1. OBJECTIVE

The Anti-Corruption Policy aims to affirm that TNAX Synthetic Ropes, or simply TNAX, is not complicit in acts of corruption, in addition to defining the rules and guidelines based on the Brazilian Law 12.846 / 13 (Anti-Corruption Law) and other applicable legislation, to conduct all our businesses with ethics, transparency, independence, integrity and regularity aiming to ensure the credibility and image of the company.

2. TARGET AUDIENCE

This policy applies to TNAX's management, employees and third parties (customers, suppliers, sales representatives, consultants, etc.).

3. CONCEPTS

Corruption is the action or effect of corrupting, dishonest, fraudulent or illegal behavior that involves the exchange of money, values or services for one's own benefit and the alteration of the original state or characteristics of something. The most common form of corruption is bribery. Bribery means paying, offering, promising or receiving an improper benefit in order to influence someone's behavior to obtain or retain some type of business advantage. A bribe can take many forms - such as offering or delivering money or anything else of value. In fact, even common trading practices or social activities, such as giving gifts or hospitality, can constitute a bribe in certain circumstances. Illicit acts mean contradicting ethical principles in order to obtain any advantage, be it financial or not. It is an act prohibited by laws or rules.

4. PROCEDURE

Acts of corruption and bribery should not be committed to the public that involves the company, nor should they make use of intermediaries, such as agents, consultants, distributors or any other business partners for this purpose.

TNAX makes no distinction between public or private agents regarding the occurrence of acts of corruption and bribery. In this way, corruption and bribery are not tolerated, regardless of the recipient's position.

We advise personal questioning before any act that can be seen as an illegitimate practice. If the answer is affirmative, or if you are not sure if this is a legitimate practice, do not proceed with the action until you are sure that you are not engaging in an act of corruption.

5. GUIDELINES

The public connected to TNAX is not allowed to:
• Promising, offering or giving, directly or indirectly, an undue advantage to a public agent, or a third person related to it;
• Finance, fund, sponsor or in any way subsidize the practice of illegal acts;
• Use another person or entity to hide or conceal your real interests or the identity of the beneficiaries of the acts performed.

Regarding bids and contracts, it is considered as intolerable:
• Failure to comply with the requirements of the Brazilian Law 8.666 / 93 (Bidding Law);
• To frustrate or defraud, by means of adjustment, combination or any other expedient, the competitive nature of a public bidding procedure;
• Prevent, disturb or defraud the performance of any public bidding procedure;
• Remove or seek to remove a bidder, by means of fraud or offering an advantage of any kind;
• Defrauding public bidding or contract resulting from it;
• Create, in a fraudulent or irregular manner, a legal entity to participate in public bidding or enter into an administrative contract;
• Obtaining an improper advantage or benefit, in a fraudulent manner, from modifications or extensions of contracts entered into with the public administration, without authorization by law, in the call for tenders or in the respective contractual instruments;
• Manipulate or defraud the economic and financial balance of contracts entered into with the public administration.

Collaboration with public agents and agencies:
• It is forbidden to hinder the investigation or inspection activity of public bodies, entities or agents, or to intervene in its performance, including within the scope of the regulatory agencies and supervisory bodies of the national financial system.

Accounting Books and Records:
• TNAX is obliged to register its accounting, operations and financial transactions in a detailed, correct and accurate manner. Your records must be filed for any audit and / or investigation processes;

6. ACCEPTANCE OF POLICY

Employees and third parties must review this Policy and confirm that they understand its content. Additionally, managers must commit themselves to adhere to their terms and conditions, applying them in their corresponding functions.

7. DECISIONS, WAIVER AND QUESTIONS

Managers have the authority to make decisions, take measures, give instructions and guide, as appropriate to the implementation and application of this Policy, in addition to managing, monitoring or resolving declared or notified conflicts, exercising such authority after considering all relevant facts. The waiver of any directive in this policy or its suspension, will only be approved by the managers of TNAX.

Any kind of questioning regarding this Policy, or the need for guidance or clarification on how it applies to specific situations, suspicion or occurrence of acts that are being performed or that will be performed in violation of it, must be made through contact with the TNAX managers, using any of the current communication channels.

8. ETHICS CHANNEL

TNAX believes that the effectiveness of an Integrity Program is only real with the unconditional participation of all the people who make up the company. Thus, it is the responsibility of each employee and third parties to comply with the explicit conduct in this Policy.

When verifying situations that characterize a violation of the conduct provided for in this policy, they must be reported in order to help the company build a more healthy environment. The situations can be presented to the immediate manager and, if the protester is not comfortable, he can try to submit his demand through the email contato@tnax.com.br , or in person.

Any and all information related to the report will only be accessed by the managers, who have the responsibility to keep the information received confidential. TNAX guarantees that its employees, or third parties, will not suffer any type of retaliation or intimidation for using good faith when making a report.

9. NON-ADHERENCE

Employees who violate this or any other company policy will be subject to disciplinary measures contained in this document or related laws.

10. RELATED POLICIES

The guidelines mentioned in this document are also referenced in the Code of Conduct, comprising both the TNAX integrity policies.