Code of Conduct

INDEX

• Purpose, Beliefs and Values
• Objective
• General considerations
• Workplace relationships and behavior
• People
• Use of physical resources
• Use of natural resources and sustainability
• Information security
• External relationships
• Open channel and Ethics Line 

PURPOSE

To be a protagonist in the appreciation of the purity and essence of nature through the development of safe and effective bioactive extracts for health and quality of life.

BELIEFS AND VALUES

• We attract, develop, and value people.
• We are an example of teamwork and maintain transparent relationships among ourselves.
• We are committed and prioritize excellence in all our developments.
• We build strong relationships based on transparency, collaboration, and diversity.
• We understand nature as the basis of our work.

ASPIRATION

To innovate with environmental awareness aligned with social transformation.

OBJECTIVE

To establish the conduct that guides RUBIAN’s business and relationships through its corporate governance and its employees, in an ethical, transparent, professional, and mutually respectful manner.

This document does not cover all possible ethical conflicts, experiences, and dilemmas that may arise. However, it defines the basic principles that should guide our conduct in any situation.

WHO IT APPLIES TO

The Code of Conduct applies to all administrators, internal and external employees, and other stakeholders who interact with RUBIAN, regardless of their hierarchical position or area of ​​activity.

GENERAL CONSIDERATIONS

The adoption of ethical and behavioral principles by RUBIAN reflects the type of organization we are part of. All employees must act in accordance with the Code of Conduct, internal policies, procedures, and current legislation. Any violation of these standards will be considered a serious offense, allowing the application of legal sanctions and disciplinary measures.

Whenever faced with what you think is a situation that has ethical or behavioral implications, before making any decision, ask yourself:

Omission and obstruction are considered unethical behavior, subject to punishment.

If you have doubts or identify any situation that violates this Code and/or current legislation, contact your manager or, if you prefer, report the case through the Open Channel. Information provided through this channel will always be treated with confidentiality.

WORKPLACE RELATIONSHIPS AND BEHAVIOR

Our commitment is to promote an ethical, safe, and healthy working environment for everyone.

To achieve this, fundamental attitudes with colleagues are essential, such as respect, education, and cooperation.

To maintain a transparent, mutually trusting, and responsible environment at all levels, RUBIAN adopts the following practices.

PEOPLE

HUMAN RIGHTS

We support the principles contained in the Universal Declaration of Human Rights of the United Nations and in the Declaration of Principles and Fundamental Rights at Work of the International Labour Organization. We believe that respect for human rights should be ensured for our employees and all individuals who interact with RUBIAN. In this sense, our policies and procedures aim to:

1. Have zero tolerance for slavery and child labor.
2. Make fair, equitable job offers in accordance with local laws.
3. Promote diversity and offer equal and fair opportunities to all.
4. Promote a workplace free from harassment, bullying, prejudice, and discrimination.
5. Allow freedom of association for our employees.
6. Provide decent and safe working conditions.

PREJUDICE AND DISCRIMINATION

We are committed to providing a non-discriminatory and equitable working environment regarding gender by treating all employees fairly. As such, our goal is to provide equal opportunities to all job applicants and employees, and no type of prejudice or discrimination in the treatment of our people, including in hiring, compensation, and training, will be tolerated.

We expect you to treat everyone with respect and promote diversity in our workplace. No type of discrimination, humiliation, intimidation, exposure to ridicule, hostility, and embarrassment in our workplace, based on race, social status, nationality, religion, age, retirement, disability, sex, marital status, sexual orientation, health condition, pregnancy, union membership, political affiliation, or other characteristics protected by law, will be tolerated.

HARASSMENT AND BULLYING

Our goal is to provide a workplace where everyone is treated with dignity, equality, and respect at all times. As such, we will not tolerate any employee, supplier, visitor, customer, or any other person in our workplace being subject to or threatened by any type of punishment or physical abuse, bullying or harassment, including, among others, sexual, physical, and verbal harassment, intimidation, humiliation, or degradation, or unjustifiable behavior by any individual or group that creates a risk to the health and safety of another worker, whether intentional or not.

ILLEGAL SUBSTANCES/ALCOHOL

RUBIAN prohibits and does not tolerate the possession, offer, or use of drugs and the consumption of alcoholic beverages in the workplace. It is also not acceptable to be under the influence of these substances during working hours.

FIREARMS AND BLADES

The carrying of any type of weapon on RUBIAN premises is not allowed, except with authorizations, as determined by the company and with the proper documentation and regulation.

CONFLICTS OF INTEREST

The use of an employee’s position or influence to promote personal interests may conflict with RUBIAN, due to inappropriate conduct. Examples of situations that cannot occur:

• Any favoritism, material or financial advantages that an employee receives from one of our suppliers or service providers.
• Performance by the employee of other professional activities that may interfere with RUBIAN’s business, even if performed outside working hours.
• Improper use of privileged information obtained within RUBIAN.
• Family relationship between employee, supplier, or service provider that compromises impartiality in business.
• Any unjustifiable favoritism directed by the employee to a specific client, to the detriment of other clients or the interests of RUBIAN itself, especially when this professional maintains any social or affective relationship with the favored one.
• Parallel activities carried out by the employee during working hours or using RUBIAN resources.

Some situations require specific actions, as per the following guidelines:

COMMERCIAL ACTIVITIES

RUBIAN does not recommend the trade of any products or services on its premises, such as the sale of cosmetics, food, catalogs, clothing, financial consulting, income tax, among others, nor that such activities be carried out using company resources. This applies to both employees and suppliers and service providers.

It is also not allowed to conduct games that involve cash prizes, such as raffles and pools.

GIFTS AND ENTERTAINMENT

Inappropriate gifts and entertainment opportunities can harm RUBIAN and lead to improper business decisions.

Employees are prohibited from using their positions to request personal favors, obtain any type of gift or favor from any person, supplier, or service provider.

Gifts include all items received, such as samples of new products, gifts, drinks, and/or any other item, from a supplier. Entertainment includes dinners, tickets to shows and sporting events.

In cases where these situations are unavoidable, received gifts should be forwarded to the Human Resources department for an internal draw, in the RUBIAN unit where they were received.

Edible items can be consumed if shared with the department team, except for alcoholic beverages. Office materials, such as mouse pads, calendars, agendas, notebooks, and simple pens, can be used by the employee in the workplace.

USE OF PHYSICAL RESOURCES

It is the responsibility of each employee to use RUBIAN’s resources carefully and consciously, without personal purposes, within the current legislation and without any intention to damage them.

Illegal copying of software, the use of pirated products, and access to websites unrelated to work activities are not allowed.

All messages distributed through the email system are the property of RUBIAN.

Access to the internet for non-work-related matters is not permitted.

Phone usage should be considered and restricted to work-related matters. This resource can be used for non-work-related matters quickly and occasionally.

USE OF NATURAL RESOURCES

SUSTAINABILITY

At RUBIAN, our ambition is to innovate and promote a positive social, economic, and environmental impact on the world.

In this way, we are constantly seeking ways to reduce our environmental impact and help our suppliers, communities, and other third parties to do the same.

As an employee, we recommend that you always comply with applicable local and international environmental laws and regulations. You should also adhere to all policies and procedures to ensure that we have all necessary local and international licenses to operate and that proactive measures are taken in our operations to reduce our impact on the environment and natural ecosystems.

Examples of these measures include, among others, reducing our waste generation, water consumption, energy usage, and CO2 emissions.

COMMUNITY AND THE ENVIRONMENT

It is essential to maintain relationships of respect, transparency, and cooperation with the communities where we operate. In our decisions, we consider the impacts we produce and aim to identify them quickly and reduce them in the course of our activities. All operations conducted by us are in accordance with current legislation.

INFORMATION SECURITY

CONFIDENTIALITY

All information not in the public domain is considered confidential since such data can affect the business’s outcome and dynamics. Anything that, if disclosed, could cause harm to RUBIAN should be considered confidential information. Public information, on the other hand, includes all those disclosed by the company on its website and/or social media.

Some examples of confidential information:

• Disclosure of new products before launch;
• Feasibility studies for new businesses;
• Business results;
• Personal information of employees, administrators, and clients.

Employees should be careful when leaving confidential information on printers, meeting rooms, exposed work environments, as well as when disposing of these documents when necessary. Complete destruction of the material before disposal is recommended.

In addition, discussing RUBIAN-related matters on social media, private channels, and any public places should be avoided.

Any requests for RUBIAN data for academic work, invitations for lectures, classes, student visits, or any activities related to the company or its industry should be forwarded to the General Management and the relevant department for analysis and possible approval.

Intellectual property resulting from our work or related to our activities must also be safeguarded.

ACCESS

The employee is solely responsible for their passwords (telephony, electronic means, and systems) for access, which are personal and non-transferable. Never disclose your passwords to colleagues or even close acquaintances. This ensures the security of information and data at RUBIAN.

In this regard, it is not allowed to copy, reproduce, transmit, or distribute documents, files, models, methodologies, formulas, research, projects, analyses, and reports produced by you or colleagues during the performance of activities, as these documents are the property of RUBIAN.

EXTERNAL RELATIONSHIPS

WITH CLIENTS

The customer is the focus of our business and the key to our success. Therefore, our commitment is to build strong and reliable relationships. We must adopt an ethical stance at all times in this relationship, acting with respect and transparency.

Employees are responsible for acting with ethics and simplicity, prioritizing good relationships at all times, and preserving the company’s image in front of clients. In addition, company professionals should not offer or advertise something that, in doubt or knowingly, cannot be fulfilled.

WITH SUPPLIERS AND SERVICE PROVIDERS

We maintain a relationship with our suppliers and service providers based on professionalism and mutual respect. We work with transparent selection criteria and require compliance with all legal and ethical requirements defined in this document.

All acquisitions of goods and services should seek the best balance in the cost-benefit relationship, always maintaining quality within technical standards and current legislation, and fulfilling commitments and schedules established.

We do not tolerate any act of corruption or fraud, and therefore, our suppliers and service providers cannot be linked or involved in any illegal or privileged activities.

WITH THE MEDIA

RUBIAN’S IMAGE

Our relationship with the press is based on trust, mutual respect, ethics, and professionalism. The disclosure of information to the external public is restricted and the responsibility of the General Management.

Only the General Management can communicate/speak to the media. The same applies to recordings and interviews, which can only happen after the knowledge and evaluation of the Administration.

If you identify any information disclosed incorrectly or that apparently may generate repercussions in society and consequently impact the image and reputation of RUBIAN, immediately inform the General Management so that appropriate measures can be taken.

In the event of an approach by the press, the employee should not expose RUBIAN’s names/brands.

USE OF THE BRAND

Any areas that need to use the RUBIAN brand must do so according to the guidance and authorization of the General Management to respect all technical requirements and the established and approved manner of use.

SOCIAL MEDIA

Social media is part of our reality. The internet is a public environment with rapid repercussions and scope, allowing the creation of both positive and negative images of both RUBIAN and you.

We do not encourage the association of RUBIAN and its names/brands with the employee’s profile on their social media, except for those of an exclusively professional nature, aiming to ensure their physical integrity and that of their family.

The disclosure of photos or videos containing the work environment or any identification of products is prohibited on any social network, except for publications already circulated in the media by the Marketing department.

If the improper use of RUBIAN’s names/brands is identified on social media, the employee must immediately inform their manager and/or report the incident through the Open Channel.

WITH PUBLIC ENTITIES AND GOVERNMENT AGENCIES

ANTI-CORRUPTION POLICY

Corruption is an unacceptable practice within the company, whether by our employees, suppliers, or service providers.

In total compliance with Law 12,846/2013, we do not tolerate any unethical practices, as well as any favoritism, bribes, payments of any amounts in cash, and distribution of gifts, products, presents, or entertainment to any public official, with the purpose of gaining advantages in decisions or using influence to maintain business.

An illegal or undue payment, as described above, can tarnish the company’s image and may lead to civil and even criminal liability for both RUBIAN and the involved employee.

POLITICAL AFFILIATIONS/ASSOCIATIONS

In accordance with Brazilian Law 13.165/2015, contributions to politicians and/or political parties by RUBIAN are not allowed.

Employees can join clubs, political parties, and other social or political institutions, as long as such association does not hinder the fulfillment of their duties described in the employment contract.

However, RUBIAN does not allow the conduct of campaigns, as well as the use of emblems suggesting the above themes within its premises.

The use of uniforms, T-shirts with logos, badges, or any emblem associating the RUBIAN brand with participation in events, interviews, or political acts is prohibited.

WITH COMPETITORS

We believe in fair competition. Our competitiveness should be based on the ability to negotiate with suppliers and the ethical management of the business.

Thus, we condemn acts of corruption, the formation of cartels, or actions that may defraud mechanisms overseeing the sector.

RUBIAN also does not permit its employees to make comments about competitors’ products or services, directly or indirectly, with the intention of publicly and/or internally denigrating or defaming the competitor’s image.

Any actions considered anticompetitive, such as price fixing, customer and market division, refusal to sell, among others, should be reported to your manager or through the Open Channel. It is expected that the employee advocates for the company’s good reputation and assets.

WITH UNIONS

We value the relationship with union entities and their importance in the relationship with employees. We respect employees’ free association and collective bargaining, recognizing their legitimacy and complying with agreements and collective conventions.

MONEY LAUNDERING

Money laundering is understood as economic and financial practices aimed at disguising the illicit origin of certain assets so that they appear to have a lawful origin.

RUBIAN does not condone such practices and adopts internal policies to prevent and monitor any suspicious occurrences. If any act of money laundering is identified, it will be appropriately reported to the competent authorities.

OPEN CHANNEL

It is important that every employee, supplier, or service provider promotes a work environment where everyone can communicate their concerns about ethical issues without fear of retaliation.

Retaliation against anyone reporting concerns or doubts about misconduct will not be tolerated. Concerns should be communicated in good faith, meaning that you should report something you believe to be honest information, even if you do not have all the evidence.

RUBIAN reserves the right to apply disciplinary measures to anyone who knowingly makes a false accusation or acts improperly. However, if someone voluntarily reports being involved in an ethical violation, such action may be taken into consideration when determining appropriate sanctions.

The company provides its employees, suppliers, and service providers with an exclusive channel for reporting situations considered unethical that violate this Code, internal policies, procedures, and/or current legislation.

RUBIAN ETHICS LINE

ASK – Pose a question about a specific situation or related to compliance with the law and our Code of Conduct.

REPORT – Submit a report about a real or potential violation of the law or the Code of Conduct.

CONTACT: LINHAETICA@RUBIAN.COM.BR

The Ethics Line is a convenient and confidential way to ask a question or report a concern. We cultivate an environment of openness, honesty, and diversity in the workplace, encouraging clear communication and enabling associates to report misconduct and raise ethical concerns without fear of retaliation. Anyone experiencing retaliation for asking questions or reporting concerns should immediately report such behavior. Any individual involved in retaliation will be subject to disciplinary measures, including possible termination.