Code of Conduct and Integrity.

THIAGO PINHEIRO DA SILVA, CNPJ 15.572.124/0001-19, trade name THG PINHEIRO CONSULTORIA, operating commercially under the Essentials Engineering Consulting brand, adopts this Code to guide its professional, commercial and institutional conduct with integrity, transparency, respect for the law and zero tolerance for fraud, corruption and unethical practices.

This Code applies to the owner and, where applicable, to employees, service providers, representatives, partners and contracted third parties acting on the company’s behalf or in activities related to its clients.

• Comply with applicable laws and regulations, as well as contractual obligations and client requirements.
• Act with honesty, technical independence, good faith, diligence and traceability in decisions.
• Not offer, promise, authorise, request or accept any undue advantage, directly or indirectly.
• Preserve people’s safety, asset integrity, the environment and the technical quality of the services.
• Avoid conflicts of interest and promptly disclose actual, potential or apparent situations.
• Protect confidential information, personal data, intellectual property and client and partner records.
• Keep accounting, commercial and technical records that are complete, true and sufficiently detailed.

It is prohibited, in any circumstance, to make or authorise any payment, gift, advantage, commission, facilitation, donation or benefit intended to influence a decision, obtain undue favour, speed up an administrative act or win or retain business improperly.

Dealings with public officials, state-owned companies and their employees must be professional, documented and consistent with applicable law, including Brazilian Law 12,846/2013 (Clean Company Act) and other relevant anti-corruption rules.

Gifts, meals, travel, hospitality and representation expenses may occur only when lawful, reasonable, of moderate value, linked to a legitimate business purpose and without intent to improperly influence decisions. Cash or cash-equivalent benefits are prohibited. Where there is doubt about appropriateness, the rule is not to offer or accept until the situation has been assessed and documented.

Any personal, family, financial or professional interest that may interfere — or appear to interfere — with independent judgement must be identified and managed. Relationships with clients, suppliers, competitors or public officials that may create a conflict must be disclosed where relevant.

The company will not use third parties to carry out any act that would be prohibited if done directly. Before engaging a representative, agent, consultant or partner with a sensitive commercial role, its scope, reputation, economic rationale, remuneration and any integrity risks must be assessed. Payments to third parties must correspond to services actually rendered, be documented and be made through traceable means.

Documents, invoices, reports, timesheets, reimbursements and accounting records must accurately reflect the nature, amount and purpose of transactions. Creating false, incomplete or misleading records, off-book accounts or unsupported expenses is prohibited.

Participation in commercial processes, tenders and negotiations must respect the client’s rules and competition law. Collusion, price-fixing, improper exchange of competitive information, bid manipulation and obtaining confidential information by improper means are prohibited.

Moral or sexual harassment, discrimination, retaliation, forced labour, child labour or any violation of human rights are not tolerated. Conduct must promote respect, professionalism, diversity and safety.

In engineering and operations-support services, decisions must give priority to safety, accident prevention, environmental protection and compliance with applicable technical requirements. No commercial target justifies omitting a relevant risk, manipulating technical data or disregarding a safety requirement.

Confidential information and personal data may only be accessed and used for a legitimate and authorised purpose. Reasonable measures must be taken to protect against unauthorised access, loss, alteration or disclosure. Data processing will comply with Brazilian Law 13,709/2018 (LGPD).

Suspected fraud, corruption, conflict of interest, harassment, breach of law or non-compliance with this Code must be reported to the owner. The company does not allow retaliation against anyone who, in good faith, raises a concern or cooperates with an investigation.

Contact channel: info@essentials-engineering.com. Relevant records must be preserved appropriately and confidentially.

The owner and anyone who comes to act on the company’s behalf must know this Code and receive periodic guidance, proportionate to the risks of the activity, on ethics, anti-corruption, conflicts of interest, dealings with public officials, gifts and hospitality, third parties, records, confidentiality and data protection.

The company will keep a simple record of training carried out and will review this Code whenever necessary, including in response to material changes in activity, client, legislation or risk.

Violations will be assessed according to their severity and may result in termination of the relationship with a third party, correction of processes, notification of the client or the competent authority where applicable, and other appropriate measures.

This Code is approved by the owner, comes into force on the date indicated and must remain accessible to interested parties. Its adoption does not replace clients’ specific policies or requirements; where a stricter rule exists, the rule applicable to the case prevails.