Company Policiesa (Code of Conduct)

  1. MESSAGE FROM THE PRESIDENT

Blue Aspirations Brazil is a global reference in the manufacturing of offshore measurement buoys and, since its founding in 2019, has based its activities on ethics and integrity. We believe this is the only path to solid growth. This Code guides the behavior of everyone: employees, Board members, directors, managers, and suppliers. Acting ethically is a personal commitment from each of us to safeguard our reputation as an upright company.

Marcio Nahas – President

  1. CONDUCT REQUIREMENTS
  • Conduct and the Law: Respect for laws, this Code, and internal policies is the basic requirement for ethical conduct. Violations subject the offender to legal sanctions and appropriate disciplinary measures.
  • Appreciation and Compensation: Blue Aspirations Brazil is committed to valuing its employees, ensuring fair and dignified compensation in full compliance with current legislation, ensuring strict fulfillment of all contractual and labor obligations.
  • Mutual Respect and Diversity: We respect individual rights and personal dignity. Any discrimination based on gender, nationality, age, physical ability, religion, color, or any other aspect of diversity is prohibited.
  • Right to Privacy and LGPD: We guarantee data processing in compliance with this Code and applicable legislation (LGPD). Technology resources (emails, internet, hardware) are company property and subject to monitoring and investigation.
  • Protection against Harassment: We have zero tolerance for any type of harassment. Pejorative nicknames, intimidation, improper gestures, slander, defamation, and derogatory jokes are prohibited.
  • Health and Safety: Ensuring safety at work is a priority. It is everyone’s duty to know preventive procedures and report risks immediately.
  1. OBEDIENCE AND MANAGEMENT REQUIREMENTS
  • Scope: This Code must be followed by anyone who works for or represents the company, including on-duty suppliers.
  • Role of Managers: They must be examples of integrity and ensure a safe environment for reporting misconduct, ensuring non-retaliation.
  1. RESPONSIBILITY WITH ASSETS AND INFORMATION
  • Use of Assets: Work tools must be used exclusively for professional activities and treated with care.
  • Confidential Information: Data regarding equipment, prices, strategies, and technical sheets are confidential and must have limited access.
  • Intellectual Property: Works created with the involvement of Blue Aspirations Brazil grant the company ownership of intellectual property rights.
  • Conflict of Interest: This occurs when personal interests conflict with those of the company (e.g., hiring relatives in the chain of command or providing services to competitors).
  1. BUSINESS INTEGRITY AND SOCIETY
  • Combating Money Laundering and Fraud: We repudiate acts intended to hide the illicit origin of resources or deceive third parties to obtain dishonest advantages.
  • Relationship with Suppliers and Human Rights: Partner selection is based on quality and ethics. We do not tolerate suppliers who use child labor, slave labor, or conditions analogous to slavery, nor partners who do not compensate their employees with dignity.
  • Gifts and Favors: Promotional items with logos up to BRL 1,000.00 (or USD 200.00) are permitted. Receiving cash amounts or alcoholic beverages is prohibited.
  • Government and Anti-Corruption: It is prohibited to offer or promise any advantage to public officials. The relationship must be strictly formal and transparent.
  • Environmental Responsibility: We adopt practices to minimize environmental impacts and conserve natural resources.
  1. WHISTLEBLOWING CHANNEL AND DISCIPLINARY MEASURES
  • Whistleblowing Channel: Violations can be reported via the website (blue-aspirations.com.br), email (clovis.tagliaferro@rcct.adv.br), or telephone (+55 11 99662-1312).
  • Guarantees: The company guarantees confidentiality, anonymity, and zero tolerance for retaliation against good-faith whistleblowers.
  • Disciplinary Measures: Non-compliance with this Code subjects the offender to measures ranging from warnings to contract termination.
  1. APPROVAL AND REVISION

This Code was approved on July 18, 2025, and will be reviewed annually or extraordinarily for continuous improvement.

Acknowledgment Term: I declare that I have received and understand the Blue Aspirations Brazil Code of Conduct, committing myself to follow its principles.