Message from the Directorate

Creating a code of ethics and conduct to simply fulfill a formality of the current corporate world is not enough.

Sondotécnica believes that ethics is something that needs to be practiced daily. For this it needs to be debated, spoken, stimulated, questioned, constantly perfected.

It can’t just be a document to be forgotten on our computers or printed on a corner of the shelf.

Ethics is done on a daily basis, learning, educating, evolving. Only then can we understand it to assimilate it in its fullness.

In this Code of Ethics and Conduct, prepared within the Sondotécnica Integrity Program developed in partnership with KPMG, there are the principles of conduct that should guide the relationships between employees and other stakeholders and the company.

It aims to disseminate the ethical guidelines of Sondotécnica, which must be followed and disclosed by those who are present in its value chain.

We hope that this culture will be assimilated and stimulated by all.

Code of Ethics and Conduct

1. Purpose and applicability of the Code

This Code of Ethics and Conduct aims to disseminate the ethical guidelines of Sondotécnica, which must be followed and disclosed by those who are present in its value chain, including Directors, Officers, Employees, Interns, Young Apprentices, Third Parties (Service Providers, Suppliers, Partners, intermediary agents and associates) and all those acting on behalf of Sondotécnica.

The ethical values sought by Sondotécnica are based on mutual respect, for the benefit of a good business and social relationship.

In addition, the ethical principles that guide our performance underlie the image of a solid and reliable company, committed to internal legislation and procedures capable of preventing the occurrence of acts harmful to the public administration, national or foreign.

The Sondotécnica Management’s commitment to integrity in public-private relations is to maintain the appropriate conditions for the consolidation of an anti-corruption culture.

2. Expected Conduct

Everyone must guide their relationships and their actions by practicing the Principles of Sondotécnica and the guidelines contained in this Code, ensuring their compliance and integrity. In addition, the following conducts are expected:

– Act in strict compliance with all applicable laws, including anti-corruption and anti-bribery laws;

– Be responsible in the relationship with the authorities, customers, competitors, suppliers, members of the communities and all other individuals, companies and organizations with which Sondotécnica relates in the exercise of its regular activities, always seeking to preserve the good reputation, image and relationships of the company.

3. Legal Attitudes

Illicit practices, nor their attempts, such as corruption, bribery, extortion, bribery, money laundering or terrorist financing, in any of their forms, involving public entities or not, will not be allowed.

4. Unacceptable practices

Moral and sexual harassment are inadmissible practices, subject to criminal prosecution, as well as punishment and dismissal for just cause.

Any and all types of discrimination will not be accepted, whether by virtue of origin, race, political option, social, economic, nationality, or based on color, religion, sex, gender identity, age, physical characteristic or disability.

All acts of intimidation, offense or aggression (physical and/or verbal) are prohibited.

It is forbidden to carry a weapon of any nature on the premises of Sondotécnica.

The use of alcohol and drugs within the work environment is prohibited.

We do not allow the involvement of minors in activities that may be characterized as employment or child labor, except for the hiring of apprentices under the terms of the law.

We also do not allow any type of labor relationship that can be characterized as slave labor or analogous to slavery, both in Sondotécnica and in our suppliers and partners.

The practice of any act considered harmful to the Public Administration, national or foreign, as defined by Federal Law No. 12.846/2013 (Anti-Corruption Law) is prohibited.

CEC - Revision 2 05/22/2020

1. Scope and Scope

The Code of Ethics for employees of Sondotécnica Engenharia de Solos S.A. applies to Directors, Officers, Employees, Interns, Young Apprentices, Third Parties (Service Providers, Suppliers, Partners, intermediary agents and associates) and all those acting on behalf of Sondotécnica.

2. Presumption of Integrity

As a fundamental individual guarantee, Sondotécnica assumes that everyone is integral and guides their actions and relationships in accordance with the guidelines contained in this Code of Ethics and Conduct.

Thus, the punishments to those responsible for any violation of this Code or current legislation will only occur after due proof of the facts, and may undergo warning, suspension, contractual termination or whatever is more appropriate depending on the severity of the acts.

3. Compliance with Laws and Respect for Human Rights

Employees will comply with all applicable laws and regulations, whether national or foreign, as well as company-specific rules, and must behave ethically and responsibly in the places where they carry out their work, on behalf of Sondotécnica.

Employees will respect human rights and will not discriminate against people on grounds of race, belief, sexual orientation, sex, social status, religion, national origin, age, or mental or physical disability.

Employees will not publicly criticize Sondotécnica’s customers, competitors and suppliers.

4. Work environment

Relationships in the work environment should be guided by positive attitude, urbanity, courtesy and mutual respect, with everyone striving for transparency, focus on results, team spirit, professionalism, loyalty and trust, always focused on the development of Sondotécnica.

Any conduct that can be characterized as discriminatory according to the hiring regime of employees, race, origin, sex, religious belief or political conviction is considered intolerable.

5. Transparency makes a difference

Reporting suspicious conduct is not only the right thing to do, but it is also what is expected and required under this Code.

Any suspicious conduct that may represent non-compliance with the law, this Code, any other corporate policy, in addition to improper or suspicious accounting and financial practices, must be immediately reported.

Sondotécnica provides structured channels for reporting concerns or suspicions, ensuring that the problem or fear is addressed correctly and effectively:

Transparency and Reporting Channels

Open channels to listen to employees and third parties (Service Providers, Suppliers, Partners, intermediary agents and associates), clarify doubts and support in the resolution of any conflicts.

It is mandatory to communicate any attitude, behavior, practice, fact or data in disagreement with this Code, which is known or distrustful, being considered an ethical deviation to know and not to communicate. The communication must be made through the Transparency and Reporting Channels, or by any of the following means, and the anonymity of the whistleblower is guaranteed:

  1. a) E-mail and telephone. Direct superiors (internal employees in the company): we encourage contact with superiors as a first attempt at guidance or reporting, but it is not mandatory, and the employee may directly seek the official Channels.
  2. b) Compliance (all): if you want to communicate doubts, fears or suspicions, the employee or third party may search the area at any time, in person or via email: or through the Complaints Channel at the electronic address available on the Sondotécnica website:

We count on everyone and you can count on:

– Confidentiality: Sondotécnica undertakes to maintain confidentiality about the employee’s identity.

– Non-retaliation: no form of retaliation will be allowed to Sondotécnica employees if they point out evidence of actions that violate the rules of this Code.

6. Relationships with Customers and Suppliers

It is everyone’s duty to serve Sondotécnica’s customers and suppliers with clarity, veracity, courtesy, promptness, efficiency and a positive attitude, aiming to meet their needs and seek a long-term relationship, always in accordance with Sondotécnica’s commercial policies and corporate objectives.

Preferential treatment to any customer or supplier should be avoided based on personal criteria, affinity, kinship, friendship, etc.

Sondotécnica’s relationship with its partner suppliers and contractors must be based on respect, professionalism, transparency and integrity between the parties.

All suppliers and partners of Sondotécnica must meet the legal requirements and respect the applicable anti-corruption legislation. Before signing any contract, suppliers, service providers and partners must be aware of the principles contained in this Code and be in agreement with it.

Adherence to the principles contained in this Code must be reflected in the contracts signed with third parties, and this Code of Ethics and Conduct will be a mandatory part of any and all contracts signed with Sondotécnica.

Any action or behavior in breach of the provisions of this Code may cause contractual termination.

7. Relationship with Public Agents and Politically Exposed Persons

The relationship of all with public agents and politically exposed persons (PPE) must be transparent, respectful, ethical, in accordance with current legislation and with this Code and Ethics and Conduct, in order to ensure healthy and sustainable relations.

For the purposes of this Code of Ethics and Conduct, a public agent is one who exercises a mandate, position, job or function in the powers of the Union, the States, the Federal District or the Municipalities, even if temporarily or without remuneration, by election, appointment, designation, hiring or any other form of investiture or bond.

Politically exposed persons are public agents or former public agents who hold or have held, in Brazil or abroad, positions, jobs or public functions that may suggest a conflict of interest with Sondotécnica, real or apparent. Also PPE (Politically Exposed Persons) are the close collaborators of these public agents, their representatives or relatives up to 2nd degree.

Hiring – The hiring of all politically exposed persons or third parties who have politically exposed persons in their staff, must be preceded by a background check (integrity assessment), whenever such exposure is known to Sondotécnica. In addition, if such politically exposed person intends to occupy a leadership position in Sondotécnica or occupies a leadership position in a supplier or service provider, such hiring must also be previously approved by the Board of Directors or Board of Directors, in accordance with the competent authority.

Political Support – Sondotécnica cannot donate, finance or any type of support, directly or indirectly, to a political party or candidate for public office. The political conviction of all must be respected, but such conviction cannot influence, restrict or impact the principles, values and activities of Sondotécnica.

8. Relations with Competitors

The relationship with competitors must always respect ethical behavior, and may never use defamation practices, dissemination of untruths and malpractices, sabotage, industrial espionage, hiring employees of competitors to obtain privileged information, theft of documents and other illicit and unethical acts.

9. Conflict of Interest

Employees must use their best efforts to avoid situations in which personal interests conflict with the interests of Sondotécnica in the exercise of its activities, and which are consistent with the ethical values of the company.

It is the responsibility of the employee to communicate the degree of kinship with suppliers, service providers and third parties that provide services to Sondotécnica.

The existence of a conflict of interest, by itself, does not necessarily constitute a violation of the Code of Ethics, provided that its occurrence is promptly informed.

In order to avoid situations of conflict of interest, the following recommendations should be observed:

– Our employees may not perform activities in competing companies, suppliers or partners that may represent a conflict of interest (consulting, service provision, society, among others), except in situations previously approved by the board of directors;

– Not participate in market events promoted by suppliers or competitors without the knowledge and authorization of its manager; and

– Employees will not use the company’s property, assets or information system for matters other than its business.

Any business opportunities presented by customers or potential customers must be promptly reported internally to the Presidency.

10. Presents, Gifts, Entertainment and Hospitality

Corruption is an evil that affects everyone, governments, citizens and companies, and its effects are responsible for distortions that directly impact business activity, either by unfair competition, overpriced prices and restriction of business opportunities, or by the diversion of resources that otherwise could be made available for better implementation of public policies.

Employees and third parties acting on behalf of Sondotécnica will not grant to people who hold public or similar positions, in return for the fulfillment of their duties, any economic favor, such as money, gifts, gifts, hospitality, entertainment or other favors.

Employees and third parties acting on behalf of Sondotécnica will not pay agents, advisors or consultants any commission that employees may have knowledge of and that will be used to illegally influence public officials or other persons in similar positions.

Employees and third parties acting on behalf of Sondotécnica will not grant to Sondotécnica’s people, suppliers or customer managers any economic favor such as money, gifts or other favors, which exceed the amount generally accepted in the commercial scope, nor will they receive such economic favors from employees or customer and supplier managers.

Employees and third parties acting on behalf of Sondotécnica will not accept from anyone, whether this customer, supplier or competitor, any favor, gift or invitation whose purpose or purpose is to benefit or create a privileged situation in favor of it.

11. Donations and Sponsorships

Sondotécnica’s donations and sponsorships must be transparent, controlled and can only be made to reputable legal entities, duly regularized and carefully verified.

These activities will always take place in support of reputable entities, especially those that aim to support Education, Culture and the Environment.

12. Use of Company Information

Employees will keep all of the Company’s secret information in complete confidence and will not disclose this information to third parties, nor will they use it for purposes other than Sondotécnica’s business.

Only authorized persons may provide relevant information to third parties.

Employees and third parties acting on behalf of Sondotécnica have an ethical and legal responsibility to safeguard confidential information that is under their custody, even after their dismissal from Sondotécnica.

Employees and third parties acting on behalf of Sondotécnica will not violate the intellectual rights of other third parties, nor will they make copies of computer software, without the prior consent of the holders of such rights.

13. External communication

Sondotécnica has a group of professionals appointed to act as spokespersons for the company.

If any employee is sought to give information, interviews, lectures or write articles on behalf of the company to any communication vehicle, the employee must inform his superior and obtain authorization to do so, as well as involve the Administrative and Financial Board of the company in these actions.

14. Sondotécnica Heritage

Employees must, in their actions within and outside the corporate environment, protect the Company’s physical and intellectual assets, which include its brand and other intangible assets, movable and immovable property, technology, business and marketing strategies, information, research and data.

Such assets may not be used to obtain personal advantages or provided to third parties for any purpose.

15. Accounting records and financial resources

The legislation, standards and accounting principles must always be observed, so the financial statements of the Sondotécnica group must be accurate, complete and true.

All financial and accounting transactions must be properly recorded and supported by supporting documentation.

Any initiatives or actions aimed at evading taxes, circumventing applicable laws, fiscal and monetary rules are prohibited.

16. Protection of the Environment

Preserving the environment for future generations is a commitment of Sondotécnica, through full respect and compliance with environmental legislation.

Existing and economically viable best practices will be applied to reduce the consumption of natural resources, waste generation, atmospheric and effluent emissions and prevent pollution resulting from our activities.

All business that Sondotécnica may carry out must be in accordance with the laws and other provisions related to the protection of the environment. The responsible employees will carry out an adequate assessment of the environment to achieve these objectives.

17. Notification and Penalty

Employees and third parties who know of the violation of these Rules or a possible future violation thereof, as well as information on acts harmful to public property, national or foreign, against the principles of public administration or against international commitments assumed by Brazil, may make the communication through the following channels:

– Communication to the local Representatives of the various areas of Sondotécnica;

– Transparency Channel (transparê;

– Complaints Channel:

– Communication to the Improvement Group, which brings together representatives of the various areas of Sondotécnica;

– Communication to the Internal Commission for Accident Prevention – CIPA;

– Communication to the Critical Analysis Group by the Management; and

– Communication to your immediate superiors or the manager of your area.

Violations of this Code are subject to disciplinary penalties, including the possibility of dismissal, as may be determined by the Board and by the analysis of its Legal Counsel.

18. Trade Unions of Class

The union entities play an essential role in representing Sondotécnica’s employees and we believe in their performance balancing the interests between employees and the company.

19. Associations

Sondotécnica has persons formally authorized to represent it in class associations. No association is authorized to speak or represent the company in defense of its interests without the prior written consent of the organization.

Transparency Channel

Sondotécnica provides the Transparency Channel for communication of attitude, suspicion of behavior or practice in disagreement with the Compliance Policy, as well as the Code of Ethics and Conduct.

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