Anti-Corruption Policy

SÃO JUDAS MATERIAIS MÉDICOS, through this Anti-Corruption Policy, hereby informs the public of its practices in combating bribery and corruption in all company operations, as well as ensuring that all employees, service providers, representatives, suppliers, business partners, and any other third parties with the power to represent or act on behalf of the company comply with national anti-corruption laws and regulations, especially Law No. 12.846/13 (“Anti-Corruption Law”), which is regulated by Decree No. 11.129/2022 , which provides for the objective, administrative, and civil liability of legal entities for acts against the national and foreign Public Administration, reflected in this Policy, as well as any other foreign anti-corruption laws that may apply, or may come to apply, to the activities of SÃO JUDAS MATERIAIS MÉDICOS.

The provisions herein follow internal rules and policies, the guidelines of the Code of Ethics and Conduct, and current laws, in order to guarantee that SÃO JUDAS is conducted with complete legality and to the highest standards of integrity and transparency.

If you have any questions regarding your obligations, rights, and duties, or wish to file a complaint, please contact our Compliance Officer via email at canaldedenuncias@saojudasmm.com.br .

SUMMARY

To facilitate your understanding, this Policy is divided as follows:

INTRODUCTION
SCOPE
GUIDELINES
1. ILLEGAL CONDUCT
1. FACILITATION PAYMENT
1. EXPENSE RECORDS
1. CONTRIBUTIONS, DONATIONS AND SPONSORSHIPS
1. Gifts, complimentary items, entertainment, accommodations, and meals.
  1. PUBLIC OFFICIALS
  1. PRIVATE AGENTS
1. OTHER FORMS OF CORRUPTION
EXCEPTIONS
SUPERVISION
COMMUNICATION CHANNELS
UPDATE TO THIS POLICY
GENERAL PROVISIONS

1. INTRODUCTION

It is the responsibility of everyone who represents or acts on behalf of São Judas Materiais Médicos to be aware of the Code of Ethics and Conduct and this Anti-Corruption Policy .

São Judas repudiates and combats all forms of corrupt conduct, in the public or private sphere, such as, but not limited to, bribery, embezzlement and the granting of undue advantages, as well as the concealment or dissimulation of these acts and the obstruction of investigation and oversight activities.

Additional policies may be created to address specific cases, primarily due to legal or regulatory requirements.

2. SCOPE

Like the Code of Ethics and Conduct , this Anti-Corruption Policy applies to all employees, administrators, and those representing São Judas Materiais Médicos, service providers, representatives, suppliers, and business partners, noting that if these stakeholders do not have an Anti-Corruption Policy, they must adhere to that of São Judas Materiais Médicos.

3. GUIDELINES

The Anti-Corruption Policy of São Judas Materiais Médicos follows legal provisions and adopts policies aimed at protecting integrity and generating honesty and transparency in the business environment, especially regarding the expenditure of public resources, combating acts that harm society.

Most laws concerning corruption focus on actions involving public officials; however, all forms of corruption are not considered corruption.

These practices are discouraged by São Judas, including those that do not involve public officials, as they are inappropriate and incompatible with the company's values.

3.1. Illegal Conduct

São Judas does not adopt, encourage, or permit any conduct that constitutes or results in acts harmful to public administration or private companies, observing the provisions of the Anti-Corruption Law , paying attention to its exhaustive list, and is prohibited from:

To promise, offer, or give, directly or indirectly, an undue advantage to a public official, or to a third party related to them;
To finance, pay for, sponsor, or in any way subsidize the practice of the illegal acts foreseen in the aforementioned law;
Using an intermediary individual or legal entity to conceal or disguise one's true interests or the identity of the beneficiaries of the actions taken;
To hinder the investigative or supervisory activities of public bodies, entities, or agents, or to interfere in their actions, including those of regulatory agencies and supervisory bodies of the national financial system;

Regarding bidding processes and contracts, the following is prohibited:

To frustrate or defraud, through agreement, collusion, or any other means, the competitive nature of a public bidding procedure;
To impede, disrupt, or defraud the execution of any act in a public bidding procedure;
To deter or attempt to deter a bidder through fraud or by offering any type of advantage;
To defraud a public bidding process or a contract resulting from it;

To fraudulently or irregularly create a legal entity to participate in a public bidding process or to enter into an administrative contract;
To obtain undue advantage or benefit, fraudulently, from modifications or extensions of contracts entered into with the public administration, without authorization in law, in the public bidding notice or in the respective contractual instruments; or
To manipulate or defraud the economic and financial balance of contracts entered into with the public administration.

In addition to the aforementioned, the following are considered illegal conduct prohibited by this policy:

Failure to observe standard procedures for hiring third parties;
Requesting or approving payments for invoices exceeding the amounts stipulated in the contract;
Refusal to include clauses on Anti-Corruption Compliance, adherence to legal principles and specific legislation, and/or respect for São Judas' policies in the contract;
Job application for a relative of a public official;
Payments to public officials, their relatives, legal entities in which they hold a stake, or an individual or legal entity designated by the public official;
Requests for payments to be made to a third party's bank account or to a bank account in another country unrelated to the contract signed with the organization;
Requests for payments to be made exclusively in cash;
Requests for commissions or "success fees" that deviate from usual market practices or are incompatible with the nature of the services provided;
Requests for advance payments or unusual pressure for payment processing that deviate from usual practices;

Receiving or offering extravagant and excessive gifts, which may potentially violate the internal policies of São Judas Materiais Médicos;
An individual who insists on interacting personally with a particular supplier or customer;
Making decisions to approve projects or contracts under atypical conditions or conditions detrimental to the interests of São Judas Materiais Médicos, whether due to costs, conditions, or deadlines;
Preference or bias in hiring specific third parties without any plausible justification, particularly of a technical or financial nature;
Attempt to avoid or impede due diligence processes necessary for the execution or maintenance of a contract;

If any warning sign is noticed, the employee should report their concern directly to the Compliance Officer or report it through the São Judas Materiais Médicos , so that the necessary investigations can be conducted confidentially and, if proven, the necessary corrective measures can be implemented. It should be noted that no employee who makes a complaint, anonymously or otherwise, will suffer any sanction or retaliation, even if the suspicions are not proven.

3.2. Facilitation Payment

São Judas Materiais Médicos expressly prohibits "facilitation payments".

Facilitation payment is the illegal or unofficial payment of a small amount to a public official or person with approval authority, with the intention of facilitating, expediting, or encouraging a specific routine or necessary action, such as the issuance of documents, licenses, and certificates.

São Judas does not condone this practice and does not authorize this type of payment. If authorized, and legally supported, the facilitating payment must be recorded in the appropriate financial records, and the Compliance Officer must be informed of the occurrence.

In the case of a request for "facilitation payment," the employee must demand reliable proof that the payment is legitimate, requesting an official receipt. If there is no satisfactory proof, the payment must be refused and the Compliance Officer informed.

3.3. EXPENSE RECORDS

Any and all payments or receipts of funds made in the name of São Judas Matérias Médicos must contain sufficient information for their identification and justification, so that they can be analyzed in detail and monitored at any time.

São Judas respects accounting principles; therefore, entries generically identified as "other" are not accepted, regardless of their value.

No payment should be concealed by placing it into inappropriate accounts or covering it up with falsified, fictitious, or simulated documents. Therefore, this Policy requires that every transaction receive the necessary approvals and be correctly recorded and accounted for to protect the interests of São Judas Materiais Médicos.

Any act committed by any of the recipients of this Anti-Corruption Policy to conceal a fraudulent or illegal act will be considered a violation.

3.4. CONTRIBUTIONS, DONATIONS AND SPONSORSHIPS

Any contribution, sponsorship, and donation, as well as other offers of a similar nature, can only be accepted in the name of São Judas Materiais.

Doctors, after prior evaluation by the Board of Directors to assess any illicit or risky factors in the offer.

With regard to this Policy, it is worth emphasizing that under no circumstances may contributions, sponsorships, and donations be accepted in exchange for favors, advantages, or conditions, whether from public or private companies, national or foreign.

Regarding the donation of goods and assets and sponsorships of social, cultural, and sporting projects to social organizations, philanthropic entities, non-profit institutions, and associations, this is permitted and only carried out after evaluation by the Compliance Officer, based on the provisions of this Anti-Corruption Policy and the Code of Ethics and Conduct , and approval by Management.

3.5. GIFTS, COURTESIES, ENTERTAINMENT, ACCOMMODATIONS AND MEALS.

São Judas Matérias Médicos prohibits the acceptance and offering of gifts, courtesies, entertainment, hospitality, and meals that aim to obtain undue or pecuniary advantage, which may affect decisions or benefit third parties.

In situations where acceptance or offering raises suspicion of corruption, the Compliance Officer must be informed immediately so that the matter can be investigated.

3.5.1.PUBLIC AGENTS

Anti-corruption laws restrict the acceptance or offering of favors involving the Public Administration, Public Officials and/or their family members; therefore, when dealing with such individuals, these benefits must not exceed a reasonable value and are only permitted when:

They must be authorized by local laws, regulations, or bylaws and granted in accordance with the specific rules and formalities of each.

The organization or company whose beneficiary is the recipient of the gift (especially in the case of Public Officials);

They must not be given or received with the intention of corrupting; and
They should not appear to be inappropriate or suggest an obligation of reciprocity.

3.5.2. PRIVATE AGENTS

Common market practice involves expenses related to meals, such as business lunches and dinners with private agents, clients, and partners; these are permitted provided they meet the following requirements:

It must take place in the presence of a representative from São Judas Materiais Médicos;
The purpose is strictly professional and/or institutional, such as: business meetings with meals or meals provided by clients or partners for the purpose of training or informative lectures related to the market;
The expenses and costs involved with these meals should be reasonable;
Be in accordance with professional ethics;
Do not be motivated by corrupt intent;
They should not be extravagant or inappropriate (i.e., adult entertainment); and
Payment should be made directly to the service provider (e.g., restaurant).

If an employee of São Judas Materiais Médicos has any questions regarding the above requirements or about the possibility of offering or accepting an invitation to a meal, they should contact the Compliance Officer for further clarification.

3.6. OTHER FORMS OF CORRUPTION

São Judas Materiais Médicos does not condone any type of corruption. For São Judas, corruption is not limited to acts in dealings with public officials, nor is it solely defined as the delivery, promise, or offer of undue advantage. It also encompasses other forms of corruption, such as those listed in Law 12.846/13 , which constitute illicit acts that cause harm to the Public Administration and fraud in bidding processes. The Compliance Officer should be consulted when an employee is involved in procedures that interact with public officials and has doubts about how to act in these situations.

3.6.1. WARNING SIGNS

Acts of corruption are sometimes difficult to identify, therefore it is necessary for everyone to be vigilant in cases such as: (non-exhaustive list)

You find unnecessary or inappropriate purchases;
A third party insists on receiving payment in cash/money;
You acknowledge any improper business practices by third parties involved with São Judas;
You become aware of, or suspect, acts of corruption by an employee;
Request for an unexpected additional fee or commission;
Failure to provide proof of expenses when employees and partners request reimbursement;

In case of suspected corruption, the Compliance Officer must be informed immediately so that the matter can be investigated.

4. EXCEPTIONS

Only Senior Management, after analyzing the specific case and observing specific policies and procedures, and after consulting with...

The Compliance Officer may authorize any exceptions to the provisions of any of the Policies.

5. SUPERVISION

It is the responsibility of everyone at São Judas Materiais Médicos, especially the management and those in positions of trust, to uphold and respect the provisions of this Policy.

The Compliance Officer is responsible for overseeing this Anti-Corruption Policy , making every effort to ensure compliance with its provisions, as well as the integrity of the Compliance program and the necessary internal controls and training.

6. COMMUNICATION CHANNELS

Any suspicion of activity carried out in violation of the Anti-Corruption Law (Law 12.846/2013) , the Code of Ethics and Conduct , or this Anti-Corruption Policy , must be immediately reported to the Compliance Officer, who will impartially investigate the facts and take appropriate measures in accordance with the Whistleblowing Channel Policy.

The communication may, at the collaborator's discretion, be carried out confidentially and anonymously, with the necessary protection guaranteed for the full realization of their complaint.

7. UPDATING THIS POLICY

The current version of the Anti-Corruption Policy was last updated on August 25, 2023.

São Judas Materiais Médicos reserves the right to change this Code as many times as necessary, always respecting the maximum period of 1 (one) year.

Any changes will take effect upon publication, and we will always notify staff and the public about any changes that occur.

8. GENERAL PROVISIONS

This Anti-Corruption Policy supersedes its previous version upon approval. If you have any questions about this Policy, please contact our Compliance Officer via email at canaldedenuncias@saojudasmm.com.br .