Compliance Policy

1 Introduction and Fundamental Principles

Commitment to ethics and social responsibility
Positive impact and sustainable development

2 Objectives and Scope of the Policy

Guidelines for legal and regulatory compliance
Alignment with best governance practices

3 Compliance Governance and Responsibilities

Compliance structure
Roles of the Compliance Committee and Representatives
Individual responsibility and ongoing training

4 Duties of Employees

Knowledge of and adherence to the policy
Reporting of improper conduct
Protection of confidential information
Participation in training and ethics and integrity practices

5 Human Rights, Equality, and Fair Working Conditions

Promotion of diversity and inclusion
Prohibition of child and forced labor
Freedom of association and collective bargaining

6 Professional Development and Continuous Education

Regular training and capacity-building
Encouragement of continuous learning

7 Data Protection, Privacy, and Confidentiality

Responsible use of data policy
Security measures and privacy protection
Transparency with data subjects

8 Anti-Corruption, Transparency, and Management of Conflicts of Interest

Prevention of bribery and fraud
Guidelines on gifts and hospitality
Reporting and management of conflicts of interest

9 Social and Environmental Responsibility and Sustainability

Environmentally responsible practices
Commitment to developing local communities
Continuous improvement in sustainability

10 Reporting Channels and Investigation of Improper Conduct

Confidential reporting channel and protection of whistleblowers
Procedures for investigation of reports

11 Review, Monitoring, and Improvement of the Policy

Periodic reviews and communication of changes

1 Introduction and Fundamental Principles

At Veloso Green Coffee, our commitment to integrity, ethics, and sustainability underpins all of our operations and relationships. This Compliance Policy is more than a set of guidelines: it is the foundation that guides us to act responsibly, transparently, and in accordance with applicable laws and regulations.

The purpose of this document is to strengthen the compliance culture, ensuring that all employees, managers, partners, and suppliers are aligned with our fundamental principles, which are:

Integrity: Act with honesty and transparency, ensuring that all decisions and actions comply with laws, regulations, and ethical standards.
Respect for Human Rights: We are committed to promoting and protecting human rights in all of our operations, creating a safe, inclusive, and fair environment for everyone.
Sustainability: We adopt practices that minimize our environmental impact and contribute to the sustainable development of the communities where we operate.
Social Responsibility: We see our role as that of an agent of positive transformation, constantly seeking economic and social development in the regions where we operate.

2 Objectives and Scope of the Policy

The Veloso Green Coffee Compliance Policy has as its central objective ensuring that all our operations are conducted in an ethical and safe manner and in full compliance with applicable laws, regulations, and international standards. This Policy sets out guidelines and responsibilities that govern our conduct, aiming to prevent risks, promote transparency, and strengthen the trust of our employees, partners, and clients.

Main objectives of the Compliance Policy:

Integrity and Compliance: Guide all Veloso Green Coffee actions so they are in accordance with in-force laws and standards, strengthening governance and ensuring compliance with national and international regulations.
Prevention of Risks and Violations: Implement monitoring, prevention, and risk mitigation mechanisms that could compromise the company’s integrity, with a focus on ethical conduct and responsible business practices.
Culture of Ethics and Transparency: Promote an organizational culture based on ethical principles and transparency, ensuring that all employees understand and fulfill their responsibilities related to compliance.
Sustainability and Social Responsibility: Ensure that our operations respect the environment and contribute to the development of the communities where we operate, aligning our business objectives with sustainability principles.

3 Compliance Governance and Responsibilities

Veloso Green Coffee has a robust compliance structure to ensure that all aspects of this Policy are applied effectively and transparently. The governance structure includes:

Compliance Committee: Responsible for approving and periodically reviewing this Policy, the Compliance Committee ensures that compliance principles are integrated into all operations and aligned with best practices in the sector.
Compliance Representatives: Appointed for each operational unit, these professionals act as contact points for compliance-related matters, promoting adherence to the Policy and facilitating the understanding and application of its guidelines.
Individual Responsibility: All employees and business partners are responsible for adhering to this Compliance Policy and reporting any incidents or improper conduct. Ongoing training is promoted to ensure everyone understands their compliance responsibilities.

4 Duties of Employees

Each Veloso Green Coffee employee plays an essential role in maintaining an ethical and safe work environment. All are expected to understand and fulfill their compliance and integrity duties. These duties include:

Knowledge of and Adherence to the Policy: Become familiar with this Compliance Policy and strictly follow its guidelines and standards in all professional activities.
Reporting Improper Conduct: Report any suspected violation of legal standards, company policies, or improper behavior through the available reporting channels, without fear of retaliation.
Protection of Confidential Information: Maintain the confidentiality of internal data and information, ensuring they are shared only with those authorized and as necessary for legitimate company activities.
Participation in Training: Actively participate in training and update programs offered by the company, staying current on best practices in compliance and security.
Ethical and Integrity Practices: Demonstrate ethical behavior in all business relationships and transactions, avoiding corrupt practices, bribery, and conflicts of interest.

5 Human Rights, Equality, and Fair Working Conditions

We are committed to respecting and protecting human rights, following the international conventions of the International Labour Organization (ILO) and Brazilian labor legislation. Our guidelines include:

Equal Opportunities and Diversity: Veloso Green Coffee promotes an inclusive and diverse work environment, where all employees have the same opportunities for development and professional growth, regardless of gender, race, sexual orientation, ethnic origin, religion, or disability.
Prohibition of Child Labor and Forced Labor: We adopt a zero-tolerance stance toward any form of child labor, forced labor, or exploitation of labor. The company conducts periodic audits to ensure these standards are respected throughout the supply chain.
Freedom of Association and Collective Bargaining: We respect and support employees’ right to freely associate and participate in collective bargaining, promoting open dialogue and active engagement with unions and workers’ representatives.

6 Professional Development and Continuous Education

Veloso Green Coffee believes that the continuous development of its employees is essential to fostering a culture of excellence, innovation, and ethics. Our commitment to education and professional development strengthens our capabilities, ensures compliance with quality and safety standards, and contributes to the sustainable growth of the company and our employees.

Our development and education practices include:

Regular Training in Compliance and Corporate Ethics: All employees take part in periodic training on the principles of the Compliance Policy, applicable regulations, ethical conduct practices, and risk prevention.
Technical and Leadership Development: We offer opportunities for technical improvement, leadership skills development, and programs geared toward continuous process improvement. These initiatives aim to prepare our team to face sector challenges with responsibility and innovation.
Support for Continuous Learning and Career Development: We encourage and support the career development of our employees, providing access to courses, certifications, and learning resources that strengthen their skills and broaden their professional perspectives.

7 Data Protection, Privacy, and Confidentiality

We are committed to protecting personal data and business information in accordance with the General Data Protection Law (LGPD) and other applicable regulations. Our practices include:

Confidentiality and Use of Information: All internal and confidential information is accessed only by authorized professionals, based on operational need and on “need-to-know” principles.
Data Security Measures: We use strict technical and administrative controls to protect information from unauthorized access, leaks, alteration, or destruction, in addition to conducting compliance audits and periodic risk assessments.
Transparency with Data Subjects: We provide clear and accessible information to data subjects regarding the processing of their personal data, respecting their rights of access, correction, deletion, and withdrawal of consent.

8 Anti-Corruption, Transparency, and Management of Conflicts of Interest

Veloso Green Coffee adopts a zero-tolerance policy toward corruption, bribery, and conflicts of interest. We strictly follow anti-corruption laws and implement internal guidelines to ensure an upright and transparent business environment.

Prevention of Bribery and Collusion: All employees must refrain from offering or accepting any form of bribe, whether in money, gifts, or favors that could influence business decisions. Any attempted corruption must be reported immediately.
Management of Conflicts of Interest: Employees and partners must avoid situations where personal interests could compromise their professional responsibilities. Conflicts of interest must be promptly reported for analysis and management.
Gifts and Hospitality Policy: Gifts of symbolic value are accepted as business courtesies, provided they do not influence decisions or compromise the integrity of relationships. Accepting higher-value gifts or those that may be considered advantageous is prohibited.

9 Social and Environmental Responsibility and Sustainability

Veloso Green Coffee is committed to sustainable development and environmental stewardship, adopting responsible practices in all operations. Our principles include:

Environmental Protection: We employ sustainable agricultural practices that minimize environmental impact, promoting the conservation of natural resources and protection of biodiversity in our areas of operation.
Community Engagement and Local Development: We invest in the well-being of the communities where we operate, supporting local initiatives in health, education, and infrastructure, and promoting partnerships with stakeholders who share the same social responsibility values.
Continuous Improvement: We adopt a continuous improvement approach to identify and implement innovative sustainability solutions, collaborating with partners to develop initiatives that protect the environment and encourage climate resilience.

10 Reporting Channels and Investigation of Improper Conduct

Veloso Green Coffee encourages all employees, suppliers, and partners to report, in good faith, any suspected violation of this Compliance Policy, legal standards, or improper conduct, promoting an environment of transparency and accountability.

To facilitate the reporting of irregularities, we offer a confidential Reporting Channel, accessible via the website www.veloso.com.br, ensuring the confidentiality and protection of everyone involved in the process. Reports may be made anonymously or with identification, according to the whistleblower’s preference.

Confidentiality and Protection of the Whistleblower: All reports received are treated with absolute confidentiality and seriousness. Veloso Green Coffee ensures that no whistleblower will be subject to retaliation for reporting improper conduct in good faith.
Investigation Procedures: Each report is analyzed by a dedicated compliance team, which conducts a fair and impartial investigation, ensuring that all parties involved are heard. At the end of the process, corrective or disciplinary measures are applied, if necessary, to prevent future occurrences.

11 Review, Monitoring, and Improvement of the Policy

This Compliance Policy will be periodically reviewed by the Compliance Committee, ensuring its constant updating and alignment with regulatory requirements and best practices in the sector. Any changes will be formally communicated to all employees and partners.

Contact Information

Veloso Green Coffee Exportação LTDA
Av. João Batista da Silva, 801
Carmo do Paranaíba, MG, Brazil
Phone: +55 (34) 3851-7500
E-mail: sustentabilidade@veloso.com.br

This document is classified as Public by Veloso Green Coffee and is authorized for disclosure in accordance with the needs of the company. Reproduction and/or copying of this document is prohibited without prior formal authorization.

Publication Date: 10/28/2024