Compliance Program and General Policies

EMFLORA carries out forest management and technology applied to silviculture, as well as solutions in forestry logistics, carbon credits, aerial application, vegetation clearing, recovery of degraded areas, and facilities, always guided by ethical and professional principles.

Our commitment is based primarily on:

• Working in partnership with stakeholders, procuring products and providing services that serve customers with quality;
• Planning and implementing actions in accordance with applicable requirements, integrating occupational health and safety, quality, and environmental matters into our activities as a way of adding value to the company's business;
• Developing employees professionally through the enhancement of skills and experience, always pursuing best practices;
• Ensuring the integrity of employees by providing healthy and safe workplaces and conditions aimed at preventing injuries and occupational illnesses;
• Identifying, assessing, and managing the risks and opportunities that affect the business, systematically measuring and monitoring the organization's production processes, with the aim of: preventing pollution, eliminating accidents, controlling risks, implementing opportunities, reducing potential environmental impacts, and making rational use of natural resources;
• Continuously conveying to employees that everyone's cooperation is essential for the elements of this Policy to be applied in EMFLORA's day-to-day operations, with the goal of ever-increasing quality.

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Our History

We are EMFLORA SERVIÇOS E EMPREENDIMENTOS FLORESTAIS LTDA, a provider of high-technology forestry solutions across the entire silviculture value chain.

Founded in 1991, we have demonstrated over the years a capacity for innovation and sustainable growth, thanks to our permanent and determined pursuit of full customer satisfaction. We have become a solid company, diversifying our businesses and areas of operation: Silviculture (from nursery to forest maintenance), Forest Logistics, Carbon Credits, Aerial Application, Vegetation Clearing, Degraded Land Restoration, and Facilities (civil maintenance, upkeep, cleaning, and green areas).

With 2,600 employees (June 2026), we operate in nine Brazilian states: Bahia, Espírito Santo, Maranhão, Mato Grosso, Mato Grosso do Sul, Minas Gerais, Pará, Santa Catarina, and São Paulo.

We have developed strategic partnerships and agreements with companies across various sectors — Pulp & Paper (Suzano, Bracell, Klabin), Wood Panels (Placas do Brasil), Mining, Metals & Energy (Vale, Gerdau, Vallourec), Bioenergy & Renewable Fuels (Acelen, Infiniti Agro), and Carbon & Assets (Mombak, Manulife, Biomas) — which have enabled the development of new lines of work. The entrepreneurial spirit and background of our Senior Management; the experience of our managers and directors, proven over more than 50 years of work in the sector; a complete technical team composed of forestry engineers, agronomists, mechanical engineers, occupational safety engineers, occupational physicians, an occupational nurse, mid-level technicians from various fields, and numerous professionals with undergraduate, graduate, and master's degrees; highly skilled staff managing our operational and administrative areas, such as lawyers, administrators, accountants, and coaches; and a valuable team of employees ready to overcome challenges (not always easy to surmount) all contribute to significant improvements in our efficiency, emphasizing the quality of our products and services and, consequently, the trust of our customers and suppliers.

In short, a great deal of work has been done to get us this far, and we know there is still much to do.

Therefore, dear employee, we always count on your best effort and enthusiasm to help us on this journey. You are part of our history.

More information about our company can be found on our website: www.emflora.com.br

Mission

To deliver high-technology solutions with sustainability across our customers' entire forestry value chain, driven by innovation and long-term strategic partnerships.

Vision

To lead the transformation of the forestry sector through continuous innovation, operational excellence, and a commitment to a sustainable future.

Values: SAQE

• S – Safety (Segurança): Safety is non-negotiable. Every employee returns home healthy and unharmed. We maintain the highest occupational safety standards, certified under ISO 45001:2018, and promote a culture of prevention across all our operations.
• A – Austerity (Austeridade): We manage resources with responsibility and financial discipline. Austerity is not restriction but intelligent efficiency — doing more with less, optimizing processes, and ensuring long-term economic sustainability for our customers and for the company.
• Q – Quality (Qualidade): Operational excellence is our commitment. Certified under ISO 9001:2015, we deliver services that exceed expectations, with rigorous control, measurement, and continuous improvement processes at every stage of the forestry chain.
• E – Efficiency (Eficiência): Constant optimization. We use cutting-edge technology, automation, and data analysis to maximize productivity, reduce operating costs, and deliver superior results within increasingly competitive timeframes.

Human Resources Policy

As a company, our goal is to provide a balanced and supportive work environment where employees take pleasure in their work and can perform their duties safely. Through dedication and the training we offer, we pursue both professional and personal development. We provide appropriate training in all areas and, whenever possible, fill open positions through internal promotion, offering salaries and benefits in line with market practices for each field of activity.

The goals of our People Management and Development Department (DGDP) are: to attract talent — competent people suited to the position being filled (Recruitment & Selection); to develop professional competencies (Training & Development); and to retain competent professionals (Compensation & Salaries and Benefits).

Recruitment, Selection, and Personnel Development

Recruitment, Selection, and Personnel Development are also among the responsibilities of EMFLORA's DGDP and aim to fill job opportunities within the Company through internal and/or external recruitment. The selection process takes into account the internal advancement of qualified employees and/or those with growth potential. Any employee who considers themselves qualified and capable of filling an available position may apply to the selection process, provided they meet the minimum requirements for that role, competing with other employees and with any external candidates, where applicable.

It is through the DGDP that we plan, execute, and oversee EMFLORA's Training Program, which aims at personal development by expanding and strengthening professional skills and competencies.

Job and Salary Administration

Within the DGDP, we administer the job and salary policy and structure according to modern administrative practices. It is updated periodically through our own surveys or surveys conducted in partnership with other companies, seeking to maintain balance among the salaries paid for the different positions in our workforce, in accordance with the category's collective bargaining agreement.

The Company ensures that men and women in equivalent positions receive equal pay, pursuant to Lei nº 14.611/2023 (Pay Equality), observing the pay transparency obligations applicable to companies with more than 100 (one hundred) employees.

Treating EMFLORA Employees with Respect

To EMFLORA, every employee is valuable. For this reason, we strive to ensure that every employee of the Company has their basic human rights respected and does not suffer physical or psychological violence in their work environment, in any form whatsoever. On the contrary, employees must be protected in their physical safety, with their working conditions always maintained at the highest possible standard, with encouragement and motivation so that, under appropriate conditions, they can develop and grow within the Company.

Accordingly, no employee shall be discriminated against on the basis of age, sex, social class, nationality, religion, disability, union membership, political opinion, ethnic origin, or any other form of diversity. Emflora's relationships are grounded in the principle of equality and in valuing diversity.

All employees must be aware of the essential terms and conditions of their employment.

For this reason, as a company, we condemn child labor and support its non-occurrence throughout our entire production chain (customers and suppliers). Under the Federal Constitution (art. 7º, XXXIII), any work is prohibited for those under 16 (sixteen) years of age, except as an apprentice, from the age of 14 (fourteen). The only contract that exists for those under 18 (eighteen) years of age at EMFLORA is the young apprentice contract (from age 14), in accordance with the applicable legislation.

Through our Social Responsibility Project, named EMFLORA EM AÇÃO, we support the Education and Development of Children and Adolescents, reflecting Emflora's concern for children and its interest in education. EMFLORA EM AÇÃO aims to help eradicate child labor, because a child's place is in school and in spaces for recreation and education.

Likewise, Emflora condemns forced or slave labor within the Company and throughout its entire production chain.

In addition, we strive to ensure that workplace safety is always a top priority: "safety first, because you matter, your life matters."

Personal Information

It is the responsibility and duty of all employees to inform the Personnel Department of any changes to their personal data (address, telephone number, marital status, surname, and dependents), as well as non-routine situations such as INSS leave or medical certificates.

Changes to personal information — address, marital status, and dependents — must be supported by a copy of the Marriage Certificate, Birth Certificate, Death Certificate, and a water, electricity, or telephone bill, or other documents that can substantiate the changes.

The processing of this data complies with the LGPD and with the "Privacy and Personal Data Protection" section of this handbook.

Employee Duties

It is the responsibility of every employee to follow EMFLORA's Code of Conduct and other policies in a consistent and appropriate manner, and to support others involved in doing the same. Employee duties include:

• Fulfilling the commitments expressly undertaken in the individual employment contract with attention, diligence, ethics, and professional competence.
• Following orders and instructions from hierarchical superiors.
• Suggesting measures to improve the efficiency of the work.
• Ensuring that the highest level of discipline is always maintained in the workplace.
• Caring for the order and proper upkeep of facilities, equipment, and machinery, reporting any abnormalities observed to their hierarchical superior.
• Safeguarding the confidentiality of the company's customer data and information.
• Being accountable for losses caused to Emflora, whether through intent or fault (negligence, lack of skill, or recklessness), with liability arising from the withholding of entrusted funds and items; damage to or deterioration of materials in their custody or subject to their oversight; or intentional miscalculation against EMFLORA and/or its customers. Administrative liability does not exempt the employee from any applicable civil or criminal liability.

We do not prohibit the hiring or promotion of employees who are related by family or romantic relationship within our workforce. However, favoritism or interference of personal matters in the Company's business will not be permitted, and adequate internal controls are also required to ensure compliance with this Code.

Anyone who violates the Code of Conduct or EMFLORA's policies and procedures, appended to this compilation, will be subject to the applicable disciplinary sanctions, which may extend to dismissal.

Disciplinary sanctions apply to anyone who commits or approves violations, or who is aware of them and fails to take steps to correct them promptly.

Punctuality and Attendance

As a company, we expect the following professional conduct from our employees.

Every employee has their working hours established in their employment contract. Failure to fully comply with these hours, without a justified reason, may result in pay deductions and constitute insubordination subject to penalties. The established working hours must be observed by all employees but may be changed according to service needs and at the company's sole discretion.

Employees must be at their workstation at the start of their shift; lateness is not permitted unless the justification complies with EMFLORA's internal rules.

Time must be clocked daily, in accordance with the working hours stipulated in the employment contract. The absence of attendance records constitutes an absence from work.

A minimum break of 1 (one) hour between the morning and afternoon shifts is mandatory. Clocking in or out on behalf of another employee constitutes, for both, grounds for termination of the employment contract for "just cause." Any errors in time records must be reported immediately to the person in charge of the Personnel Department.

An employee who, for any justifiable reason, must miss work will have 48 (forty-eight) hours to submit the certificate or supporting document to the Personnel Department or to their immediate supervisor for proper processing; otherwise, the absence will not be excused. Absences not justified by or to management will result in the application of the applicable penalties to both the manager and the employee. Time cards must be signed by the employee at the end of each month and may not contain any erasures or annotations anywhere on them.

Overtime

Employees are strictly prohibited from working overtime, except when requested and/or with the express written authorization of their Management/Executive Board/Supervisor. EMFLORA considers "overtime" only those hours duly recorded on the time card and authorized via the "internal communication" form, endorsed and stamped by the Personnel Department, not exceeding 10 (ten) hours per day, except in cases of force majeure.

Force Majeure: The Company may also extend its employees' normal working hours due to force majeure, that is, due to an unforeseeable and unavoidable event, such as floods, fires, structural collapses, etc.

In such cases, there is no time limit on the extension, and payment for the hours worked is mandatory.

Visitors

Visitors have access only to the Reception area and the Gatehouse.

Within the Company's internal premises, only suppliers and customers who are duly identified, authorized, and accompanied by an employee are permitted; in other words, visitors must not move about the Company's premises without being accompanied by an employee or without proper identification. Even when identified, they must be announced by Reception.

We value quality and constantly seek the continuous improvement of our processes. In all interactions with customers, suppliers, consumers in general, the press, and the broader public, we must keep in mind the importance of maintaining our standard of quality and service, since EMFLORA's image is in contact with the outside world.

Employees must not criticize and/or disparage the services, the team, or the Company in front of others. Doing so demonstrates a lack of ethics and commitment toward the Company, its products, and one's colleagues. In a spirit of teamwork and unity, any and all problems should be raised and addressed internally.

Hair, Beard, and Makeup

Women: hair clean, worn loose or properly tied back. For the receptionist position, we ask that no flashy accessories be worn and that makeup be discreet. For all other positions, wearing makeup is not mandatory, but it is appropriate and should preferably be discreet.

Men: short hair and a clean-shaven face; if choosing to wear a beard, it must be kept trimmed.

Uniform

The uniform is mandatory during working hours and must always be clean, presentable, and complete. Employees are responsible for the safekeeping and proper use of this attire, keeping it clean and in good condition.

Female administrative employees will be provided with the uniform shirt, which may be worn with plain trousers (jeans or fabric) or skirts of knee length or longer. Pregnant employees will be provided with the "smock" uniform and, when necessary, will be permitted to wear other clothing, at the discretion of the executives.

Guidance for Executives

With regard to "Personal Presentation," executives must dress in a manner appropriate to the role they hold at EMFLORA, with the following prohibited for everyone: wearing flip-flops in the workplace; wearing extravagant, short, or sheer clothing; wearing shorts, above-the-knee skirts, or sleeveless tank tops (except for women, who may wear them under a blazer); and wearing caps or soccer team jerseys.

Conduct in the Workplace

EMFLORA values a healthy and harmonious work environment. To that end, it relies on cordial and courteous interpersonal relationships, avoiding jokes with double meanings as well as the use of profanity. Respect your colleagues the same way you wish to be respected. Take care of the Company's equipment and materials so as to prevent accidents, losses, damage, and harm.

It is the responsibility of every employee to follow EMFLORA's Code of Conduct in a consistent and appropriate manner, and to support others in doing the same. When there is information that our Code of Conduct has not been complied with, or even when non-compliance is suspected, measures will be taken to investigate and, if necessary, resolve the situation.

All employees have the support of the Executive Board and are encouraged to report and voice their concerns, which should be done in good faith and with clarity, respect, and honesty.

EMFLORA is committed to protecting its employees from any retaliation. Those who violate the Code of Conduct or the Company's policies and procedures will be subject to the applicable disciplinary sanctions, which may include dismissal.

How to Handle Conflicts of Interest and Influence

A conflict of interest arises from any opportunity for personal gain by an employee that may conflict with EMFLORA's activities, interests, and image, as well as from engaging in any other activity that conflicts with their working hours.

At EMFLORA, decision-making must always be grounded in what best serves the Company's interests, over and above personal considerations or relationships. Everyone must avoid situations in which personal interests interfere, or appear to interfere, with the Company's interests. Below are some examples of situations that warrant special attention.

Outside Employment

Any other employment an employee holds outside EMFLORA, with or without compensation, must not impair the performance of their duties at the Company.

Professionals must not become involved in outside business interests that may divert attention or time away from their responsibilities at EMFLORA, or that require work during their hours at the Company.

Workplace and Sexual Harassment

No form of workplace or sexual harassment will be tolerated, encompassing any conduct that negatively affects work performance, demeans the dignity of any person, or creates an intimidating, hostile, or offensive work environment.

Conduct considered sexual harassment includes behaviors such as repeated propositions or verbal, gestural, or physical sexual insinuations.

Pursuant to Lei nº 14.457/2022, Emflora maintains a whistleblowing channel (ombudsman), investigation procedures with guaranteed confidentiality, and periodic training initiatives on preventing and combating harassment, with the support of the CIPA — Internal Commission for the Prevention of Accidents and Harassment.

Criticism and Suggestions

Criticism and suggestions aimed at adding value and encouraging improvements for the Company are extremely constructive and welcome. Accordingly, criticism and suggestions should be directed to one's superior, who will forward them to the appropriate responsible department.

Conversations that are not directed to people who can take the appropriate action or who can genuinely contribute to improving the system lose the focus of continuous improvement, become destructive, and are inconsistent with the ethical conduct expected of a member of the EMFLORA team, and may carry consequences for the employee.

Ethics

In Relations with Stakeholders

Our Management Team aligns its management model with sustainability principles as a foundation for the longevity of the business. For this reason, our corporate operations pursue continuous improvement in their processes, relationships, and services through our Quality Management System and through effective engagement with Health, Safety, and Environment principles, out of respect for the life of every employee.

We at EMFLORA express our policy of respect for standards of business ethics based on conduct enshrined in nationally and internationally recognized treaties and standards, such as the Universal Declaration of Human Rights, the Fundamental Rights at Work, and the Rights of the Child and Adolescent.

All of us, EMFLORA employees, strive to contribute to fair and sustainable development. Our commitment encompasses and extends across all levels of the Organization and aims to raise awareness throughout the other levels of the production chain so that the country can achieve the goals established by the 17 Sustainable Development Goals (SDGs) of the UN 2030 Agenda.

Ethics with Customers and Competitors

It takes many years to build a good corporate reputation and become a benchmark in the national market. We have built and sustained our reputation on the quality of our services and on respect for, and the use of, legal and ethical practices in our relationships with customers and competitors. We know our worth and understand that there is no need to break ethical rules or "defame" customers and competitors in order to be noticed. This is because the results of our work speak for themselves. That is how we maintain our market position, and the Company's success is the result of its own merit, with the contribution of every employee.

We deal with the competition with fairness and respect for all laws applicable to our business segments. Accordingly, false or misleading statements are unacceptable, whether about our Organization or its activities or about the people and/or institutions that interact with us.

We respect the confidentiality of our customers, our competitors, our own, and that of other companies with which we do business. Ethical posture and conduct demonstrate that there is no need to use confidential information — whether professional or personal, belonging to EMFLORA or to third parties — for personal benefit; accordingly, we prohibit such behavior. We also do not allow information owned by EMFLORA to be provided to any individual or legal entity without its express authorization.

Under no circumstances do we engage in business that is not grounded in ethical principles and guided by transparency, which is one of our Company's values and pillars.

Ethics with Partners and Suppliers

For the engagement of suppliers and service providers, we use technical, professional, and ethical criteria, following the guidance of regulatory standards that meet the requirements of ISO 9001:2015. The qualification process follows procedures that are established in advance and known to all parties interested in establishing business relationships with EMFLORA. We do not accept payments or benefits of any kind in exchange for contributions we may have made to individuals or legal entities that maintain business relationships with EMFLORA.

Social and Environmental Responsibility

Ecological awareness and care for the environment are social commitments of the Company, for it is through respect for the environment that we can believe in a better future for all.

To this end, we comply with the legislation in force applicable to our activities. We also express our commitment to and support for fundamental human rights, and we avoid establishing relationships with individuals or legal entities that break the law or abuse human rights.

We act ethically and in a socially responsible manner. We encourage support for activities related to education, health, and volunteer and community service, in line with our social and environmental responsibility. We strive to minimize any potential environmental impacts that may be caused by our operations.

Through the Emflora em Ação project, we assist surrounding communities with the aim of promoting social well-being and fostering improvements and transformations in the quality of life of their residents. Emflora works to develop partnership relationships, especially in the areas of Safety, Health, Environment, and Psychology, in the regions where it operates.

The transparency embedded in all our processes led us to join the Carbon Disclosure Project (CDP) Supply Chain in 2010, and we remain signatories to this day. The CDP is a collective request put forward by a group of 300 institutional investors. The project was conceived as an effective mechanism to enable companies and investors around the world to access reliable information about the impact of GHG emissions and the resulting climate change on the results of the companies involved.

In addition, Emflora has also created a social training project called "Semear," offering a free training course in partnership with the employment agencies of the cities where the company operates, thereby contributing to workforce qualification alongside sustainable development.

Emflora's social engagement is rounded out by three programs integrated into its operations: Raízes Florestais — the hiring of refugees in partnership with Operação Acolhida, the Brazilian Army, and NGOs, with more than 500 refugees hired; Recomeço — the hiring of former inmates of the prison system, offering a second chance as forestry employees; and Cultivar — an inclusion and diversity program.

Emflora has been carrying out initiatives that are economically viable, environmentally sound, and socially fair. And beyond the awareness of the parties involved, our goal is to build awareness among people. As an Organization, we thereby affirm our social and environmental commitment and, after 35 years since our founding, we seek to ensure the conditions for Emflora itself and for society to meet present needs without compromising future generations.

We work with the goal of meeting sustainability requirements.

Privacy and Personal Data Protection (LGPD)

EMFLORA processes the personal data of employees, candidates, customers, suppliers, and other stakeholders in compliance with the Brazilian General Personal Data Protection Law — LGPD (Lei nº 13.709/2018) and with the Resolutions of the ANPD, as detailed in EMFLORA's Privacy Policy and Internal Data Protection Regulations, which supplement this handbook.

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Purpose

The purpose of this manual is to prevent and combat corrupt practices, bribery, money laundering, breaches of information privacy involving stakeholders, violations of fair competition, and any practices that may fall outside compliance standards and could involve the company and its stakeholders. It seeks to meet the requirements of Lei nº 12.846/13, Decreto nº 11.129/2022, and other applicable regulations, as well as to clarify which acts are contrary to these rules, reinforce the Company's Code of Ethics and Conduct, and provide guidance on what to do should such practices occur, so that, as a company, we can carry out our activities with integrity and respect for our stakeholders.

Definitions

Corrupt Practices: The following practices set out in law are considered corrupt or harmful acts against the national or foreign public administration: giving, promising, or offering kickbacks, undue advantages, or benefits; engaging in money laundering, bribery, or extortion; creating and/or improperly using individuals or legal entities to conceal real interests; committing any type of fraud against public procedures, the contracts arising from them, or their bidders; as well as obstructing public or private oversight.

For further clarification, see Lei nº 12.846/13.

Extortion: The act of forcing someone to do something through threats in order to obtain some benefit.

Bribery: The practice of paying, promising, or offering something to someone in order to induce them to commit a specific unethical and illegal act.

Money laundering: A financial practice intended to conceal assets and capital of illicit origin, or to disguise them so that they appear to have been acquired legally.

Fraud: Any unlawful and deceptive act carried out with the intent of obtaining personal gain.

Stakeholders: Individuals or legal entities that have some relationship with the company or are affected by it in any way.

Compliance: Conformity with applicable requirements.

Nepotism: The practice whereby a person in a position of authority favors individuals with whom they have a family relationship, replacing merit-based evaluation.

Statement of the policy on integrity in business relations and anti-corruption

EMFLORA strives to conduct its activities ethically and transparently toward its stakeholders, focusing on the compliance of its activities and the quality of its services, respecting life, and remaining mindful of its social and environmental commitments.

In keeping with our values, our company's mission is to carry out its activities with commitment to its clients, acting in accordance with applicable national and international legislation, grounded in compliance practices, and aiming to meet the standards of its Code of Ethics and Conduct, which does not allow relationships (with either individuals or legal entities) or practices characterized as corrupt or involving any type of fraud, money laundering, extortion, bribery, or the acceptance of improper payments, benefits, or gifts.

Our vision is to expand our field of operations with integrity and commitment to the adoption of anti-corruption practices, underpinned by this defense, so that we may achieve our objectives within the framework of lawful practices.

Employees are expected to perform their duties while safeguarding the privacy of stakeholders' information, in accordance with the Company's Code of Ethics and Conduct; any action contrary to it and/or unlawful under the applicable laws is subject to consequence management, which may even result in termination of the employment contract. All stakeholders have the authority and the responsibility to report any occurrence or suspicion of such practices, thereby fostering a work environment grounded in anti-corruption actions and practices and strengthening EMFLORA's compliance efforts.

Anti-corruption practices adopted by the company

Policy – Political Parties

Our company does not provide any financial support or any other contributions of value to political parties or their campaigns.

Donations and Social Contributions

Our social and charitable contributions are subject to prior internal approval, in order to restrict potential conflicts of interest and prevent money laundering operations or other types of illicit activities.

Centralization of Payments at the Head Office

We make virtually all payments to our suppliers through the head office, thereby avoiding the need for finance departments at our branches. To this end, this procedure follows these steps:

1. The branch contracts a service or purchases a given product;
2. After delivery of the product or service, the supplier issues its corporate invoice;
3. This invoice is sent by the branch's purchasing department to the head office's tax department;
4. The head office's tax department enters the invoice into the system;
5. The manager responsible for the branch accesses the system and approves payment of the obligation generated by that invoice;
6. On the day before the due date, the head office's finance department checks the entries and the approval. If everything is in order, it proceeds with the bank remittance. Payment remittances are generated and sent using two keys/passwords, so that two people always share this responsibility. If payment is made by bank deposit, the account holder must be the same legal entity that issued the invoice. In the case of payment by bank slip (boleto), the same rule applies to the payee.

The financial transactions carried out by our branches are limited to what is known as the petty cash fund, which corresponds to an amount sent by the head office, between R$ 1,000 (one thousand reais) and R$ 2,000 (two thousand reais), withdrawn by the branch to pay small expenses throughout the month, such as ticket purchases and travel expenses. These must be submitted regularly for review, approval, and recording by the head office's finance department. For this purpose, a standard report is used, requiring authorization from the person responsible for the contract for the expenses paid. Replenishment of the petty cash fund is always conditional on proper accounting for the previous disbursement.

Branch payments made from the petty cash fund follow the same rules as any purchase. Therefore, a valid accounting document is never waived. The petty cash fund is generally under the responsibility of the branch's Administrative Supervisor.

Centralization of Accounts Receivable at the Head Office

Even though customer billing invoices are issued by the branches, payments are received exclusively in bank accounts held by the head office, with access and transactions restricted to the corporate finance department, always using two keys/passwords.

Tracking of Owned, Leased, and Subcontractor Vehicles

Our company has a fleet consisting of owned, leased, and subcontractor vehicles. Owned vehicles are equipped with a GPS tracking system with driver identification, providing advanced vehicle-usage reports that can be sent automatically by email at the desired frequency, indicating whether the vehicle traveled outside the company's operating area or outside working hours.

Gifts and Courtesies

Stakeholders must not receive from or offer to one another gifts, presents, or courtesies. Should this occur, the immediate supervisor must be informed and the gift handed over to them, so that it may be made available to EMFLORA or returned.

The only exception is corporate giveaways, such as planners, pens, caps, shirts, or other items bearing the logo of the company donating the item in question.

Accounting Records

We purchase products or services only from companies that are able to issue tax and/or accounting documents.

Tax assessments are performed, recorded, and filed within the legal deadlines, in accordance with municipal, state, and federal legislation.

Regarding the place where services are performed, we indicate where the Tax on Services of Any Nature (Imposto Sobre Serviço de Qualquer Natureza – ISS) will be allocated, whether as payment or withholding, in accordance with the tax code of the municipality in which the service in question was performed.

As a best practice, there is systematic monitoring of the clearance certificates we obtain at the municipal, state, and federal levels. More specifically, licenses/certificates are also monitored with the relevant oversight bodies, such as: the Brazilian Institute of the Environment and Renewable Natural Resources (Instituto Brasileiro do Meio Ambiente e dos Recursos Naturais Renováveis – IBAMA), FGTS Severance Fund certificates with Caixa Econômica Federal, and labor and litigation certificates with the Ministry of Labor and Employment (Ministério do Trabalho e Emprego – MTE), among others.

Among the records mentioned, we also submit labor, social security, and tax information in strict accordance with the legally established deadlines, through eSocial and EFD-Reinf (monthly) and FGTS Digital.

A computerized system records all invoices for services rendered, sales, purchases, and asset transactions, as well as all payroll events and financial operations. The latter are exemplified by situations such as receipt of invoices and withholdings, and payments of financing, fees, taxes, contributions, and insurance, among others.

To meet these requirements, we maintain physical and/or digital archives to ensure the safekeeping of tax/accounting documents, in accordance with the legal guidelines governing labor, tax, and financial matters, with attention to the archiving of ledgers (required by law) in physical and/or electronic format, as defined by the relevant legal requirements.

Nepotism

The company has a Human Resources Policy that sets out EMFLORA's recruitment and selection methods, based on technical criteria and the organization's professional needs.

Relationships with External Providers

Our company maintains its Code of Ethics and Conduct based on clear guidelines regarding relationships with external providers.

In addition, we have a purchasing procedure for acquiring products and/or services that are critical to the business.

As a way of clearly formalizing the sale of products or services to EMFLORA, ongoing external providers (for a term defined by contract) have a service or product supply agreement with the company that includes the following provision: The external provider undertakes not to engage in any practice that may violate anti-corruption law (including international laws and Brazilian laws relating to improper or illegal gifts, gratuities, payments, or commercial or government bribery). In particular, the provider must ensure that neither it nor any of its agents, representatives, partners/employees, and/or staff will pay, promise, or authorize the payment of money or anything of value (including, without limitation, all gifts, meals, entertainment, or travel), directly or indirectly, to any official, individual, or legal entity, where there is a reasonable likelihood or the purpose of: a) inducing the person to improperly perform or fail to perform their function; b) securing an improper advantage; or c) inducing the person to improperly use their influence to affect or influence any act or decision.

Conflict of Interest

These are situations that may give rise to personal interests on the part of stakeholders in professional matters concerning Emflora, improperly influencing its business. Decision-making must take into account solely and exclusively the interests of the company, and practices contrary to organizational objectives will not be tolerated on the part of employees or other parties involved.

Structured Mechanisms for Monitoring the Evolution of the Legal Framework

EMFLORA relies on the support of three advisory and consulting firms, which assist the company in monitoring and staying up to date with rules and legislation on labor, social security, accounting, and tax matters, as well as in the other areas covered by Business Law, providing consulting services and daily bulletins on these subjects.

Training

Emflora disseminates its anti-corruption practices and policies through its Code of Ethics and Conduct, offers training to its employees in the form of dialogues on the subject, and provides this manual as a source of information for all stakeholders, so that they know how to identify situations of non-compliance and what to do when they occur. Training activities also serve to prevent corrupt practices.

Training is guided by the Human Resources Management Procedure, which specifies mandatory training and also describes how training needs are assessed and how EMFLORA's training plan is prepared. Finally, the company also provides for an evaluation of the effectiveness of its training as a way of ensuring continuous improvement of the organizational process.

Internal Control

Emflora is also legally required to plan and maintain a system of internal accounting controls sufficient to ensure that:

1. transactions are carried out in accordance with management's general or specific authorizations;
2. transactions are recorded as necessary to (A) permit the preparation of financial statements in accordance with generally accepted accounting principles or any other criteria applicable to such statements; and (B) maintain control over assets;
3. access to assets is permitted only in accordance with management's general or specific authorizations;
4. the recorded accountability for assets is compared with the existing assets at reasonable intervals and appropriate action is taken with respect to any differences.

All Emflora business units must establish internal controls and procedures consistent with these criteria and that enhance compliance with this Anti-Corruption Policy.

An effective internal control system consists of having commercial and financial teams review transactions and expense/payment requests for indicators that signal inadequate commercial grounds or excessive risks. Below is a list of common red flags:

• The party involved in the transaction has business ties, a family relationship, or any other type of close personal relationship with a client or public official, or was recently a client or public official, or qualifies for the transaction solely on account of its influence over a client or public official. A client or public official recommends or insists on the use of the party involved in the transaction.
• The party involved in the transaction refuses to include anti-corruption contractual provisions, uses a "shell company" (a company that has been incorporated but has no record of significant assets/operations) or other unorthodox corporate structures; insists on unusual or suspicious contractual procedures; refuses to disclose the identity of its partners; or requests that its contract be backdated or otherwise altered to falsify information.
• The party involved in the transaction has a bad reputation, has faced accusations of bribery, corruption, fraud, or other unlawful acts, or has few or no third-party references. The party involved in the transaction does not maintain an office, staff, or adequate qualifications to perform the contracted services.
• The expense/payment request is unusual, is not supported by adequate documentation, is extraordinarily high or disproportionate to the services to be rendered, does not comply with the terms of the contract governing it, or involves the use of cash or bearer instruments.
• The expense/payment request involves an unrecorded account, is for payment in a jurisdiction outside the country where the services were or will be rendered, or was not made in accordance with local laws.
• The expense/payment request is described as necessary to "win the business" or "make the necessary arrangements."

This is not an exhaustive list (i.e., other red flags may be considered), and the indicators vary according to the nature of the transaction, the expense/payment request, and the geographic market or line of business. Emflora employees must constantly assess whether other common red flags are present in the specific situations they are monitoring.

Risk Assessment, Monitoring, Certification, and Investigation

Business segments must periodically assess the nature and extent of their exposure to internal and external corruption risks and properly document this risk assessment. The purpose of this assessment is to identify the most significant risk areas and take mitigation actions focused on those areas.

Emflora is committed to monitoring the effectiveness of its anti-corruption processes and controls, as well as to conducting investigations to ensure compliance with anti-corruption laws, this Policy, and any related procedures.

Business segments must periodically certify compliance with these matters, in accordance with Emflora's Compliance certification process, and provide relevant information related to risk assessments, processes, and controls.

Ombudsman

Emflora maintains an ombudsman channel through which compliments, complaints, and reports may be submitted — the latter in the event of, or upon suspicion of, corrupt practices or practices contrary to this manual or to other EMFLORA policies.

It can be accessed through the contacts below:

It is important to emphasize that reports may be made anonymously or not, and the company is committed to preserving anonymity if the reporter so wishes.

Reports received will be assessed and answered, with the appropriate handling, within 96 hours. In some scenarios a longer response time may be necessary. In that case, however, if the report was not anonymous, EMFLORA will get in touch to communicate a new deadline.

There is internal follow-up to ensure responses to internal and external reports. In some cases, the Compliance department is responsible for assessing and determining, together with the company's executive board, the actions to be taken in response to the report.

Applicable Penalties

In the event of a violation of this policy, a warning will be issued — a maximum of two. After the second warning, a suspension may follow, and subsequently termination of the contract.

In most jurisdictions, both legal entities and individuals may be held liable for committing a crime. In general, criminal liability involves fines and terms of imprisonment that can be severe.

Alternatively, the fine may amount to twice the benefit the defendant sought to obtain by making the corrupt payment. Legal entities and individuals may be prosecuted for corruption in Brazil, in the country where the corruption took place, and in other countries. Fines imposed on individuals may not be paid by their employers.

In addition to criminal liability, both individuals and legal entities involved in corruption run the risk of being sued in civil court and ordered to compensate other individuals or companies that may have suffered losses as a result of the corrupt act. This can occur when, in order to recover costs and profits lost due to a lost competitive bid, the losing bidder brings an action against the winner to whom the contract was corruptly awarded.

In some cases, dismissal for cause or cancellation of the contract with an external provider may occur directly, with this situation being evaluated by the Compliance Committee.

References

• UK Bribery Act - UKBA (the United Kingdom's anti-bribery and anti-corruption law)
• Foreign Corrupt Practices Act – FCPA (the U.S. federal anti-corruption law)
• Lei nº 12.846/2013 (the Brazilian Anti-Corruption Law)
• Decreto nº 11.129/2022 (the regulation implementing the Anti-Corruption Law)

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Purpose

At EMFLORA, we recognize that our employees are the key to our success. Nothing can be achieved without their engagement. This document presents the guidelines that serve as the foundation for Human Resources Management and illustrates aspects of the employee life cycle at EMFLORA.

The mission of EMFLORA's People Management and Development Department (DGDP) is to:

• Attract talent — competent people suited to the position being filled (Recruitment & Selection).
• Develop the competence of our professionals (Training & Development).
• Retain Competent Professionals (Compensation & Salaries and Benefits).

Statement of EMFLORA's Human Resources Policy

EMFLORA's Human Resources Policy aims to provide a balanced and supportive work environment where employees take pleasure in their work and are able to perform their duties well and safely.

In keeping with its values, the company's mission is to carry out its activities with commitment to its clients, acting in accordance with applicable national and international legislation and grounded in dignified labor relations practices.

We ensure full compliance with all applicable rules and regulations, whether of legal, labor, administrative, or collective-bargaining origin, including in the hiring of third parties.

In its activities, Emflora adopts measures to prevent coercive practices aimed at obtaining advantages, abuse of power, and inhumane treatment, and maintains a formal mechanism for reports and complaints — its communication channel, the Ombudsman. The company also adopts formal measures in its activities to prevent any form of discrimination and to encourage inclusion.

EMFLORA has a solid record of social engagement through the EMFLORA EM AÇÃO project, as respect for and appreciation of human rights is a core value of our company. Human Capital is our greatest asset, and we invest diligently in its development through the training we offer, so that our people can grow in a well-rounded way, both professionally and personally.

EMFLORA provides adequate training in all areas, giving preference, whenever possible, to internal candidates when filling vacancies, and offering salaries and benefits in line with market practices in its field of operation.

In addition, the company runs PROJETO SEMEAR, which seeks to achieve sustainable business development by delivering content and expanding self-knowledge, personal skills, and competencies, through a course designed to develop increasingly well-rounded professionals for the forestry sector.

Employees are guided toward understanding and complying with their employment contract; in cases of breach of the contract or of other applicable legal requirements, disciplinary measures are applied.

The company upholds dignified work, banning child labor from its practices and adopting measures to combat the sexual exploitation of children.

Preliminary Provisions

The Human Resources Policies shall govern the relationship between EMFLORA SERVIÇOS E EMPREENDIMENTOS FLORESTAIS LTDA and its workforce across all of its units.

Approval of the Policies and any amendments thereto is the sole responsibility of the Executive Board and the General Management.

The Administrative Board, the General Administrative Management, and the People Development Management are responsible for the administration, control, and direction of all of EMFLORA's Human Resources policies.

All staff holding coordination, supervisory, or leadership positions are responsible for applying all of the human resources policies described in this document.

They also have the authority and responsibility to apply disciplinary measures, in accordance with the legislation in force.

Approval of any change to the policies described in this document requires the following:

• Submission of the proposed change to the General Management;
• Forwarding of the change proposal to the General Administrative Management and the People Development Management;
• Thorough analysis of the proposal by the General Administrative Management and the People Development Management;
• Full discussion with the Executive Board.

No change or proposal shall take effect before it is announced by the General Administrative Management and the People Development Management.

Only proposals approved and released by the Executive Board shall be published by the General Administrative Management and the People Development Management.

Organizational Chart

EMFLORA's Organizational Chart is published as part of its Administrative and Operational Structure. This organizational chart is updated whenever there is any change to the Administrative and/or Operational Structure, subject to approval by EMFLORA's Executive Board.

Workforce Composition

The workforce shall be composed of people without restrictions as to race, color, sex, sexual orientation, age, religion, nationality, ideology, social standing, physical disability, medical conditions, criminal record, or other characteristics protected by law, provided they fully meet EMFLORA's technical, operational, policy, and human requirements. Likewise, EMFLORA expressly prohibits the employment of anyone under 16 (sixteen) years of age, except as a minor apprentice (from age 14), in accordance with the legal provisions and guidance in force for this type of hiring.

The workforce headcount, with the advisory support of the General Administrative Management and the People Development Management, shall be set for the other Coordination units and Management areas, and any modification to a position shall require the approval of its respective management.

Headcount increases shall only be proposed in light of the need to open the position, as justified by the requesting supervisor or coordinator and validated by their respective Management.

Changes to job titles, as well as to descriptions of duties, skills, requirements, and other characteristics of positions, may only be made and put into effect through the People Development area.

Any headcount reduction must be communicated immediately to the Local Management, with notice given to the General Administrative Management and the People Development Management.

Notes: 1. The closing of a position shall not automatically entail the creation of another. 2. The creation of a new position to replace a closed one must follow the procedures described in article 10 of this document.

Personnel Recruitment and Selection

The recruitment and selection process shall only begin with the Employee Requisition form, completed and signed by the immediate supervisor and approved by the manager, and subsequently forwarded to the personnel department to continue the process.

For any position, the minimum time frame for carrying out the Recruitment and Selection work shall be 10 (ten) days, EXCEPT: helper and assistant positions, which shall have a minimum time frame of 07 (seven) days; and executive and highly specialized technical positions, which shall have an indefinite time frame.

Hiring shall only take place to replace an employee or to increase headcount.

All records, résumés, and selection processes carried out shall remain valid for 6 (six) months, in accordance with the retention schedule of the Internal Data Protection Regulations. They shall subsequently be deleted from the records.

All of the hiring rules described herein also apply when an employment agency is used.

Personnel Recruitment

Any recruitment should, preferably, begin within EMFLORA's own workforce.

Any employee may apply for other vacancies within EMFLORA, and Coordinators shall have, among their duties, the role of encouraging and motivating the employees in their areas to do so;

To apply for a vacancy, the employee must demonstrate that their technical, practical, and personal knowledge matches the requirements defined in the job description;

For positions requiring specific qualifications, the employee must provide proof of their specialization and experience;

All else being equal, preference for filling positions shall go to the candidate who is within the progression path of the job and salary plan;

Only when no employee within the company's own workforce meets the requirements for the requested position shall recruitment become external;

Upon approval and at the time of hiring the new employee, original documents must be submitted within 48 hours, except for identification documents, which may never be withheld. No one shall be hired without prior verification of original documents, in order to prevent the irregular hiring of minors under 16 (sixteen) years of age (hiring permitted only as an apprentice, from age 14).

Except for employees with a defined progression in their job and salary plan, all others shall go through the internal selection process.

In the event of a tie in internal recruitment, the tiebreaker shall follow, in order, the following criteria:

1. The best performance, attendance, and punctuality;
2. The longest experience in the role;
3. The longest length of service at EMFLORA.

Only after all internal recruitment possibilities have been exhausted shall external recruitment be conducted to fill any existing vacancy, giving preference to local candidates.

External recruitment may also rely on referrals (for participation in the selection process) from any employee who presents a candidate, with the referring employee being responsible for the candidate's conduct throughout the selection process as well as during their probationary period.

All candidates presented by employees shall receive the same treatment, regardless of the position held by the person presenting them.

In addition to the criteria described above and depending on its needs, the People Development Management may use other means for recruiting personnel, such as:

• Files of candidates whose résumés are on record with the personnel department or who have taken part in previous recruitment processes;
• Posters or notices on EMFLORA's bulletin boards;
• Contacts with professional associations, universities, schools, human resources groups, Linkedin, Catho, etc.;
• Conferences and lectures at universities and schools;
• Contacts with other companies operating in the same market, on a basis of mutual cooperation;
• Advertisements in newspapers, magazines, websites, etc.;
• Recruitment firms (headhunters);
• Recruitment trips to other locations.

Any employee, regardless of length of service, may assist in the Selection process, when requested by those responsible for the process.

The presentation of candidates by employees shall be made via a résumé form stating the name of the person making the referral, which shall be forwarded to the People Development Management.

For candidates who have previously worked at EMFLORA, it shall be at EMFLORA's sole discretion whether or not they may take part in the recruitment and selection process, under the following conditions:

• Those dismissed for cause;
• Those who resigned or were dismissed from EMFLORA within the last 12 (twelve) months;
• Those dismissed for technical or operational inability in the same position;
• Those who displayed behavior or attitudes incompatible with EMFLORA's regulations or policies.

Former employees who left EMFLORA for the following reasons may apply for the same position or other positions at any time, provided they meet the profile required for each position:

• Reduction in the volume of activities;
• Organizational restructuring;
• Cost reduction;
• Strategic reasons approved by the Executive Board.

Persons falling under the preceding paragraph shall have preference over all others, EXCEPT internal candidates.

The company shall keep open standing recruitment for roles to be defined by process managers, based on the following criteria:

• Professionals who are hard to find in the local market;
• Specialized professionals for EMFLORA's strategic areas.

Except in the cases defined in Article 26, candidate résumés shall only be accepted for vacancies that are open or about to be opened.

All candidates, regardless of the position they are applying for, and of race, color, sex, sexual orientation, age, religion, nationality, ideology, social standing, physical disability, medical conditions, criminal record, or other characteristics protected by law, shall receive the same treatment, provided they fully meet EMFLORA's technical, operational, policy, and human requirements. Preferential treatment of candidates presented through any kind of referral or recommendation is prohibited.

When receiving any candidate who is of interest to EMFLORA, one must:

• Verify their experience through the CTPS - Employment and Social Security Record Book (Carteira de Trabalho e Previdência Social); request that those who fit the appropriate profile submit their résumés.
• After checking the candidates' information, screening interviews may be conducted to verify their professional histories, comparing them with the requirements of the positions.
• After the screening interviews, up to 05 (five) candidates best suited to fill the position shall be forwarded to personnel selection.
• If there are not enough candidates, all those capable of filling the position should be forwarded to selection.

Personnel Selection

The selection process must assess the technical knowledge, psychological condition, and health of all candidates.

For candidates to be approved during Selection, they may be subjected to the following assessments:

• Administrative interview by the HR department;
• Fit ("feeling") interview by the head of the department requesting the hire;
• Professional technical tests, where necessary;
• Psychological and/or behavioral assessment, consisting of an interview and tests;
• Medical and supplementary examinations, in accordance with the provisions of the Occupational Health and Medical Control Program (PCMSO) adopted by EMFLORA.

Professional technical tests are applied when the head of the requesting area deems them necessary. Their purpose is to verify each candidate's knowledge, enabling an orderly ranking of the candidates.

The candidates' professional technical tests must be prepared, administered, and evaluated by the coordinators of the requesting areas, or by qualified professionals appointed by them.

The purpose of the psychological and/or behavioral assessment is to analyze candidates personally, psychologically, and behaviorally, in order to understand their capacity to integrate into the organization and the work.

The psychological and/or behavioral assessment shall detect tendencies toward relationship problems, emotional and psychological issues, and behavioral preferences that could affect the employee's performance in their activities, as well as their intra- and interpersonal relationships.

In selections for leadership positions, the tests may be supplemented by specific group dynamics or other tools, at the discretion of the psychology professional.

Psychological tests and interviews are for the restricted use of the Human Resources Area and must not be forwarded or disclosed to supervisors or any other Section of EMFLORA. They shall be presented to the head of the requesting department at the time of the analysis to conclude the recruitment and selection process, and should that person later need to consult them, they must approach the Human Resources Manager and make the request.

Psychological assessments are confidential and must be stored in closed files without access by the public or by laypersons. The processing of this data complies with the LGPD and the "Privacy and Personal Data Protection" section of this manual.

At the discretion of the Human Resources Area, candidates may have access to the results of their psychological and/or behavioral assessment. When such access is granted, the employee receives feedback so that they can follow the process when undergoing training for the continuous improvement of the system.

Supervisors have the authority and responsibility for the selection and final choice of the candidates who undergo the selection process and who meet the requirements for the open position.

Where there is an open vacancy in an area in which a worker hired under a temporary or outsourced labor arrangement is performing their activities, that worker shall have preference over other candidates for permanent placement or hiring by EMFLORA, provided that the said temporary or outsourced worker is approved by the area Supervisor, through the application of the corresponding assessment and analysis of their performance.

Candidates deemed unsuited to the selected position must be kept on record for possible future opportunities.

Before each candidate's file is archived, their suitability for other open vacancies within Personnel Selection must be checked.

After the interviews and tests, supervisors must refer all candidates to the Human Resources Area for the remaining necessary steps.

The supervisor, or whoever was designated to conduct the technical (fit) interview with the candidate, must not inform them of their approval or rejection.

It is the responsibility of the Human Resources Area to communicate the assessment results to all candidates.

Candidates approved by supervisors for hiring shall be referred for examinations, for psychological and/or behavioral assessments, for medical examinations, and for the other steps relating to the documentation required for admission. For candidates approved in the selection process who are selected for hiring and present complete documentation, the Personnel department shall contact them to inform them of the hiring and provide the list of documents required for admission. Subsequently, the Hiring Authorization shall be completed and signed by Management, and the form shall then be forwarded to the personnel department, which shall proceed with referral for pre-employment examinations.

After approval by the occupational physician (pre-employment Occupational Health Certificate — ASO), the professional shall be referred to the personnel department for the assembly of their file, entry into the new-hire system, and signing of the employment contract. Both for seasonal and for temporary work, workers at EMFLORA have an employment contract signed between the parties.

The personnel department and SESTR (Occupational Safety and Nursing Department) shall put together the hiring and onboarding training schedule, as well as deliver the training needed to acclimate all newly hired employees, together with the quality and operational departments.

EMFLORA's Onboarding Training for new employees shall essentially consist of the following information about the company:

• EMFLORA's general and compliance policies;
• Occupational Medicine and Safety;
• Human Resources Policies;
• Quality Management System;
• Other matters of interest to EMFLORA.

After the Orientation Training, newly hired employees shall be referred to the requesting supervisors and/or coordinators to begin their professional activities.

Job and Salary Plan

The purpose of this plan is to remunerate the holder of each position at EMFLORA fairly and equitably, comparing the value of each position relative to the institution's other positions, with a view to internal balance, and comparing the value of each position relative to market conditions, with a view to external balance.

By establishing and/or maintaining balanced salary structures, Salary Administration seeks to achieve the following objectives:

• Remunerate each employee according to the value of the position they hold;
• Reward employees appropriately for their performance and dedication;
• Attract and retain the best talent for each position, reducing staff turnover and absenteeism rates;
• Increase the institution's flexibility by providing the appropriate means for staff mobility, streamlining opportunities for development and career progression;
• Secure employees' acceptance of the remuneration systems adopted by EMFLORA;
• Support Managers, Area Coordinators, Supervisors, and Foremen in managing their subordinates, based on well-defined remuneration criteria known to all;
• Satisfy and motivate employees in the exercise of their duties, motivating them to increase productivity, improve quality, and reduce costs;
• Maintain a balance between EMFLORA's financial interests and its employee relations policy.

To achieve the objectives set out in the first paragraph, the following actions are necessary:

• Conduct ongoing surveys of the local and regional markets regarding the salaries paid by companies and educational institutions — especially those in the same sector — for the various positions existing at EMFLORA, in order to identify discrepancies;
• Keep EMFLORA's job and salary table consistently aligned with the market and coherent with its internal structure, through systematic monitoring of positions and their respective values;
• The table of positions, salaries, and corresponding salary bands is held by the People Development Manager and the People Development Analyst.

Job descriptions were drawn up in detail, taking into account the following aspects and requirements for each position:

• Job title;
• Summary description of the work;
• Essential education required;
• Progression from one position to another.

The following aspects were considered in the preparation and structuring of the Job and Salary Table: the Knowledge, Skills, and Responsibilities of each position, in accordance with the Points System for the Job and Salary Plan.

Salary Increase Policy

Salary increases may be granted to EMFLORA employees, in addition to those that are mandatory under Law, Collective Agreements and Conventions, etc., in the following cases: Confirmation of Employment, Promotion, Internal Pay Alignment, External Pay Alignment, and Discretionary Adjustment (General Increase), under the criteria below:

CONFIRMATION OF EMPLOYMENT (EF): Upon being hired by EMFLORA, the employee shall receive the starting salary corresponding to the position they will hold, as specified in the salary table. Once the probationary period — of up to 90 days — has elapsed, and if the employee is confirmed in the position for which they were hired, they may receive a Confirmation salary increase, in accordance with the aforementioned salary table, corresponding to the job group in which their position is classified.

PROMOTION (P): At the discretion of area supervisors and coordinators, an employee may, as a result of their performance, be promoted to a higher position within the job and salary scale, where they shall undergo a trial period of no more than 90 (ninety) days. If approved in the new position, they shall be entitled to a salary increase, also in line with the said salary table, and shall begin receiving the amount established therein for the new position. It should be noted that changes of position within the same job group, or even between different job groups, do not in themselves constitute promotions. In other words, a job transfer does not necessarily entail a promotion. A promotion shall always result from moving from one position to another with a higher point score, according to the job and salary classification table, and we recommend that the interval between two promotions be no less than 6 (six) months.

MERIT ADJUSTMENT (RM): Even without a change of position, an employee may receive a merit-based salary adjustment, taking into account their performance of their duties, attendance, punctuality, length of service, productivity, self-sufficiency, initiative, contribution to meeting targets, professional knowledge, professional development, understanding of duties, workplace safety, workplace discipline, responsibility, and interpersonal skills, etc. This type of increase may only be granted after analysis of performance results.

INTERNAL PAY ALIGNMENT (EI): This type of salary adjustment shall be granted for the purpose of correcting internal distortions, with the aim of bringing the salary into the band corresponding to the employee's job group, position, and level, aligning it with the salaries of people holding similar positions, based on EMFLORA's job and salary table. These adjustments may not occur more frequently than every 3 (three) months for the same employee.

EXTERNAL PAY ALIGNMENT (EE): The purpose of this modality is to grant salary increases for positions paid below the rates of the local or regional market, allowing the company to achieve external balance and minimizing the risk of losing good employees already trained at EMFLORA. In these cases, the percentages and frequency to be applied shall be defined by need, concretely demonstrated through surveys.

DISCRETIONARY ADJUSTMENT (GENERAL INCREASE) (AG): EMFLORA may, to the extent of its means, voluntarily grant salary increases covering all of its employees without distinction, whether as an advance on, or as a supplement to, collective bargaining agreements or collective labor disputes. In this case as well, the percentages and frequency shall be defined according to need.

Whenever a salary or job change is contemplated, the head of the department of the position in question must complete and sign the salary and job change form and forward it for approval by the branch Management, after which it shall be submitted for approval by the People Development Management. (form attached).

Internal Opinion Survey

Its purpose is to give every EMFLORA employee the opportunity to express their opinion on matters related to their work. The Internal Opinion Survey allows employees to tell EMFLORA what they like or dislike, on matters that are certainly important both to EMFLORA and to the employees themselves. At EMFLORA, this survey is conducted by the General Administrative Manager, when requested.

Before any internal transfer of any staff member takes place, the General Administrative Management and the People Development Management must be notified immediately, so that the appropriate changes can be made to the respective cost centers and organizational charts, and any other necessary steps can be taken.

When any staff member is terminated, the personnel department Assistant and/or the People Development Analyst must immediately notify the person in charge of the Information Technology department by e-mail, so that the employee's access credentials to the system modules, directories, and/or network can be duly revoked.

Labor Relations

EMFLORA recognizes its employees' freedom of association and the right to collective bargaining, provided local laws are respected. We ensure full compliance with all applicable rules and regulations, whether of legal, labor, administrative, or collective-bargaining origin. As a rule, the local HR area handles, at the appropriate levels, all Labor Relations matters, with the support of labor law counsel.

With a view to the company's long-term success, EMFLORA communicates continuously with all of its employees — regardless of representation.

EMFLORA does not condone coercive practices aimed at obtaining advantages through abuse of power, inhumane or degrading treatment, corporal punishment, or harassment — whether economic, moral, sexual, racial, political, religious, or of any other kind — as previously stated.

Our Code of Conduct sets out a formal policy of warnings and graduated sanctions, agreed between the company and its employees. For any complaint regarding improper disciplinary practices, abuse of power, harassment, or discrimination against diversity and inclusion, please contact our communication channel, the Ombudsman.

The company operates in a manner that avoids the use of lodging facilities as residences for its employees, even temporarily. Should such a situation be strictly necessary and no alternative measure be possible, all legal guidelines established for the use of this type of accommodation shall be followed and implemented.

With regard to labor relations and free association with unions or workplace accident prevention committees, EMFLORA allows its employees to participate, whether by appointment, choice, or election.

Collective bargaining conventions or agreements and/or the legislation in force are followed so as to honor what has been established between the company and the trade union representing the workers, ensuring the best positioning between the parties and alignment with legal requirements and with all matters concerning labor relations within the organization.

Human Rights and Social Engagement

EMFLORA prohibits the use of forced or involuntary labor, or labor in conditions analogous to slavery. Every employee has the right to refuse to perform activities they do not feel prepared to carry out, especially in situations that pose a risk to their physical integrity. Forced or compulsory labor is defined as any service demanded under threat of penalty and for which the person performing it has not volunteered of their own free will.

In Brazil, forced or slave labor is defined by Article 149 of the Penal Code as follows: Reducing someone to a condition analogous to that of a slave, whether by subjecting them to forced labor or exhausting working hours, by subjecting them to degrading working conditions, or by restricting, by any means, their freedom of movement on account of a debt owed to the employer or the employer's agent.

Penalty — imprisonment of two to eight years, plus a fine, in addition to the penalty corresponding to any violence committed.

§ 1. The same penalties apply to anyone who: I — restricts the worker's use of any means of transportation, in order to keep them at the workplace; II — maintains overt surveillance at the workplace or seizes the worker's documents or personal belongings, in order to keep them at the workplace.

§ 2. The penalty is increased by half if the crime is committed: I — against a child or adolescent; II — out of prejudice based on race, color, ethnicity, religion, or origin.

Slave labor is not characterized by mere labor-law infractions. It is a crime against human dignity. The presence of any one of the four elements below is sufficient to constitute the exploitation of slave labor:

FORCED LABOR: the individual is compelled to submit to working conditions under which they are exploited, with no possibility of leaving the workplace, whether because of debts or because of threats and physical or psychological violence;

EXHAUSTING WORKING HOURS: grueling work schedules that go beyond overtime and endanger the worker's physical integrity, as the interval between shifts is insufficient for them to recover their energy. In some cases, the weekly rest period is not respected. As a result, the worker is also prevented from maintaining a social and family life;

DEBT BONDAGE: the fabrication of illegal debts relating to expenses for transportation, food, lodging, and work tools. These items are charged abusively and deducted from the worker's wages, keeping the worker trapped by a fraudulent debt;

DEGRADING CONDITIONS: a set of irregular elements that characterize the precariousness of the work and of the living conditions to which the worker is subjected, in violation of their dignity.

EMFLORA combats the sexual exploitation of children and adolescents and encourages the use of the Dial 100 hotline. The Human Rights Hotline (Disque 100), coordinated by the Ministry of Human Rights and Citizenship (MDHC) through the National Human Rights Ombudsman, is the main channel of communication with society. It is a free telephone service created to receive reports and complaints about human rights violations, especially those affecting the most vulnerable populations.

The service operates 24 hours a day, including Saturdays, Sundays, and holidays. Calls can be made from any telephone (landline or mobile) by directly dialing the number 100.

Reports may be anonymous, and the confidentiality of the information is guaranteed when requested by the caller. Reports received via Dial 100 are forwarded, within a maximum of 24 hours, to the competent authorities for investigation of responsibility.

For us at EMFLORA, the sexual exploitation of children and adolescents is unacceptable, as we believe that the care of children and adolescents must be an absolute priority and is the responsibility of the State, society, and families. We note that each report may describe more than one type of violation.

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Introduction

The purpose of this manual is to provide Emflora employees with knowledge of OHS requirements and to instruct them to perform their duties in the safest manner possible, thereby ensuring adequate safety conditions for personnel, equipment, and operations.

Accordingly, the manual establishes five basic aspects as guidelines, namely:

1. Professionals at the leadership level are responsible for supervising work areas with a view to preventing accidents;
2. All activities must be carried out under safe conditions, which include hazard identification, risk assessment, and determination of controls;
3. The immediate supervisor is responsible for encouraging employees to act in accordance with the requirements of documented procedures, as well as applicable regulatory requirements;
4. Emflora provides its employees with adequate operating conditions, including equipment, tools, materials, and PPE;
5. All activities are systematically planned and evidenced through documented procedures and/or the Preventive Risk Analysis (APR), which highlight occupational health and safety aspects.

EMFLORA forestry enterprises

Emflora is a company that develops Forest Management and Applied Technology projects in Silviculture.

Founded in 1991, Emflora has demonstrated, over the years, a capacity for innovation and sustained growth, thanks to its permanent and determined pursuit of full customer satisfaction.

With 2,600 employees (June/2026), Emflora is present in nine Brazilian states. Partnerships and strategic agreements entered into with companies from various sectors — Pulp & Paper (Suzano, Bracell, Klabin), Wood Panels (Placas do Brasil), Mining, Metals & Energy (Vale, Gerdau, Vallourec), Bioenergy & Renewable Fuels (Acelen, Infiniti Agro), and Carbon & Assets (Mombak, Manulife, Biomas) — have enabled the development of new lines of work. Today, in addition to the forestry segment, the company also offers a diversified portfolio in the areas of forest logistics, carbon credits, aerial application, and facilities.

The entrepreneurial spirit and background of the company's senior management, the experience of its managers and directors — proven over more than 50 years of work in the sector — a complete technical team composed of forestry, electrical, civil, and safety engineers, physicians, and mid-level technicians from various fields, highly skilled staff managing the administrative areas such as lawyers, administrators, and accountants, and a valuable team of employees ready to overcome challenges that are not always easy to surmount all contribute to significant improvements in the company's efficiency, the quality of its products and services, and, consequently, the trust of customers and suppliers.

General Requirements

Senior management hereby determines the certification scope of the Occupational Health and Safety Management System, established on the basis of the ISO 45001:2018 standard, as: Afforestation, Reforestation, and Forest Maintenance.

Emflora holds triple ISO certification: ISO 9001:2015 (Quality Management System), ISO 45001:2018 (Occupational Health and Safety Management System), and ISO 14001:2015 (Environmental Management System).

Integrated Policy

EMFLORA develops forest management and applied technology in silviculture, as well as solutions in forest logistics, carbon credits, aerial application, vegetation clearing, recovery of degraded areas, and facilities, guided by ethical and professional principles, and is committed to:

• Working in partnership with stakeholders, procuring products and delivering quality services that meet customers' needs;
• Planning and implementing actions in compliance with applicable requirements, integrating occupational health and safety, quality, and environmental matters into its activities as a way of adding value to the company's business;
• Developing employees by enhancing their skills and experience in pursuit of best practices;
• Ensuring the well-being of employees by providing healthy and safe workplaces and working conditions aimed at preventing occupational injuries and illnesses;
• Identifying, assessing, and managing the risks and opportunities that affect the business, systematically measuring and monitoring the organization's production processes, with a focus on: pollution prevention, elimination of accidents, risk control, implementation of opportunities, reduction of potential environmental impacts, and the rational use of natural resources;
• Continuously conveying to employees that everyone's cooperation is essential for the elements of this Policy to be applied in EMFLORA's day-to-day operations, with the aim of continual improvement.

Planning

Hazard identification and risk assessment

Emflora uses procedure NP/SSO 004 – Survey and Assessment of Aspects/Impacts and Hazards/Risks to identify the risks related to its activities, procured products, and services that can be controlled and over which it is presumed to have direct or indirect influence, in order to determine those that have or may have significant impacts on the progress of the process.

The survey carried out is presented in accordance with NP/SSO-004 – Survey and Assessment of Aspects/Impacts and Hazards/Risks.

Changes may be identified at any time, with control actions implemented by Emflora as described in NP/SSO 002 - Change Management.

Legal and other requirements

The legal and other requirements applicable to Emflora are identified, controlled, and reviewed with a view to compliance, as described in NP/SSO 005 – Identification and Assessment of Compliance with Legal and Other Requirements.

Information regarding legal and other requirements is available in the ProSig System.

Objectives and programs

The objectives, targets, and programs related to the Occupational Health and Safety Management System were established by Emflora in NP/SSO-015.

The IMS Committee is responsible for monitoring the fulfillment of objectives and targets during the IMS management reviews and throughout the year, seeking to ensure that the established targets are achieved.

Implementation and Operation

Resources, roles, responsibility, accountability

Emflora has established roles, responsibilities, and authorities in MDF-001 - Job Description Manual. Emflora's senior management has defined the main duties and responsibilities, taking into account the aspects related to this management, as presented below.

a) Contract Manager

• Size the Specialized Rural Occupational Health and Safety Service (SESTR) in accordance with legal and contractual requirements or Emflora's needs;
• Provide an Internal Commission for the Prevention of Accidents and Harassment in Rural Work (CIPATR) in accordance with the applicable legislation;
• Make available the technical, human, and financial resources needed to carry out the SESTR Work Plan;
• Monitor the implementation and/or change of controls considering risk reduction according to the following hierarchy: elimination, substitution, engineering controls, signage/warnings and/or administrative controls, personal protective equipment;
• Hold meetings with or with the participation of SESTR representatives;
• Seek guidance and advice from Emflora's SESTR professionals and/or its Corporate OHS team.

b) Supervisors, Technicians, and Coordinators

• Analyze the work to be carried out, planning at each stage, together with the SESTR, the general protective measures required. Preventive Risk Analysis (APR), communicated to their employees;
• Establish and ensure the use of the PPE and CPE necessary for carrying out tasks;
• Take note of the issues reported by the SESTR and CIPATR, providing conditions for the development of the necessary measures;
• Participate in and facilitate the participation of their team members in the training sessions and prevention campaigns conducted at the company;
• Participate in safety meetings and, whenever possible, in the CIPATR;
• Analyze and weigh general health and safety aspects.

c) Work Front Leaders

• Analyze the tasks to be performed, planning and adopting the general and specific protective measures indicated by the Supervision and the SESTR;
• Conduct the Safety Talk at the start of each shift or at the beginning of a new field task;
• Use and supervise the correct use of PPE and CPE;
• Neutralize or minimize unsafe conditions existing at the work fronts;
• Take note of the issues reported by the SESTR and CIPATR, adopting the appropriate corrective measures;
• Participate in and facilitate the participation of their team members in the training sessions and prevention campaigns conducted at the company;
• Record and report each and every work incident;
• Accompany the SESTR during investigations of incidents that have occurred;
• Provide prompt assistance to victims of work accidents.

d) Employees in general

• Correctly use the PPE and CPE provided by Emflora, in accordance with the guidance of the SESTR, CIPATR, and their immediate superiors;
• Minimize observed unsafe conditions or report them to their immediate superior;
• Take care of the materials, equipment, tools, and utensils used;
• Take care of shared-use facilities;
• Report, as promptly as possible, each and every incident that occurs;
• Comply with the procedures, standards, orders, and general safety rules of Emflora and of the client to which it provides services;
• Take part in OHS best practices;
• Support the development and application of OHS Programs;
• Participate, whenever requested, in surveys of the hazards and risks inherent to their activities and tasks.

e) Specialized Rural Occupational Safety Engineering and Medicine Service (SESTR)

• Study, together with the areas involved, the possible means of neutralizing or reducing the existing risks of accidents/illnesses, recommending PPE, CPE, and appropriate preventive measures;
• Develop and evaluate the outcomes of general and specific training in occupational safety, hygiene, and medicine and environmental protection;
• Investigate incidents that have occurred together with the person responsible for the task, addressing the measures necessary to prevent the recurrence of similar events;
• Advise and support the CIPATR;
• Present reports on incident and occupational health statistics;
• Observe, comply with, and recommend compliance with legal and contractual obligations related to the area;
• Develop and implement hygiene programs, with systematic inspections.

Competence and training

Emflora employees receive safety onboarding and other training, guidance, and talks on health, the environment, and occupational safety, aimed at ensuring that their activities are performed safely and preventing work accidents. For human resources management, Emflora uses NP/RH 001 – Human Resources Management.

Communication, participation, and consultation

The purpose of the communication process is to disclose to stakeholders the actions taken by the organization, as well as relevant facts associated with processes and/or new technologies.

The channels used for dissemination are: Routine Meetings, Safety/Health Alerts, Safety Talks.

Communication activities include:

1. Communication conducted by management in work areas;
2. Informal meetings and team meetings, such as those for recognizing achievements;
3. Notice boards and alerts (safety/health);
4. Electronic and audiovisual communication media, such as e-mail and Internet pages;
5. Campaigns.

Emflora uses its institutional website for dialogue with the community, available at: www.emflora.com.br

Documentation

The documents that make up Emflora's Occupational Health and Safety Management System are:

• manual;
• procedures;
• forms;
• records; and
• documents of external origin.

The issuance, approval, dissemination, revision, and control of Emflora's documents are carried out as described in NP/SIG 002 - Document and Record Control.

NP/SIG 002 - Document and Record Control covers the control of the following documents: manual; procedures; forms; and documents of external origin.

Operational control

Emflora, consistent with the risks identified and assessed, has defined procedures aimed at establishing the controls necessary to minimize risks, namely:

• NP/COP 001 - Corrective/Preventive Maintenance;
• NP/COP-003 - Black Smoke Emission Monitoring with Opacimeter;
• NP/COP-004 - Tractor and Implement Lubrication Plan;
• NP/COP-005 – Chainsaw/Brush Cutter Preventive Maintenance Plan;
• NP/SSO-001 - Air Conditioner Maintenance, Operation, and Control Plan;
• NP/SSO-003 - Safety Talk;
• NP/SSO-009 - Waste Master Plan;
• NP/SSO-010 - Behavioral Audit;
• NP/SSO-012 - Drinking Fountain Cleaning Procedure;
• NP/SSO-013 - Sun Exposure Prevention;
• NP/SSO-017 – Thermal Bottle and Hotbox Container Cleaning Procedure;
• NP/SSO-018 – Supplier Management;
• NP/SSO-019 – Work at Height; and
• MSSO-E/00 - Safety Manual.

Operational activities are carried out by Emflora as described in NP/SSO-007 - Preliminary Risk Analysis – APR.

Emergency preparedness and response

Potential emergency situations are identified and described in NP/SSO 008 - Linked Contingency and Emergency Control Plan.

Emflora conducts drills as planned and, after the drills, the results are analyzed and the necessary actions are implemented, as described in NP/SSO 008 - Linked Contingency and Emergency Control Plan.

Monitoring and Measurement

Performance monitoring and measurement

Measurements of the processes within the certification scope are performed through the indicators in NP/SSO-014 – Occupational Health and Safety System Indicators and NP/SSO-015 OHS Objectives, Targets, and Programs.

All equipment used to monitor health- and safety-related conditions is controlled and calibrated in accordance with NP/SSO 011 - Control of Measuring and Monitoring Equipment.

Compliance evaluation

The applicable legal and other requirements have been evaluated by Emflora for compliance, with this information available in the Applicable Legislation Control, as described in NP/SSO 005 – Identification and Assessment of Compliance with Legal and Other Requirements.

Incident investigation, nonconformity, corrective and preventive action

Incident investigations may be identified and described in accordance with NP/SSO-016 – Incident Investigation.

Corrective and preventive actions may be identified at any time, and they are recorded and handled as described in NP/SIG 008 - Corrective Action and Preventive Action.

Record control

Emflora controls the records generated in the course of its activities as described in NP/SIG 002 - Document and Record Control.

Records kept in electronic form are protected through backups performed as described in procedure NP/SIG – 009 – Control, Validation, Distribution, Access, and Protection of the Computerized System.

Internal audit

Emflora periodically conducts internal audits of the Occupational Health and Safety Management System, as described in NP/SIG-005 Internal Audit.

The audits are planned, conducted by qualified auditors — who may be internal and/or contracted — and duly recorded.

Management Review

The management review is conducted annually by Emflora. The minimum agenda of the meeting includes the following items:

1. Results of internal audits and of evaluations of compliance with applicable legal requirements and other requirements to which the organization subscribes;
2. Results of participation and consultation;
3. Relevant communication from external stakeholders, including complaints;
4. OHS performance;
5. The extent to which objectives have been met;
6. Status of incident investigations, corrective actions, and preventive actions;
7. Follow-up actions from previous management reviews;
8. Changing circumstances, including developments in legal and other requirements related to OHS;
9. Recommendations for improvement.

The outputs of the management reviews are based on decisions and analyses, which must be consistent with Emflora's commitment to continual improvement, and must include any decisions and actions related to possible changes:

1. In OHS performance;
2. In the OHS policy and objectives;
3. In resources;
4. In other elements of the OHS management system.

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Objectives

The exchange of gifts and entertainment can strengthen business relationships, but some gifts and entertainment may create improper influence (or the appearance of improper influence). Some may even be viewed as bribes, capable of tarnishing Emflora's reputation as a Company that adopts legitimate business practices, or may even constitute a violation of the law.

This procedure complements the relevant provisions of the Code of Conduct and the Anti-Corruption Policy and, in essence, seeks to provide further guidance to Emflora employees regarding (i) the types of gifts and entertainment we may offer or receive, and (ii) the conditions under which we may offer or accept them.

The Compliance Committee is permitted to adopt stricter procedures when it deems them appropriate based on a risk assessment. The main roles and responsibilities under this procedure can be summarized in the table below:

"Gifts and Entertainment" means anything of value, including (among other things) loans, favors or discounts on any product or service, the provision of services, prizes, transportation, use of another company's vehicle, use of vacation facilities, shares or other securities, participation in stock offerings, home improvements, event tickets, gift vouchers, lunches, dinners, and events of any kind.

Gifts and entertainment may raise issues of an ethical nature and of compliance with anti-corruption rules, in both the private and public sectors.

However, Emflora employees must be especially cautious when offering gifts to public officials. This procedure prohibits offering anything of value to public officials; it is important to ensure that gifts and entertainment offered to public officials cannot be construed as bribes.

In addition, public officials are generally prohibited by law from accepting gifts or entertainment. Therefore, offering gifts or entertainment may put them in an uncomfortable position. For these reasons, this procedure establishes stricter rules regarding gifts and entertainment offered to public officials.

Guidelines for gifts and entertainment involving EMFLORA employees or employees of other private companies

Gifts and Entertainment are divided into three categories:

1. those that are usually acceptable and that you may approve yourself;
2. those that are never acceptable;
3. in case of doubt, they may be referred to the Compliance Committee and the Legal Department for approval.

In case of doubt, the Compliance Committee must be copied on any approval. When reviewing the approval request for "always unacceptable" gifts and entertainment, the Emflora manager or immediate superior, as applicable, will apply criteria similar to those described in the "self-approval test," which is set out below.

With regard to entertainment and other events, the invitation should, whenever possible, be addressed to the Company, kindly asking the invited Company to send a representative of its choice. When the invitation is addressed to a specific individual, the invitation should ask that individual to inform their management about the invitation.

In case of doubt, the matter should be referred to the responsible Compliance Officer or to the Legal Department.

Guidelines for gifts and entertainment offered to public officials

Who is a "Public Official"? The term "public official" is very broad. It includes all officials, at any level, of a government body or agency, in any of the three Branches of government.

Directors and employees of companies owned or controlled by the government are also considered "public officials." Thus, the term includes not only individuals such as elected politicians, civil servants in government procurement, and customs, environmental, or tax inspectors, etc., but also employees of state-owned or state-controlled companies.

In case of doubt, and for gifts and entertainment not covered by this Procedure, the matter should be referred to the responsible Compliance Committee or to the Legal Department.

Any gift in cash or cash equivalents is an example of an unacceptable gift.

Documentation

All records related to gifts and entertainment, especially when pre-approval is required, must be accurate and include supporting documentation confirming the proper, good-faith business purpose.

Pre-approvals must be given in writing, and the records must be provided to the accounting department for proper recordkeeping. The Compliance Committee is entitled to access any document related to this procedure for monitoring purposes.

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Purpose

The purpose of this Whistleblowing Policy is to identify, as quickly as possible, any relevant problems related to irregularities in accounting, monitoring and investigation, financial, or bribery matters.

Scope

This Whistleblowing Policy is intended to receive reports of possible irregularities in accounting, investigative, financial, or bribery matters in Emflora's business, and does not apply to commercial complaints, product-related issues, or individual labor grievances.

Principles

1. Reports

If any employee of Emflora or its subsidiaries has any concern about conduct that may fall within the scope of this Whistleblowing Policy, they should report it to their immediate supervisor, a member of management, the head of the legal department, or the Compliance Committee.

However, if the employee does not feel comfortable reporting to one of the persons mentioned above, they may do so through the whistleblowing channel described below. Reports may be made:

2. Handling of Reports

Reports received will be immediately forwarded to Emflora's Compliance Committee. Any reports not related to accounting, monitoring and investigation, financial, or bribery matters will not be considered, unless they relate to serious facts, such as facts that affect Emflora's business and fundamental interests, or the integrity and physical or moral well-being of its employees.

In cases where there is a legal obligation to communicate the information to the public authorities responsible for criminal proceedings, Monitoring and Investigation will instruct the Legal Department to forward the report to the competent authority. If the report falls within the scope of this Whistleblowing Policy, the Compliance Committee will engage the Monitoring and Investigation unit to conduct an investigation.

The Internal Monitoring and Investigation unit will immediately inform any employee allegedly involved in an accounting, investigation and monitoring, financial, or bribery matter of the facts alleged against them, as well as how they may access the information and, where applicable, correct it. Such communication may be postponed for as long as deemed necessary to protect any evidence-gathering procedures.

All reports will be reviewed as quickly as possible, taking into account their nature and complexity.

3. Investigation Outcomes

All reports made under the Whistleblowing Policy will be entered into a list to be discussed at the next meeting of the Investigation and Monitoring unit. All investigation outcomes will be recorded by the head of the Investigation and Monitoring unit.

The Investigation and Monitoring unit will decide on the next steps, taking into account the outcome of the investigations, and may deepen the investigations or make recommendations to the Compliance Committee regarding procedural improvements or corrective measures.

4. Feedback

The employee who made the report will receive a response regarding how their report was handled, and will be informed whether any corrective measure or procedural improvement has been recommended and whether any additional action will be taken.

Details concerning specific individuals will not be disclosed, and the feedback may be generic, taking into account Emflora's interest in protecting its confidential information, as well as the rights of third parties.

5. Confidentiality

Reports will be disclosed only to employees who need to know the information for investigation purposes.

All employees involved in the Whistleblowing Policy will maintain strict confidentiality regarding the content of any reports made, in accordance with applicable laws.

Any disclosure of reports or investigation results must be authorized by the Investigation and Monitoring unit or by Emflora's Compliance Committee.

6. Non-Retaliation

Emflora will take the necessary measures to protect employees who, in good faith, make reports under the Whistleblowing Policy against any retaliation by managers or other parties involved.

7. Document Retention

Investigation and Monitoring will keep a record of all reports, with information about their receipt, investigation, and resolution. Statistical data on the types of reports received and corrective measures taken will be retained for at least 5 years from the conclusion of the investigation, unless otherwise required by local laws.

Information relating to facts found to be unsubstantiated will be deleted immediately. Information relating to a substantiated report will be deleted within two months of the conclusion of the investigations, unless disciplinary proceedings or legal action are initiated against the person named in the report or against the author of an abusive report.

Any employee has the right to access and, where applicable, correct their personal data, including any information available in the report records, and may do so by contacting the Legal Department. However, the name of the person who made the report will not be communicated by Emflora to the accused.

The processing of personal data related to whistleblowing reports complies with the LGPD and the "Privacy and Personal Data Protection" section of this manual.

Emflora values transparency. Do your part:

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