Compliance and Ethics Channel

Compliance

At Melnick, the Compliance area also includes Risk Management functions. The Risk Management and Compliance area is the main body responsible for the Company’s internal integrity procedures, which is responsible for, among other functions: (i) guiding compliance with the program through technical consultancy and clarifying doubts, solving any gaps , and (ii) carry out or ensure that due diligence is taken to contract and supervise suppliers, service providers, intermediaries and associates, among others.

The Risk Management and Compliance area is managed by a professional who does not carry out other operational functions. The area reports directly to the Company’s Audit Committee, a body constituted in the Board of Directors’ Meeting on July 30, 2020, which will be responsible for supervising the independence of the area’s operations. In addition, at its sole discretion, the Audit Committee may appeal to independent opinions with respect to compliance issues.

The duties of the Risk Management and Compliance area are duly formalized in the Company’s Code of Conduct and Risk Management Policy, documents approved by the Company’s Board of Directors at a meeting held on July 30, 2020.

The Risk Management and Compliance area is also responsible for conducting investigations of possible integrity deviations, ensuring application and adherence to the Code of Conduct. For cases classified as suspected fraud, bribery or corruption, the Risk and Compliance Management area will be responsible for conducting the investigation of the report with confidentiality and in an exempt manner, reporting monthly the progress of the investigation activities to the Audit Committee. A summary of these activities will be reported by the Audit Committee to the Board of Directors when participating in the Board of Directors’ meetings, which take place on a quarterly basis.

The Company also has a Conduct Committee, an independent collegiate body that advises the Board of Directors, to whom it reports directly, and is composed of three members who do not have operational functions: (i) the Human Resources Manager; (ii) the Manager of the Legal area; and (iii) the Manager of the Company’s Risk Management and Compliance area. The Conduct Committee has subsidiary competence to supervise investigative activities in the Risk Management and Compliance area that are not the responsibility of the Audit Committee, as well as to prepare a communication and training plan related to the Integrity Program and ensure compliance with it. In addition to reporting directly to the Board of Directors, the Conduct Committee provides information to the Company’s Audit Committee.

Ethics Channel

The Ethics Channel was created to record doubts or suggestions about the Code of Conduct and for reports of conduct that are not in accordance with Melnick’s culture of ethics.

The contact is made through Contacto Seguro, a third party company that keeps the information confidential and that does not, under any circumstances, identify the person who sent the information.

To get in touch you can call 0800-648-6324. The call is free and the service is open 24 hours a day, 7 days a week. If you prefer, go to www.contatoseguro.com.br and type Melnick in the name of the organization.

If you identify or suspect any incorrect behavior at Melnick, contact us by phone or the website above to report. You can also access it to make any suggestions or clarify any questions about the Melnick Code of Conduct.

Misconduct is considered to be any behavior and / or situation that does not comply with the Melnick Code of Conduct.

After your report is received, it will be referred to a conduct committee, responsible for the analysis. If the report is confirmed, appropriate action will be taken. In addition, all records will have an answer, which can be consulted on the Channel.