INTEGRITY POLICIES AND GOVERNANCE NOTE

Blue Aspirations do Brasil guides its actions by transparency and ethics. Due to the dissolution process with the foreign parent company, we have established the following guidelines for market protection and human rights:

  1. Prevention of Humanitarian Abuse and Labor Exploitation

We formally repudiate and denounce the state of “financial suffocation” imposed on the Brazilian operation. The arbitrary withholding of salaries and subsistence funds for local professionals for several months is treated by this administration as a direct violation of human dignity and the fundamental norms of Labor Law. This practice has already been the subject of formal complaints before the Labor Public Prosecutor’s Office (MPT) and international bodies.

  1. Protection of Strategic Projects and Government Entities

We are committed to the integrity of the Aura Sul Wind project, Brazil’s first floating offshore wind pilot. We record that the contractual and ethical breaches by the foreign partners — Hainan Bojing Technology and Hangzhou Blue Aspirations China — have caused direct damage to the strategic planning of the State Governments of Rio Grande do Sul, Rio de Janeiro, and Ceará. Our current policy is one of maximum alert to these entities to prevent the contamination of their institutions by transnational mismanagement practices.

  1. Combating Financial Crimes and Capital Fraud

Our financial compliance policies are based on rigorous audits. It is hereby established that:

  • Capital Default: An audit dated February 24, 2026, proved the failure to pay in the subscribed share capital (BRL 3.1 million), characterizing the foreign partner as a “defaulting partner” (sócio remisso) and identifying the use of inconsistent financial information.
  • Data Security and Digital Integrity: We report a serious security incident involving the unlawful extraction of emails, contacts, and confidential documents (including NDAs and MoUs) via the WeCom platform. Due to evidence of remote manipulation, Blue Aspirations do Brasil does not recognize the integrity of any document or communication issued following the lockout of Brazilian administrators (Art. 154-A, Brazilian Penal Code).

LEGAL BASIS FOR THE DUTY OF DISCLOSURE

The maintenance of this information on our official channel is an exercise of the Duty of Diligence and Transparency, supported by:

  • Art. 5, Clause XXXIII, of the Federal Constitution: The fundamental right of access to information of public and private interest.
  • Art. 422 of the Civil Code (Objective Good Faith): The duty to inform partners and third parties about risks that may compromise the legal certainty of future business.
  • Art. 188, I, of the Civil Code (Regular Exercise of a Right): Informing the market about irregularities proven by audits and official complaints does not constitute an unlawful act, but rather the protection of corporate and social assets.
  • Anti-Corruption Law (Law 12.846/2013): The duty of companies to adopt integrity mechanisms and report harmful acts against public administration, whether domestic or foreign.