Supplier/Client Code of Conduct

1. Introduction

This Supplier/Client Code of Conduct aims to establish guidelines that should guide the ethical and socio- environmental conduct of Suppliers/Clients in their relationship with Traive. In turn, the guidelines presented here are in full compliance with the Code of Conduct and the Company’s position on compliance and sustainability issues.

2. Purpose

Our expectation is that Traive’s Suppliers/Clients will support our commitment to not only doing what’s good for the business, but also what’s good for our people and the communities in which they live and work. Thus, our Code of Conduct and this Supplier/Customer Code of Conduct are intended to inform our ethical values, in order to provide those who read them with an understanding of the types of behaviors and decisions that are acceptable and encouraged by Traive, as well as aiming to guide the how to deal with unethical conduct or conduct that violates this Code.

3. Scope

This Supplier/Client Code of Conduct applies to any organization that: (i) supplies goods or services to Traive, (ii) is engaged for the purpose of serving Traive’s customers, or (iii) enters into a business relationship with Traive to create market eminence, including alliance and resale relationships (“Supplier/Client”).

The guidelines presented here must be disclosed to all spheres of decision and operation of the Supplier/Client.

A Supplier’s/Client ́s contract may contain clauses related to some of the topics covered in this Code, however, nothing in this Supplier/Client Code of Conduct will replace stricter clauses of any specific contract.


A.1. Honest and Ethical Conduct

Traive’s policy is to promote high standards of integrity by conducting its business honestly and ethically. Ensuring respect for the fundamental rights of its employees and adequate working conditions are some of the basic requirements considered by Traive and, therefore, all Suppliers/Clients are expected to observe the highest ethical standards of business conduct in their relationships during performance of your activities.

A.2 Compliance

Suppliers/Clients must comply with and maintain their processes in accordance with current applicable legislation and adopt corporate business management standards – especially in customer relations, having adequacy plans for dealing with non-compliance. All Supplier/Client company personnel must comply, both in letter and in spirit, with all applicable laws, rules and regulations in the cities, states, and countries where Traive operates. While not all members are expected to know details of applicable external laws, rules, and regulations, it is important to know enough to determine when to seek advice from appropriate personnel and to comply.

Compliance questions should be directed to Traive’s Compliance Team (see Section F).

A.3. Values

Our principles are based on transparency, responsibility, ambition, innovation, vision, and empowerment. Such guidelines are essential for the continuous development of a good relationship with our employees. Likewise, we hope to build a responsible and transparent relationship with our Suppliers/Clients, with the support and effective participation of these Suppliers/Clients being essential in strict compliance with these guidelines and the provisions of thisCode.


B.1. Dignity and Respect

Suppliers/Clients, above all, must treat Traive employees – as well as their own personnel, with respect and dignity and under no circumstances subject them to degrading conditions.

B.2. Non-Retaliation

This Code is intended to allow our Suppliers/Clients not only to comply with our principles, rules, and current legislation, but also to encourage and allow these third parties to identify and raise serious concerns involving Traive before compromising commercial relationships and eventual extreme measures. In this sense, we expect our Suppliers/Clients to respect the legal rights of freedom and encourage their people to an environment where business standards are clearly understood and where there are open channels for them to communicate openly with management about threats of retaliation, intimidation, or harassment.

Traive has zero tolerance for retaliation, whether from its employees or Suppliers/Customers, which includes, but is not limited to, retaliation against anyone who reports any violations of this Code or who has cooperated with an investigation to investigate violations of this Code.

B.3. Anti-Harassment

Harassment can take many forms and can be carried out virtually or in person. It can be sexual or non-sexual. The line between what is appropriate and what is not can often be blurred, especially when working remotely, and particularly in a culturally diverse workplace like Traive. Therefore, it is essential that all our Suppliers/Clients continually educate themselves on these issues and act accordingly.

Traive adopts a zero-tolerance policy against all types of harassment that leads to a toxic and unhealthy work environment and therefore will briefly demonstrate below the forms of harassment and correlations due to their special importance.

i) Sexual Harassment: in general terms, the definition of sexual harassment is broad and has different conditions and forms. In Brazil, sexual harassment is a crime and there is a need for subordination between the harasser and the victim (“blackmail harassment”). In turn, Brazilian doctrine provides for the possibility of “sexual harassment by intimidation”, which is independent of a hierarchical relationship. In the United States, on the other hand, sexual harassment has been defined by the Equal Employment Opportunity Commission as “unwanted sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature”. Furthermore, it is important to emphasize that sexual harassment does not have to be of a sexual nature, it is enough

to offend a person about their sex.

ii) Moral Harassment/Bullying: in general terms, both in Brazil and in the United States, there is no clear and objective definition on the existence of the crime of moral harassment, especially in the work environment. Thus, the protection arising from this act is supported by auxiliary regulations. In the United States, these regulations generally protect a protected class/group from suffering derogatory acts, which, in turn, are prohibited from suffering discrimination based on race, color, religion, sex (including pregnancy), national origin, age (40 years or older), disability or genetic information. In Brazil, moral harassment in the workplace is characterized by repetitive exposure to

humiliating and embarrassing situations;

iii) Discriminatory Behaviors: addressed in

Section E.1.

It is important to clarify that while such behavior is not always necessarily illegal, it can still be intolerable at Traive and deserves to be approached with great caution. For us, any behavior that is intended or results in creating a hostile and toxic atmosphere is not tolerated.


C.1. Business Integrity

Supplier/Client is expected to uphold fair business standards and practices, maintaining a proprietary confidential process that allows its workers and contractors to report incidents of unethical behavior.

C.2. Financial Crimes

Traive strictly complies with the applicable legislation regarding the prevention of fraud and money laundering, acting to ensure the legitimate origin of business activities.

Payments made and amounts received must correspond to goods and services actually provided, with due registration in Traive’s accounting, which means that we do not accept payments in unknown bank accounts or receipts from people or companies that are not related to the transactions trades made between the parties.

Supplier/Cliente shall not undertake or assist any third party, including Traive, in any activity or intent of money laundering, terrorist financing or other financial crimes.

C.3. Gifts, Gifts, Entertainment and Hospitality

The main distinction between bribery and donation is the “intent” behind the act, and, given that “intent” is not always easy to determine, as a matter of policy, Traive employees:

i) Must not solicit or accept for personal benefit, directly or indirectly, any gift, loan, discount or any item of substantial monetary value (amounts greater than R$300.00 or US$100.00) from any person or company seeking do or are currently doing business with Traive;

ii) May accept gifts, meals and accommodations of reasonable and normal value provided to all under the same circumstances (subject to Management approval);

iii) They must consult with Management on the advisability of any exchange of gifts and obtain its approval.

In this sense, a Traive Supplier/Client must not offer, accept, or request gifts, gifts, entertainment, and hospitality when there is reason to believe that there is an intention to improperly influence decisions or impair the objectivity of any business with Traive through its collaborators.

C.4. Conflict of interests

Supplier/Client shall not allow conflicts of interest or inappropriate influence by others to override its professional judgments and responsibilities. Supplier/Client is expected to voluntarily declare any conflicts involving Traive employees.

C.5. Confidentiality, Privacy, and Intellectual Property

The Supplier/Customer must fulfill its obligations related to the protection and proper use of all confidential and personal information exchanged during and/or as a result of the relationship between the parties, under the terms of the specific contracts signed, as well as in compliance with the applicable legislation.

Traive owns the intellectual property and copyright of all information, data and products exchanged or originated as a result of the relationship with the Supplier/Customer, unless the parties stipulate a different condition in a specific contract.


D.1. Environmental, Social and Corporate Governance (ESG)

The Supplier/Client declares and guarantees that it carries out its activities in accordance with the current legislation applicable to them and that it holds all necessary and sufficient approvals for this purpose.

The Supplier/Customer undertakes to adopt best practices aimed at preserving the environment during its operations, carrying out its respective activities in compliance with current legislation regarding the National Environmental Policy and Environmental Crimes, as well as legal, normative acts and administrative related to the environmental area and correlated, emanating from the federal, state, and municipal spheres.


E.1. Anti-Discrimination

While discrimination can be expressed as “harassment”, it can also take other forms, which may not necessarily be considered harassment, but can equally lead to a hostile and unhealthy work environment. At Traive, we pride ourselves on our diversity and, as an equal opportunity employer, we are committed to complying with all applicable laws, rules and regulations that prevent discrimination against team members and related parties based on: race, color, ethnicity or national origin, religious beliefs, political beliefs, gender, sex (including pregnancy, sexual orientation or gender identity), family status, genetic information (including family medical history), disability, age, veteran status, martial status, physical challenges or any other relevant factor.

In the same sense, Traive expects the Supplier/Customer to adopt and encourage a culture that promotes equality of opportunity and treatment for all. The Supplier/Customer must not tolerate discrimination. Candidates for work and partnerships, collaborators and partners are expected to be assessed based on their skills and respected for their choices and opinions.

E.2. Anti-Violence

Traive expects all Suppliers/Clients to always behave in a non-threatening and non-abusive manner. No direct, conditional, or veiled threat of harm to any Traive employee or Company property will be acceptable. Any member of the Supplier/Client who commits, or threatens to commit, a violent act against any person, may be subject to remedies and/or penalties to the extent permitted by law, as well as the immediate termination of the commercial contract between the parties.

E.3. Work Conditions

The Supplier/Client shall consider applicable regulations regarding the working conditions of all its professionals, including, without limitation: laws, regulations, and norms regarding the observance of legally required breaks and rest periods, dignified and freely agreed and formalized conditions.

E.4. Slave Labor, Child Labor, and Discrimination

The Supplier/Client declares and guarantees that it does not use illegal work, including, but not limited to, the practice of work similar to slavery, child labor, except for the latter as an apprentice, subject to the provisions of the Consolidation of Laws of Work and, without prejudice to the provisions of item E.1., not to use practices of negative discrimination and restrictions on access to or maintenance of the employment relationship.

E.5. Health and Safety

In addition to complying with the minimum legal requirements for working conditions, Traive expects the Supplier/Client to guarantee safety and health in the work environment and to take the necessary precautions to prevent accidents and injuries.


F.1. Reporting suspected violations

Traive adopts the “open door” principle and suggests that all its employees and related parties – including Suppliers/Clients, share their queries, concerns, suggestions or complaints with someone who can appropriately address them.

In case of doubts regarding any issues of this Code or issues that have not been addressed by this Code, Suppliers/Clients should seek their relationship contact at Traive.

In relation to denouncements of possible violations of this Code, illegal conduct, conflicts of interest or questionable behavior, the Supplier/Client may also seek their relationship contact at Traive or, if this is not possible, appropriate, or comfortable, they should report the incident to a Traive’s Compliance manager or use our Whistleblowing Channel.

Traive’s official reporting channel is through SafeSpace at the following access link:

Traive expects all its Suppliers/Clients and partners to ensure compliance with this Code and report any inappropriate or illegal conduct. Anonymity and confidentiality are guaranteed – unless the whistleblower chooses to reveal his name – and retaliation or punishment for whistleblowers in good faith will not be tolerated.