Integrated Policies

The Integrated Policies gathered in this document are instrumental rules subordinate to GRICCO's Code of Ethics and Conduct (GRICCO-GOV-001), which prevails as the parent rule of the Integrity System. In the event of any divergence of interpretation, the provisions of the Code of Ethics and Conduct shall prevail. Detailed operating procedures are set out in the Internal Regulations, in the Data Protection Manual and in the other instrumental documents of the Integrated Management System.

These Policies are declaratory in nature and express GRICCO's public commitment to its fundamental principles. Compliance with them is mandatory for all employees, service providers, suppliers, partners and other members of the GRICCO ecosystem.

GRICCO Soluções Integradas, a company specializing in the provision of Quality, Health, Safety and Environment (QHSE), compliance and Management System solutions for the maritime, shipping, oil & gas and port-chain industries, within the scope of its project management, training and supply of specialized technical teams, undertakes to:

• Provide high-quality services, solutions and training, focused on simplicity, efficiency and the generation of measurable value for clients.
• Establish, monitor and continually review measurable QHSE objectives, with specific key performance indicators (KPIs), aiming at the continual improvement of the Integrated Management System, in accordance with clause 5.2 of ISO 9001:2015, clause 5.2 of ISO 14001:2015 and clause 5.2 of ISO 45001:2018.
• Strictly comply with the legal, regulatory and contractual requirements applicable to our operations and to those of our clients, in particular: NORMAM (Brazilian Maritime Authority Standards — Brazilian Navy), the regulations of the ANP (Brazilian National Agency of Petroleum, Natural Gas and Biofuels), IBAMA standards, NR-30 (waterway work), NR-37 (safety on offshore platforms), MARPOL, SOLAS and MLC 2006, as well as the expectations of interested parties.
• Promote a safe and healthy working environment, preventing injuries, occupational illnesses and psychosocial risks, through hazard identification, risk assessment and the implementation of effective controls, in line with ISO 45001:2018 and ISO 45003:2021.
• Consult employees and their representatives and encourage their active participation in matters related to occupational health and safety.
• Protect the environment, prevent pollution and promote the sustainable use of resources in our operations and in the services provided to clients.
• Eliminate hazards and reduce occupational health and safety risks, taking into account the organizational context and the nature of our activities, applying the principles of ISO 31000:2018 (Risk Management).
• Prioritize client satisfaction, understanding their needs and exceeding their expectations through customized and efficient solutions.
• Foster an organizational culture based on our values: focus on what is essential, simplicity, honesty, integrity, ethics, trust, creativity, initiative, excellence, humility, environmental sustainability, diversity and inclusion.
• Invest in the continual development of our employees, promoting competencies aligned with QHSE best practices.

The scope of this Policy covers all units, processes and activities of GRICCO Soluções Integradas. This Policy shall be communicated, implemented and maintained at all levels of the company, made available to all interested parties and reviewed periodically to ensure its continued suitability to the purpose and context of our organization. The operating procedures that give effect to this Policy are contained in the Integrated Management System (IMS) and in the Internal Regulations.

GRICCO recognizes that smoking and exposure to second-hand smoke pose serious risks to the health, safety and well-being of our employees, clients and visitors. Aware of these hazards, we establish the following policy:

• Smoking is prohibited in all indoor GRICCO facilities, including offices, meeting rooms, corridors and restrooms.
• The prohibition extends to all types of smoking products, including electronic cigarettes and similar devices.
• Smoking is not permitted in company vehicles or in outdoor areas near the entrances, windows or ventilation systems of GRICCO buildings.
• The company will not provide designated smoking areas on its premises.
• This policy applies to all GRICCO employees, contractors, clients and visitors.
• GRICCO undertakes to support employees who wish to stop smoking by providing information on smoking-cessation programs.
• Failure to comply with this policy will result in disciplinary action in accordance with the company's internal rules, as provided in the Sanctions Matrix of the Code of Ethics and Conduct.

GRICCO is committed to providing a healthy and safe working environment for everyone. We count on everyone's cooperation and respect in complying with this policy. We undertake to communicate, implement and maintain this policy at all levels of the company and to make it available to all interested parties.

GRICCO is committed to providing a safe, healthy and productive working environment for all its employees, clients and partners. We recognize that the use of drugs and alcohol may adversely affect performance, operational safety and well-being, with a particularly critical impact in offshore environments, on oil platforms and aboard vessels, where our employees work. We establish the following policy:

• The use, possession, distribution or sale of illicit drugs on GRICCO premises or during the performance of work-related activities, including aboard vessels, on platforms and at other client facilities, is strictly prohibited.
• The consumption of alcohol is prohibited during working hours, including breaks, or while operating company or client vehicles, vessels or equipment.
• Reporting for work under the influence of drugs or alcohol is expressly prohibited and will result in disciplinary action.
• GRICCO may conduct drug and alcohol testing in circumstances justified by operational and psychosocial safety, particularly on account of work in maritime, offshore and port environments, in accordance with the protocol set out in the Internal Regulations (authorized circumstances, qualified professional, chain of custody, right to contest the result and treatment of results as sensitive personal data pursuant to Art. 11, II, 'a' of the LGPD).
• Prescribed medications that may affect performance at work must be reported to the immediate supervisor or to the Human Resources department.
• The company offers confidential support to employees who voluntarily seek help for problems related to the use of drugs or alcohol.
• Failure to comply with this policy is subject to the disciplinary measures provided in the Sanctions Matrix of the Code of Ethics and Conduct, which may include termination of the employment contract.
• GRICCO undertakes to provide training and information on the risks associated with the use of drugs and alcohol in the workplace.

This policy applies to all GRICCO employees and contractors. The operating procedures for testing, grounded in the safety of maritime, offshore and port operations, are detailed in the Internal Regulations. We count on everyone's commitment to maintaining a safe and healthy working environment.

GRICCO is committed to providing a respectful, inclusive and psychologically safe working environment for everyone. We do not tolerate any form of harassment or discrimination in our operations.

Purpose

To establish clear guidelines to prevent, identify and combat any form of harassment or discrimination in the workplace, and to promote the psychological safety of all employees. This policy applies to all GRICCO employees, contractors and partners, at all hierarchical levels and workplaces.

Definitions

• Harassment: any unwelcome conduct that creates an intimidating, hostile or offensive environment.
• Discrimination: unfair or prejudicial treatment based on personal characteristics protected by law.
• Psychological Safety: an environment in which individuals feel safe to express ideas, opinions and concerns without fear of retaliation or humiliation.

Prohibitions

Any form of harassment or discrimination based on race, color, religion, gender, sexual orientation, gender identity, nationality, age, disability or any other characteristic protected by law is strictly prohibited.

Responsibilities

All employees must treat one another with respect and dignity. Managers have the additional responsibility of preventing and promptly responding to any reported incidents, and of promoting a psychologically safe environment.

Promotion of Psychological Safety

We encourage the expression of diverse ideas and opinions. We value constructive feedback and open communication. We promote a learning culture in which honest mistakes are seen as opportunities for growth.

Reporting Procedure

Anyone who witnesses or is the victim of harassment, discrimination or situations that compromise psychological safety must report it immediately to their direct supervisor, to HR or to the confidential Ethics Channel. The detailed investigation procedures are set out in the Code of Ethics and in the Internal Regulations.

Investigation and Corrective Action

All reports will be investigated promptly and confidentially. Appropriate disciplinary measures will be taken when necessary, in accordance with the Sanctions Matrix of the Code of Ethics and Conduct.

Protection against Retaliation

GRICCO prohibits any form of retaliation against individuals who, in good faith, report violations of this policy or take part in investigations.

Training and Awareness

The company will provide training on the prevention of harassment and discrimination and on the promotion of psychological safety to all employees, at least twice a year, observing the principles of Law 14,457/2022 (Brazil) and of ILO Convention 190, promulgated by Brazil in 2024. An Internal Commission for Accident and Harassment Prevention (CIPA+A) will be set up once the legal thresholds that make it mandatory are reached. The preventive measures and the operation of the channel are detailed in the Code of Ethics and Conduct.

Assessment and Continual Improvement

We will carry out periodic assessments of the organizational climate to measure and improve the levels of psychological safety in our company.

GRICCO, in accordance with its Integrated QHSE Policy, establishes the following Stop-Work Authority policy, setting out the right and duty to stop work:

Purpose

To ensure that all employees and persons associated with GRICCO have the right and the duty to stop any work or activity that poses an imminent risk to safety, health or the environment.

Scope

This policy applies to all employees, contractors, subcontractors, visitors and any person performing activities on behalf of GRICCO or at its facilities.

Right and Duty to Stop Work

Everyone has the right and the duty to immediately stop any work or activity upon identifying a situation that poses a risk to safety, health or the environment. Work must be stopped in a safe manner, without creating additional risks.

Stop-Work Procedure

Upon identifying a risk situation, the individual must:

• Immediately stop the activity in a safe manner.
• Report the situation to the immediate supervisor or to the person responsible for the area.
• Isolate the risk area, if it is possible and safe to do so.
• Remain on site until the situation has been assessed by qualified personnel.

Non-Retaliation

GRICCO guarantees that no employee or associated person will suffer any form of retaliation or punishment for exercising their right and duty to stop work in risk situations. All work stoppages will be taken seriously and properly investigated.

Resumption of Work

Work may only be resumed after a full assessment of the situation by qualified personnel and the implementation of the necessary corrective measures. Authorization to resume must be formally given by the person responsible for the area or by a higher hierarchical level.

Responsibility

It is everyone's responsibility to know, understand and comply with this policy. GRICCO's leadership has the duty to actively promote and support this policy.

GRICCO reaffirms its commitment to safety, health and the preservation of the environment, recognizing that the right and duty to stop work is fundamental to maintaining a safe and risk-free working environment.

GRICCO, as a company committed to ethics and human rights, recognizes the crucial importance of combating forced labor and child labor in all their forms. This policy reflects our unwavering commitment to fair and ethical labor practices, aligned with national and international law and with the fundamental principles of human rights.

Purpose

To establish clear guidelines to prevent, identify and combat any form of forced or child labor in our operations and supply chain. This policy applies to all GRICCO employees, suppliers, subcontractors and business partners, in every location where we operate.

Definitions

• Forced Labor: any form of forced or compulsory labor, or labor in conditions analogous to slavery.
• Child Labor: the employment of children in violation of the conventions of the International Labour Organization (ILO) and local legislation.

Commitments

• Absolute prohibition of forced and child labor in our operations and supply chain.
• Strict compliance with applicable labor and human-rights laws, including the Maritime Labour Convention (MLC 2006), promulgated in Brazil by Decree 10,671/2021, where applicable to operations on board.
• Regular due diligence on our supply chain, including consultation of the Brazilian Register of Employers that have subjected workers to conditions analogous to slavery.
• Training and awareness-raising for employees and partners.

Preventive Measures

• Periodic audits of our facilities and suppliers.
• Specific contractual clauses with suppliers prohibiting forced and child labor.
• Supplier assessment and qualification program.

Reporting Procedure

Any suspected violation must be reported immediately through the company's confidential Ethics Channel, in accordance with the procedure set out in the Code of Ethics and in the Internal Regulations.

Consequences

GRICCO reserves the right to terminate business relationships with any entity that violates this policy.

Commitment to Education

Support for educational and professional development programs for young people in vulnerable communities.

GRICCO is committed to being an agent of positive change, promoting decent working conditions and protecting the fundamental rights of all individuals within our sphere of influence.

GRICCO, committed to the privacy and security of the personal data of its clients, employees and partners, establishes this Data Protection Policy in accordance with the Brazilian General Data Protection Law (LGPD) — Law 13,709/2018. This policy reflects our commitment to ensuring transparency, security and compliance in the processing of personal data, respecting the privacy and rights of data subjects in all our operations.

Purpose

To establish clear guidelines for the processing of personal data, ensuring compliance with the LGPD and protecting the rights of data subjects. This policy applies to all personal data processed by GRICCO, including data relating to clients, employees, suppliers and business partners. The operating procedures, processing inventory, retention periods, incident protocols and other executive aspects are detailed in GRICCO's Data Protection Manual.

Data Processing Principles

• Purpose: processing for legitimate, specific purposes made known to the data subject.
• Adequacy: compatibility of the processing with the purposes made known.
• Necessity: limitation of the processing to the minimum necessary to achieve its purposes.
• Free access: guarantee of easy consultation by data subjects regarding the processing.
• Data quality: guarantee of the accuracy, clarity and currency of the data.
• Transparency: clear and accessible information about the processing and the processing agents.
• Security: technical and administrative measures to protect the data.
• Prevention: adoption of measures to prevent harm to data subjects.
• Non-discrimination: prohibition of processing for discriminatory purposes.
• Accountability: demonstration of the adoption of effective measures.

Declaratory Commitments

• To ensure that any international transfer of personal data is carried out in strict compliance with the LGPD, guaranteeing an adequate level of protection.
• To immediately notify the ANPD and the affected data subjects of any data security incident that may give rise to relevant risk or harm, pursuant to Art. 48 of the LGPD.
• To investigate and mitigate the effects of incidents, implementing measures to prevent future occurrences.

Rights of Data Subjects

GRICCO guarantees data subjects the rights provided in Art. 18 of the LGPD, including confirmation of the existence of processing, access, correction, anonymization, blocking or deletion, portability, information on data sharing and withdrawal of consent. Requests are answered by the Data Protection Officer (DPO) within the statutory time limits.

Security Measures

• Implementation of strict access controls.
• Encryption of sensitive data.
• Periodic security audits.
• Regular employee training on data protection.

Data Protection Officer (DPO)

GRICCO formally designates, in compliance with Art. 41 of Law 13,709/2018:

• Data Protection Officer: formally designated by GRICCO (contact details below).
• Contact: dpo@gricco.com.br | compliance@gricco.com.br.
• Public contact channel: www.gricco.com.br/privacidade.

The DPO is responsible for: receiving complaints and communications from data subjects; providing clarifications and taking action; receiving communications from the Brazilian National Data Protection Authority (ANPD); guiding employees and contractors on data protection practices; and the other duties set out in the Data Protection Manual.

GRICCO, committed to the highest standards of ethics and integrity, establishes this Anti-Corruption and Business Integrity Policy to reaffirm our commitment to ethical and transparent conduct in all our operations. This policy aims not only to comply with applicable national and international legislation, but also to promote a culture of integrity at all levels of our organization.

Hierarchy of Rules

This Policy is an instrumental rule subordinate to GRICCO's Code of Ethics and Conduct (GRICCO-GOV-001), which prevails as the parent rule. The operating parameters — including, but not limited to, limits for gifts and hospitality, the approval flow for donations, and the Ethics Channel procedures — are those established in the Code of Ethics. In the event of any divergence of interpretation, the guidelines of the Code of Ethics shall prevail.

Purpose

To establish clear guidelines to prevent, detect and remedy corruption, bribery and other unethical conduct, ensuring compliance with applicable national and international laws. This policy applies to all employees, officers, business partners, suppliers and any third parties acting on behalf of GRICCO, both in Brazil and abroad.

Applicable Legislation

• Brazilian Anti-Corruption Law (Law 12,846/2013 (Brazil)) and its implementing regulation (Decree 11,129/2022).
• United States Foreign Corrupt Practices Act (FCPA).
• United Kingdom Bribery Act 2010 (UK Bribery Act 2010).
• United Nations Convention against Corruption (Decree 5,687/2006).
• Other anti-corruption laws applicable in the countries where we operate.

Main Guidelines

Prohibition of Bribery and Corruption: it is strictly prohibited to offer, promise, give or authorize the delivery of anything of value or any undue advantage to any person, especially public officials, with the intent of influencing decisions or obtaining undue advantages.

Facilitation Payments: facilitation payments are prohibited, even where permitted in some jurisdictions.

Gifts, Hospitality and Entertainment: these must be reasonable, offered in good faith and in accordance with the parameters established in GRICCO's Code of Ethics and Conduct, which sets out the limits, approval flows and cases of absolute prohibition. Under no circumstances may they be offered or accepted with the intent — or the appearance — of influencing business decisions or obtaining favors, information or preferential treatment.

Donations and Sponsorships: these must be transparent, documented and in accordance with applicable law and with the Code of Ethics and Conduct. They must not be used as a means of obtaining undue advantages.

Political Contributions: political contributions on behalf of the company are prohibited.

Relationships with Third Parties: mandatory due diligence before engaging third parties, in accordance with the procedure set out in the Code of Ethics and Conduct (Annex 1 — Ethical Risk Checklist). Anti-corruption clauses in all contracts.

Accounting and Financial Records: maintenance of accurate and transparent records of all transactions.

Conflict of Interest

A conflict of interest arises when an individual or organization is involved in multiple interests, one of which could corrupt, or be perceived as corrupting, the motivation for an act in another. All GRICCO employees, officers and business partners must avoid situations that may give rise to actual, potential or perceived conflicts of interest.

It is each individual's responsibility to proactively disclose to their immediate superior any situation that may represent a conflict of interest. Typical situations include: personal or family relationships that may influence business decisions; financial interests in competitors, suppliers or clients; use of confidential company information for personal gain; outside activities that interfere with responsibilities at GRICCO.

Important: doing business with companies/clients in the same field or area of activity does not automatically constitute a conflict of interest. However, such situations must be assessed on a case-by-case basis to ensure the transparency and integrity of business relationships.

Conflict Management Process

• Disclosure: employees must immediately report any potential conflict.
• Assessment: the company will analyze each case individually.
• Mitigation: measures will be implemented to manage or eliminate the conflict, where necessary.
• Monitoring: conflict situations will be regularly reassessed.

Training and Communication

Regular anti-corruption information and instruction for all employees, in accordance with the training program set out in the Code of Ethics and Conduct. Clear and constant communication on the importance of integrity.

Ethics Channel

Maintenance of a confidential channel for reporting violations, in accordance with the procedure detailed in the Code of Ethics and Conduct. Protection against retaliation for good-faith whistleblowers.

Audits and Monitoring

Periodic audits to ensure compliance. Continuous monitoring of risk activities.

Responsibilities

All employees are responsible for complying with this policy and reporting violations. Senior Management is responsible for leading by example and ensuring the effective implementation of this policy.

Consequences of Violations

Violations of this policy may result in disciplinary action — in accordance with the Sanctions Matrix of the Code of Ethics and Conduct —, including termination for cause for employees, termination of contracts for business partners, and legal action and penalties under applicable law.