or any individual/entity wishing to do business with the company.

Competitions – Our competitive practices will be legal, ethical and fair, and will comply with all applicable antitrust and other laws and regulations. We do not allow adjustments with competitors to divide markets, to combine prices or to adopt other arrangements that prevent a fair competition.

Bidding – Our contacts with public employees in the context of bidding must be made in accordance with the rules of the bidding body and other applicable rules. Informal contacts with public employees involved in bids are not allowed.

In discussions for contract negotiation or extension, we cannot aim at obtaining undue advantage from the employee or public agency.

Individual Advantages – When acting on behalf of the company our actions must prioritize Polo Surgical’s interests in relation to our personal interests and under no circumstances may we engage in activities that may compete with Polo Surgical’s activities, refraining from obtaining individual advantages due to the exercise of our business activities. Polo Surgical’s assets and facilities may not be used for personal purposes by our employees, except in exceptional cases and with prior and express authorization.

Relationship with Healthcare Professionals – The interactions of Polo Surgical employees and their partners with healthcare professionals may only involve the presentation or discussion of educational/scientific topics related to the medical products marketed by Polo Surgical. No commercial negotiation, delivery of gifts or values to health professionals is allowed by any Polo Surgical representative.

Donations, Gifts and Entertainment – It is not allowed to transfer anything of value to public employees, health professionals or any other, such as gifts, entertainment expenses.

Donations may be made for charitable purposes, to philanthropic entities, nursing homes, institutions that care for cancer patients. These donations will always be motivated by good faith and will not be made to clients or directed by sales.

5. SUSTAINABILITY IN BUSINESS

Social Responsibility and with the Civil Society – Polo Surgical acts with social responsibility in all its policies, in all its practices, in all its relations with its internal or external public, being always attentive to human rights and to the fulfillment of good labor practices.

Respect for the Environment – Polo Surgical acts with responsibility and respect for the environment, keeping its Solid Waste Management Program updated, according to the applicable legislation, by entering into a contract with a specialized and legalized company with the competent bodies whenever it is necessary to dispose of expired or damaged medical products in its stock.

6. COMMUNICATION CHANNELS

In order to ensure compliance with this Code of Ethics and Conduct, cooperating at all organizational levels, the Compliance area is available for clarifications through its agents and existing communication channels whenever any doubt arises regarding the interpretation and compliance with the rules consolidated herein.

Incident Communication – Denouncements Channel

All Polo Surgical associates have the right and duty to report violations of this Code, the Compliance Manual, the Quality Procedures, as well as other internal Policies and Norms and current legislation. For this purpose, the Polo Surgical Denouncements Channel is available, accessible through written communication and directed to compliance@polosurgical.com.br or to the address Rua Coroados, 67, Aterrado – Volta Redonda – RJ – CEP 27213-000, To Compliance Officer. It is also possible to contact by phone 21-99013-0006.

The company, through its Audit and Compliance Committee, will diligently investigate the allegations presented.

The protocol followed is that of confidentiality and aims to preserve the integrity of the information, the success of the verification process and the principle of non-retaliation.

Responsibility for internal investigations – The Polo Surgical Audit and Compliance Committee is responsible for internal investigations and for the collection of evidence and evidence, as well as for taking the measures it deems appropriate regarding violations of this Code, internal policies and applicable laws.

7. FULFILLMENT

The Executive Director is responsible for ensuring that employees understand and comply with this Code of Ethics and Conduct, as well as creating a work environment where compliance is expected and rewarded.

All Directors, Managers and other employees certify in writing that they understand and are committed to comply with the provisions of this Code of Ethics and Conduct and its principles.

Violation of the ethical principles described herein or failure to comply with internal policies will not be tolerated and will result in disciplinary action, which may include termination of employment, if appropriate.

FINAL PROVISIONS

The bases and principles of this Code must be constantly observed and respected by all.

We value the cooperation of all employees in solving problems and clarifying doubts related to the rules of this Code. Consultations are welcome and encouraged.