CODE OF ETHICS AND CONDUCT

Dear colleagues,

SÃO JUDAS MATERIAIS MÉDICOS, through this Code of Ethics and Conduct, hereby sets forth its principles and mission, reiterating the company's core values, which are:

Ethics;
Excellence;
Respect for Life;
Social Responsibility; and
Caring for those who make up our company.

The effectiveness of these values is only possible through the commitment of the employees who are part of the company's staff and the proper compliance with the standards of conduct, guidelines and principles present in this Code and other internal policies, which always aim to guarantee ethical and transparent behavior from our institution.

Thus, São Judas Materiais Médicos, as it has done before, maintains its uncompromising position regarding the practice of illegal and/or unethical conduct in the workplace or within the scope of its operations.

This Code of Ethics and Conduct is the official document that outlines what São Judas expects from our team members.

Therefore, this document should serve as a guide for conduct, basing the company's activities and the team's behavior always on ethical and transparent principles.

Therefore, the science and preservation of what is presented here is not merely an administrative matter, but an attitude that generates value for the organization and demonstrates São Judas Materiais Médicos' commitment to ethics.

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 Code is divided as follows:

INTRODUCTION
SCOPE OF ACTION
SCOPE
PRINCIPLES
MISSION, VISION AND VALUES
GOOD RELATIONSHIP PRACTICES
1. Work Environment
1. Professional Posture
1. Moral and Sexual Harassment
1. Drug use, alcohol, possession of weapons, and sale of goods.
1. Health and Safety at Work and Environment
1. Customer Relationship
1. Relationship with Third Parties
  1. Third parties
  1. Public and Private Agents
  1. Competitors
  1. Bidding processes
  1. Preceptorship
REPREHENSIBLE CONDUCT
1. Facilitation Payment
1. Child Labor Exploitation
1. Political Activities
OVERSIGHT
PRIVILEGED INFORMATION
ACCOUNTING RECORDS
TRAININGS

SANCTIONS
COMMUNICATION CHANNELS
UPDATE THIS CODE
GENERAL PROVISIONS

1. INTRODUCTION

The Code of Ethics and Conduct of São Judas Materiais Médicos establishes the guiding principles for the institution's commercial and interpersonal relationships with its employees, clients, partners, and civil society.

Therefore, our Ethical Compliance and Anti-Bribery program aims primarily to prevent illicit practices and, if identified, seeks to remedy them in the fastest and most effective way, not allowing them to be committed or encouraged in any organizational sphere or business relationship.

For the progress and fulfillment of this Code of Ethics and Conduct , São Judas Materiais Médicos is committed to always strengthening its management and monitoring mechanisms, disseminating information permanently and making itself available to its public to resolve any doubts and welcome suggestions.

2. SCOPE OF ACTION

This Code of Ethics and Conduct applies to São Judas Materiais Médicos, its headquarters and subsidiaries, and to all companies controlled by it, encompassing all its employees, directors, suppliers, service providers, representatives, and all its commercial and interpersonal relationships.

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

SCOPE

Through this Code of Ethics and Conduct , São Judas Materiais Médicos demonstrates its role in society and the values it cultivates. In this way, each professional who is part of the staff has a set of...

General rules of conduct, based on morality and ethics, as well as other specific company values and the Brazilian legal system, are established to guide the actions of all those who work for the institution.

4. PRINCIPLES

Principles are the foundation, the essence; they are the rules that a person or organization establishes to guide their decisions and behavior.

In this regard, São Judas Materiais Médicos declares the following principles:

RESPECT - The dignity of the person is a fundamental principle of society and of our institution, and any form of affront to the dignity, diversity, and privacy of individuals is unacceptable.
- HONESTY – Respect for and compliance with internal and regulatory rules preserve the honor of São Judas; therefore, we expect honest conduct, based on good faith, integrity, and sincerity.
- TRANSPARENCY – Transparency in actions is an important tool for promoting efficiency and combating corruption, as well as enabling accountability. Information must be clear, accurate, and complete, always respecting secrecy and confidentiality in a consistent manner.
- INTEGRITY – São Judas bases its actions on a commitment to always act consistently, fulfilling its social role and maintaining ethical, fair and honorable conduct, continuously seeking the common good.

5. VISION, MISSION AND VALUES

Based on its principles, São Judas Materiais Médicos operates according to its vision, mission, and values:

VISION – To be a benchmark in the distribution of medical supplies, recognized by customers, suppliers, employees, partners, and the community.
OUR MISSION – To provide health products, ensuring longevity and quality of life for people.
VALUES – São Judas Medical Supplies' core values are:
Ethics: we adopt it as the foundation of our business and interpersonal actions;
Respect for life: providing quality of life through our products is what motivates us.
Social responsibility: São Judas' growth is directly linked to the development of the community, which is why we strive for excellence in our services to improve the quality of life for everyone.
Taking care of those who make our company what it is: providing conditions for our employees to develop and offering an excellent work environment makes all the difference.

6. GOOD RELATIONSHIP PRACTICES

WORK ENVIRONMENT

The ethical stance of each individual who is part of the São Judas Materiais Médicos workforce is a decisive factor in creating a healthy work environment where everyone can develop professionally and remain motivated.

Interpersonal relationships are challenging in any organization, and to ensure the unity of all employees, São Judas promotes the best working conditions, providing a balance between the professional and personal lives of employees, as well as safety and health in the workplace.

Empathy and loyalty are values encouraged by São Judas to ensure unity among its employees, through internal cooperation, good communication, and mutual support.

The workplace should be a place of professionalism, respecting cultural, racial, ethnic, and gender differences. A dignified and healthy environment, governed by respect and cordiality regardless of hierarchical level.

All employees of São Judas Materiais Médicos must treat and be treated with respect and equality. Any manifestation or form of abuse of power, discrimination, threats, intimidation, violence, or moral or sexual harassment will not be tolerated. Furthermore, the employment of child or forced labor, directly or through any third parties involved in any aspect or to any degree, will not be permitted, nor will sexual exploitation or trafficking of human beings.

In this same vein and in compliance with current legislation, São Judas reaffirms its commitment to providing appropriate protective facilities and equipment for each of the activities carried out by its business areas, ensuring that each employee, in the performance of their duties, follows all notices, rules and procedures of the institution, as well as in accordance with applicable health and safety laws.

It should also be emphasized that, in order to maintain a good and healthy work environment, it is absolutely forbidden to be under the influence of drugs, alcohol or narcotics, whether within the organization or externally when representing São Judas.

6.2. PROFESSIONAL POSTURE

The staff at São Judas Materiais Médicos to perform their duties with the highest standards of quality and professionalism.

All employees must uphold the name of São Judas, ensuring that the company's values and standards are strictly followed. It is the duty of each team member to be aware of and practice the provisions of this Code, internal policies and standards, preserving the principles of integrity and honesty.

It should be emphasized that criticism of operational performance, feedback, guidance regarding internal and market policies, as well as requests for changes in conduct, are part of professional development and should not be understood as personal attacks.

Professionals on the team are required to act with ethics, integrity, professionalism, good faith, honesty, and fairness, always choosing the best and most advantageous option for São Judas when there is more than one.

Moral and sexual harassment

São Judas Materiais Médicos repudiates any conduct that may constitute harassment of any kind, treating it as a serious act of violence. Moral harassment when someone in a privileged position uses that advantage to humiliate, disrespect, or embarrass an individual or group. Moral harassment aims to destabilize a person professionally and emotionally, and can occur in different ways such as: accusations, insults, offenses, shouting, public humiliation, social exclusion, lack of respect for job responsibilities, and spreading rumors.

persecution.

At São Judas, we value cordiality and good interpersonal relationships.

It is important to highlight that actions such as: professional demands, specific corrective actions foreseen in internal regulations, increased workload, and the use of technological control mechanisms are not interpreted as workplace harassment.

Sexual harassment is a crime defined in the Penal Code (Article 216-A), characterized by the coercion of a colleague with the intent of obtaining sexual advantage or favor.

São Judas Materiais Médicos does not tolerate harassment of any kind, such as sexual, economic, moral, or any other type, nor situations that constitute disrespect, intimidation, or threats in the relationship between employees, regardless of their hierarchical level.

If you believe you are a target of the aforementioned actions, please report the incident through the communication and complaint channels available to everyone, via the official website saojudasmm.com.br or by email canaldedenuncias@saojudasmm.com.br .

6.4. USE OF DRUGS, ALCOHOL, POSSESSION OF WEAPONS AND SALE OF GOODS.

Every employee should take care of their image and maintain conduct appropriate to the professional environment.

São Judas Materiais Médicos prohibits the consumption of alcoholic beverages during working hours, as well as while intoxicated during professional duties. Consumption of alcoholic beverages is only permitted when provided at events promoted by the company.

The use of illicit drugs , besides being a crime, causes serious harm to users in various areas, including professionally. Therefore, the use and possession of drugs are not accepted by São Judas, nor is remaining on company premises under the influence of these substances.

Furthermore, the carrying of weapons and the sale of goods for personal gain that could, in any way, tarnish the image of São Judas Materiais Médicos are also prohibited.

These prohibitions aim to maintain the safety of employees, the proper performance of activities, and a healthy work environment.

HEALTH AND SAFETY AT WORK AND ENVIRONMENT

Health, physical integrity, and environmental protection are priorities for São Judas Materiais Médicos. Therefore, the PCMSO (Occupational Health Medical Control Program) and the PGR (Risk Management Program) have been implemented and are updated annually, according to the records that comprise the Compliance Program.

The PCMSO ( Occupational Health Medical Control Program) has a preventive character, focusing on screening and early diagnosis of work-related health problems, including subclinical conditions, as well as identifying cases of occupational diseases or irreversible damage to the health of employees.

In turn, the Risk Management Plan (PGR) proposes measures to prevent and control the risks identified, through their neutralization, minimization, or elimination. The PGR highlights the risks and guides São Judas and its staff on the risks, means to prevent or limit possible dangerous situations, aiming to preserve the physical and mental integrity of employees.

São Judas handles all environmental information that may have an impact on its employees, the community, or the environment itself in a transparent manner.

The employee must familiarize themselves with and strictly adhere to health, safety, and environmental policies, procedures, and practices, paying close attention to the work environment and identifying potential hazards.

CUSTOMER RELATIONS

This Code of Ethics and Conduct reflects an ethical and integral standard. With the ethical conduct of its employees, São Judas Materiais Médicos gains...

Respect in their business dealings and approval from the community.

Negotiations with our clients are based on ethical values and principles, integrity, and transparency, always providing the necessary information regarding the products purchased.

Customer requirements and expectations must be considered, and all agreed-upon terms must be strictly adhered to.

São Judas does not discriminate against clients based on origin, economic size, or location, reserving the right to terminate any business relationship whenever its interests are not being met or when the relationship represents a legal, social, or environmental risk.

The relentless fight against corruption is intrinsic to the mission and values of São Judas Materiais Médicos and its employees; therefore, we are committed to:

not to give, offer or promise any valuable asset or advantage of any kind to public officials or persons related to them, or any other persons, companies and/or private entities, with the aim of obtaining undue advantage, influencing an act or decision or illicitly directing business; and
To adopt best practices for monitoring and verifying compliance with anti-corruption laws, with the aim of preventing acts of corruption, fraud, illicit practices or money laundering by its partners, administrators, employees and/or third parties contracted by them.

Proven violation of any of the aforementioned obligations will be considered just cause for unilateral termination of the contract.

It is of utmost importance to be careful with technical information intended for employees and customers, as incorrect information is considered a source of risk with consequences for the image and financial assets of São Judas Materiais Médicos.

RELATIONSHIPS WITH THIRD PARTIES

6.7.1.THIRD PARTIES

Third-party contractors are also subject to the provisions of this Code, and must be aware of and committed to it in the performance of activities carried out within the scope of their relationship with São Judas Materiais Médicos, by signing a liability waiver or equivalent document, if they do not have a Code of Ethics and Conduct , or if they do have one but it is not compatible with this Code.

The Compliance Officer of São Judas may waive, subject to specific regulations on the matter, the prior requirement in contracts for the acquisition of common or simple goods or services, such as off-the-shelf goods like consumable materials, food, passenger vehicles for company use, telephony, etc.

6.7.2. PUBLIC AND PRIVATE AGENTS

The actions of those representing São Judas Materiais Médicos must, in all cases, be guided by good faith, integrity, and transparency, maintaining, under any circumstances, the highest ethical standards of conduct, especially when dealing with public and private agents.

It is expressly forbidden to promise, offer or grant, directly or indirectly, any undue advantage, pecuniary or otherwise, to a public or private agent (or through third parties related to them), and facilitation payments, especially those to expedite administrative procedures, are prohibited.

In dealings with public and private entities, the provisions of the Anti-Corruption Policy, which is part of the Compliance Program of São Judas Materiais Médicos, must be observed.

6.7.3. COMPETITORS

The relationship with competitors should be friendly, based on good faith and respect. The relationship will be guided by best business practices, in accordance with organizational values and observance of the good practices foreseen in this Code, respecting the constitutional principle of free competition.

Employees are prohibited from adopting any attitude that denigrates the image of business partners or competitors of São Judas Materiais Médicos, as well as from disclosing information, even if true, that may cause harm to them.

In dealings with competitors, it is prohibited to provide confidential information, trade secrets, and business plans of São Judas.

Above all, agreements with competitors should not be promoted with the aim of abusing economic power or engaging in arbitrary commercial practices.

6.7.4. Tenders

The actions of São Judas are based on the unrestricted obedience to the constitutional principles of the economic order, especially the principle of free competition, which is considered a general principle of economic activity, aiming at social justice, solidarity, and the dignity of the human person.

In accordance with this principle, employees and those acting on behalf of São Judas Materiais Médicos are prohibited from engaging in any conduct that may, directly or indirectly, frustrate or defraud the competitive nature of public or private procedures.

It is expressly forbidden to carry out acts aimed at corrupting or bribing public officials, especially for the purpose of obtaining...

undue advantage or benefits obtained through the signing, amendment, extension, or termination of a public or private contract.

São Judas Materiais Médicos reiterates its unwavering adherence to the normative precepts of Law 8666/93 (Public Procurement Law), Law 14.133/21, Law 12846/13, and Decree 8420/15 (Anti-Corruption Law).

PRECEPTORSHIP

During its operations, for commercial and business reasons, São Judas Materiais Médicos acts as a facilitator of knowledge by establishing preceptorship agreements.

The Preceptor is the professional who acts as a link between theoretical knowledge and professional practice. Since the company operates as a representative of products in the cardiology and audiology fields, with innovative and pioneering technologies, it is often necessary to hire preceptors to train professionals on the use of the products marketed by São Judas.

This line of action is also subject to the provisions of this Code of Ethics and Conduct , and must follow the guidelines set out in its own Policy, which is part of the Compliance Program.

7. Reprehensible Conduct

São Judas Materiais Médicos, in accordance with its ethical principles and applicable legislation, does not tolerate any form of corruption or transgression of the provisions of this Code of Ethics and Conduct .

São Judas prohibits its employees and those who represent the company from participating in any form of corruption in any context.

7.1. RECEIPT OF UNDUE BENEFITS

São Judas Materiais Médicos prohibits its employees, and those who represent it, from soliciting or accepting any money or item of value, including business courtesies, in exchange for improper services, information, or advantages.

No one involved, directly or indirectly, with São Judas may accept any offer of value from a third party that seeks to unduly influence business decision-making.

It is understood that business relationships are positive and cordial, and the receipt of courtesies and gifts is common in this area, representing a legitimate way to build relationships. These relationships should be based on transparency and ethics, always in accordance with applicable anti-corruption laws and with the rules and policies widely disseminated within the organization. Therefore, receiving gifts is only legitimate if it does not constitute a means of reward or inducement to improper or corrupt acts or decisions.

São Judas always bases its relationships on what is ethical, transparent, honest, and legal.

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 in order to facilitate, expedite, or encourage a specific routine or necessary action, such as the issuance of documents, licenses, and certificates.

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.

7.3. POLITICAL ACTIVITIES

Employees are prohibited from making any contributions, in the name of São Judas Materiais Médicos, in the form of donations to finance election campaigns, including political parties or financial committees. Furthermore, the offer or provision of any service, granting of loans, or the transfer of assets, personnel, or favors that could constitute an unauthorized election contribution, contrary to electoral regulations or the company's established policy, is strictly prohibited.

8. INSPECTION

São Judas Materiais Médicos, respecting the principles of transparency and integrity, prohibits actions that may hinder or interfere with internal or external oversight activities, especially those of regulatory bodies.

Employees and representatives of São Judas Materiais Médicos must facilitate the full development of any inspections carried out by public bodies, entities, or agents, as well as those performed by private companies due to agreements or contracts signed with the organization, in accordance with current legislation. Similarly, staff are subject to periodic inspections of their workstations, email, and corporate cell phones, in order to ensure compliance with this Code of Ethics and Conduct and other internal policies.

Any inspections that São Judas may undergo must be directly accompanied by a company representative holding a Director, Manager, Coordinator, or Technical Manager position, or another person more suitable for the proper conduct of the inspection process.

Inspections may occur on a scheduled basis or without prior notice, respecting compliance with applicable legislation, internal policies and rules, especially those concerning the confidentiality of information, and respecting the principle of human dignity.

9. Privileged Information

Insider information is strategic or confidential data not known to the market, the disclosure of which could affect the operations of São Judas Materiais Médicos. Employees may have access to it as part of their duties and responsibilities or casually and inadvertently.

Privileged information may not be disclosed or made available to third parties without the express authorization of the Board of Directors of São Judas Materiais Médicos.

The handling of information will be governed by its own policy.

10. ACCOUNTING RECORDS

In keeping with the principles of integrity, transparency, and accountability, all accounting and financial records of São Judas Materiais Médicos must be kept accurately and clearly, in accordance with applicable rules and regulations.

All staff, management, and representatives of São Judas must accurately and meticulously document and record all expenses in the name of São Judas Materiais Médicos. They are prohibited from concealing or misrepresenting company expenses or making payments in the name of São Judas without proper approval and verification of the transaction's validity.

11. TRAINING

For this Code of Ethics and Conduct , regular training for all employees of São Judas Materiais Médicos is essential.

Efforts are being made to ensure that everyone is aware of what is presented here; therefore, São Judas adopts a training plan, which includes:

Training;
- Lectures;
- Workshops. Accompanied by:
- Primers;
- Official announcements;
- Banner;
- Brochures; and
- Awareness material.

Maintaining the ethical commitment presented here is paramount for São Judas and is an integral part of the Compliance Program.

12. SANCTIONS

Any employee who demonstrably violates or fails to observe the provisions of this Code of Ethics and Conduct, Brazilian legislation, and other internal rules and policies, as well as the values of São Judas Materiais Médicos, may be penalized with the application of the following sanctions, taking into account the seriousness of the conduct and any recurrence of the act:

Disciplinary Warning: a minor penalty, which may be verbal or written;
Suspension: intermediate penalty, suspension of up to 30 (thirty) consecutive days, when applicable; or

Termination of employment: the maximum penalty applied in cases of serious misconduct and follows the provisions of current legislation. Dismissal of the offender without just cause or with just cause;

IV. Application of the stipulated contractual penalties.

Regardless of the penalties mentioned above, employees may be notified by the Executive Management and/or Board of Directors of São Judas Materiais Médicos to immediately cease any inappropriate or inadequate conduct, in accordance with this Code of Ethics and Conduct .

The penalty will be applied according to the severity of the actions and the extent of the damage caused. São Judas Materiais Médicos reserves the right to file a claim for reimbursement against the employee or third party, when applicable.

13. COMMUNICATION CHANNELS

Any suspicion of activity carried out in violation of current legislation, this Code of Ethics and Conduct , or other internal rules and policies, must be immediately reported to the Compliance Officer, who will impartially investigate the facts and take appropriate action in accordance with the Whistleblowing Channel Policy.

The communication may, at the employee's discretion, be carried out confidentially and anonymously, guaranteeing the necessary protection for the full realization of their complaint, noting that São Judas Materiais Médicos has a primary obligation to ensure the effective application and dissemination of this Code of Ethics and Conduct .

Complaints can be made through the communication and reporting channels available to everyone, via the official website saojudasmm.com.br or by email to the Compliance Officer at canaldedenuncias@saojudasmm.com.br .

14. UPDATING THIS CODE

The current version of the Code of Ethics and Conduct was last updated on August 1, 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.

15. GENERAL PROVISIONS

This Code of Ethics and Conduct supersedes its previous version upon approval. If you have any questions about this Code, please contact our Compliance Officer via email at canaldedenuncias@saojudasmm.com.br .