Code of Business Conduct

1. INTRODUCTION

Our Code of Business Conduct, the foundation of our Mission and Strategy, aims to guide the personal and professional conduct of all our employees, regardless of their position or function, and to regulate their relationship between co-workers, Customers, suppliers and representatives of the communities with which BRIMONT interacts.

The materialization of BRIMONT‘s Principles and Values is reflected in the daily performance of its employees, in accordance with consensual ethical practices.

As a set of ethical rules that are imposed on the collective conscience as a behavioral model, the provisions of this Code of Business Conduct are not limited to its provisions and must be observed as a reference of a high moral standard of conduct to which the Company and all who work in it and for it must respect and follow.

2. SCOPE OF APPLICATION

The Code of Business Conduct applies to all BRIMONT employees and its Agents, whose control or operational management is held, directly or indirectly, by BRIMONT, without prejudice to other applicable legal or regulatory provisions or to which of the exercise of their functions are obliged, as well as – with the necessary adaptations – to permanent or occasional employees, representatives, external auditors and other persons who provide services to them on a permanent or occasional basis.

In this sense, “employees” must be understood as all members of the governing bodies, managers and employees of BRIMONT.

“Customers” shall mean natural or legal persons to whom BRIMONT supplies its products or services.

“Suppliers” shall mean natural or legal persons who supply products to BRIMONT or provide services to it.

“Stakeholders” shall mean natural or legal persons with whom BRIMONT relates in its business, institutional and citizenship activities, including Customers, suppliers, employees, investors and representatives of the communities with which it interacts.

3. OUR PRINCIPLES AND VALUES

The observance of the Law, regulations, regulatory provisions, behavior based on integrity, ethics, transparency and honesty, is a commitment of each and every one of BRIMONT employees and that characterize the entire organization towards the community in which it operates. .

The conduct of BRIMONT’s business and corporate activities must be carried out within a framework of transparency, professionalism, rigor, good faith and with full respect for competition rules and based on a system of clear defense of the principles of sustainable development such as are affirmed by the International Institutions and Conventions.

In carrying out its activities, BRIMONT protects fundamental and universal human rights and, as such, inalienable and indispensable, promoting the principles of equality and solidarity and repudiating all forms of discrimination and corruption. In this sense, BRIMONT operates within the framework of the United Nations Universal Declaration of Human Rights and the International Labor Organization.

Each employee, by assuming with total autonomy the commitment to respect and follow these principles, is reaffirming the corporate values and contributing to bring BRIMONT closer to achieving its Vision: “To be an Angolan company that intends to assert itself as a reference on Multiple Service Provision.

4. RULES OF BEHAVIOR AND RELATIONS WITH INTERESTED PARTIES

4.1.RELATIONSHIPS WITH CLIENTS AND SUPPLIERS

BRIMONT will promote with its Customers and suppliers the observance of the regulations and safety practices that are in force, paying special attention to the taking of preventive measures for the safety of people and goods. BRIMONT employees must conduct their behavior in an ethical, professional and respectful manner, promoting civility, affability and professional pride in relations with Customers and suppliers, as well as respect for their respective rights, observing and demanding that contractual obligations and maintaining a relationship in accordance with good customs and commercial and deontological practices. The selection and contracting of suppliers must comply with transparent, fair and impartial criteria, taking into account not only commercial conditions but also their ethical and professional behavior.

BRIMONT employees undertake not to establish or maintain relationships with Customers and suppliers that are not in line with the spirit of this Code, and to adopt immediate and strict measures in cases where their ethical conduct is questionable, namely the reporting of such situations. to the respective hierarchy.

4.2.BRIMONT’S RELATIONS WITH EMPLOYEES

Employees are an essential element for the pursuit of BRIMONT’s strategies, objectives and goals.

BRIMONT is committed to promoting respect for equal opportunities for all its employees, developing a company culture that values and encourages teamwork and the sharing of knowledge and information.

All of BRIMONT’s labor practices, policies and procedures are aimed at preventing discrimination and differential treatment based on race, gender, sexual orientation, creed, marital status, physical disability, political orientation or opinions of another nature, origin ethnic or social origin, birthplace or trade union membership.

Brimont guarantees the safeguarding of the moral integrity of its employees, ensuring their right to working conditions that respect their individual dignity and does not allow any form of moral or psychological coercion, or behavior that offends the dignity of the human person.

4.3. EMPLOYEES IN THE PERFORMANCE OF THEIR FUNCTIONS

Employees, in the development of their professional activities, as mandated by BRIMONT, must observe the principles of loyalty, rigor, transparency, efficiency and openness to the market, with all their actions, operations and negotiations guided by compliance with the principles of integrity and transparency of information, for the formal and substantial legitimacy of its action and for the clarity, veracity and legitimacy of the supporting documents, all in accordance with current rules and internal procedures and with the required commitment and professional rigor.

Any practice of corruption is prohibited, in all its active and passive forms, whether through acts and omissions or through the creation and maintenance of favor or irregular situations, being ethically reprehensible and repudiated by BRIMONT.

BRIMONT employees will refuse any offers that exceed mere courtesy or of significant commercial value that may be considered or interpreted as likely to create expectations of favoring their business relationships with BRIMONT.

In case of doubt, the employee must communicate the situation in writing to the respective hierarchy.

BRIMONT employees must pursue an attitude of continuous improvement and innovation, striving for personal evolution and taking the best benefit from the training actions promoted by the Company. They must also ensure the protection and good state of conservation of BRIMONT’s assets, making a judicious and parsimonious use of the assets provided to them, adopting the appropriate measures to minimize costs in order to make their use more efficient and avoid waste and not directly or indirectly use any Company assets for personal or third party benefit.

CONFLICT OF INTERESTS 

BRIMONT employees are committed to:

• Not to carry out any external professional activity, with or without remuneration, that interferes with their professional performance or with the activities or interests of the Company;

Do not intervene in decision-making processes that:

• Directly or indirectly involve organizations with which they collaborate or have collaborated;
• Directly or indirectly involve people or entities to which they are or have been linked by kinship or affinity ties. Employees with family or similar relationships may not carry out their professional activity in a hierarchical or functional relationship, directly or indirectly, and must collaborate with the Company in taking the necessary measures to eliminate this situation. Any conflict or potential conflict of interest must be communicated and discussed with the superior.

CONFIDENTIALITY

BRIMONT employees are committed to:

• To keep absolute secrecy, in relation to the outside, of all facts concerning the life of the Company that they are aware of in the exercise of their functions or because of them. This duty is especially applicable to employees who have access to privileged and/or relevant information not made public, such as business plans, new products or management models, processes, mergers, acquisitions, financial information, contract negotiations (the disclosure of restricted, non-public information to others, including family and friends, constitutes a violation of this Code);
• (Where applicable) Do not buy or sell stocks or securities based on non-public information obtained through your work or presence with the Company.

4.4. RELATIONS BETWEEN PARTNERS

The main objective for BRIMONT is to seek to create value for its Partners, supported by excellence in professional, economic, social responsibility and sustainable development.

BRIMONT is committed to respecting the principle of equal treatment for its partners, ensuring that all the necessary information is made available in a timely manner, in a true, transparent and rigorous manner.

4.5. RELATIONS WITH LOCAL AUTHORITIES, INSTITUTIONS AND COMMUNITIES

BRIMONT, through its employees, cooperates actively and fully with the authorities, maintaining behavior characterized by rigor, transparency and open collaboration, promoting dialogue with institutions and civil society organizations, being prohibited to make, induce or encourage false statements to authorities.

BRIMONT respects market criteria, not promoting or participating in any type of activities that may violate basic ethical, deontological or competition rules aimed at obtaining advantages over competitors. It is BRIMONT’s commitment to contribute to the promotion of the quality of life and socio-economic development of the communities where it operates, as well as to the formation of human capital and local skills, while carrying out its own activities in accordance with the best commercial practices.

BRIMONT employees may participate in community services as long as this does not give rise to a conflict of interest and is not incompatible with the functions they perform in the Company.

4.6. ENVIRONMENT AND SUSTAINABILITY

BRIMONT and its employees must respect and protect the environment using the best practices and technologies that ensure the effective rationalization of consumption and significant gains in terms of the global impact of emissions and risks to the environment.

Sustainability must integrate all of BRIMONT’s decision-making processes, in order to reflect at all times and in all activities carried out the Company’s philosophy in its current and strategic management.

4.7. FOLLOW-UP AND GUARANTEE OF COMPLIANCE

BRIMONT guarantees the availability of this Code to all employees, who must sign a declaration of adhesion with the entry into force of the same. The Human Resources Department will be responsible for ensuring the implementation of this Code of Business Conduct as well as its interpretation and clarification of doubts and omissions.

All employees, Customers, suppliers and other interested parties may contact BRIMONT Management to ask any questions or request clarifications and to report any occurrence or irregular situation that may violate the rules of this Code.

4.8. COMMITMENT TO COMPLIANCE

All BRIMONT employees must sign a Declaration of adherence to this Code of Business Conduct.

4.9. DEFAULT

It is a serious misconduct, subject to disciplinary proceedings, to deviate from compliance with the general rules of conduct established in this Code of Business Conduct.