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ETHICS AND COMPLIANCE

Whistle Blower Policy

In compliance with the requirement of Companies Act, 2013 and Listing Agreement with the Stock Exchanges, the Company has adopted a Whistle Blower Policy (the “Policy”). All protected disclosures under the Policy should be reported / routed through Ombudsman channels as defined in the Code of Conduct and put under Ethics Point website link .

Ethics and Compliance

At Votorantim Cimentos, we are committed to customer success, empowered employees, sustainability and operational excellence.  We also know that our success in these areas will only be achieved if we act ethically with integrity and transparency. That’s why our Values and Beliefs and Code of Conduct reinforce our companywide commitment to Compliance. We expect employees at all levels, from operational roles to our board of directors, and shareholders to follow the Code of Conduct guidelines and to comply with all laws, regulations and policies in the regions and countries where we operate. We are constantly searching for best practices, encouraging the fight against corruption and emphasizing the damages caused by corruption in political, economic and social domains.

At Votorantim Cimentos, we have zero tolerance towards corruption, bribery and facilitation payments. We prohibit the offer or receipt of any kind of advantages meant to secure an unfair business or personal gain, especially with regard to public officials or government authorities. This includes receiving and offering gifts, providing entertainment and hospitality, extending corporate invitations or any other act that is in conflict with local laws and regulations or is contrary to our own policies. Effective in 2017, Votorantim Cimentos has had in place a Donations and Sponsorship policy that restricts and governs political donations. In all instances, employees of Votorantim are expected to respect and abide by the guidelines outlined in our Code of Conduct.

Since 2013 we have maintained a Compliance Program with communication and training campaigns aimed at all employees at all levels within the Company. We monitor the effectiveness of the program regularly, and take the necessary measures in the event of infractions, intentional or unintentional. We also encourage the reporting of any suspected wrongdoing through our Ethics Line and we do not tolerate any form of retaliation against those who raise these concerns. Our Ethics Line - public and open to all, inside and outside of the organization — provides a way to report misconduct (real or perceived) in a confidential and anonymous manner. All reports are investigated and addressed in accordance with internal policies and current laws and regulations.

Our programs and policies are constantly evolving as we consolidate best practices and adapt to changes in our society, while preserving our enduring legacy of integrity, ethics and transparency.

Votorantim has above Ethics line in order to learn about, analyze and solve issues regarding its Code of Conduct. This channel may be accessed both by internal and external audiences.

Impartial and transparent, the Ombudsman ensures the confidentiality of all information, preserving the identity of people involved, and collaborating to promote a better environment for everyone. The Ombudsman may be contacted to clarify doubts regarding the interpretation of the Code of Conduct, and to make complaints of violation of the Code of Conduct, such as corruption, bribery, fraud, environmental aggression, false information, inadequate accounting records, poor use of the Company's assets, discrimination by race, color, religion, sex, physical or social condition, and unethical behavior and procedures.

Every complaint received by Votorantim will be treated confidentially. No retaliation will be accepted against anyone who makes a report in good faith.