code of ethics and conduct

Code_of_Ethics_and_Conduct.indd 1 10/13/16 2:38 PM

1 Organisational Guidelines ................................................................................... 04

2 Atlantic welcomes you ........................................................................................... 07

3 Introduction .................................................................................................................. 08

4 Relationship with collaborators ...................................................................... 10

5 Relationship with clients ...................................................................................... 12

6 Relationship with the communities .............................................................. 13

7 Relationship with suppliers ................................................................................ 14

8 Commercial integrity .............................................................................................. 15

9 Relationship with Governmental and Regulatory Agencies ...... 16

10 Relationship with the Press ................................................................................ 17

11 Relationship with stakeholders ....................................................................... 18

12 Health and Safety ...................................................................................................... 19

13 Environmental .............................................................................................................. 20

14 Conflict of interests.................................................................................................. 22

15 Gifts and entertainment ....................................................................................... 23

16 Protection and use of information and assets ...................................... 24

17 Ethics and Conduct Committee ....................................................................... 26

18 Channel of Ethics and Conduct ........................................................................ 27

19 Commitment agreement ...................................................................................... 29


Organisational Guidelines

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MISSIONTo generate renewable energy in a social and environmentally responsible manner, while investing in technology and human resources so as to contribute to the country’s development.

VISIONTo be a leading company in the Brazilian renewable energy market, seeking the best outcome for our shareholders, for our staff and for the communities where we operate.

VALUES• Constant search for the best results, while upholding

the highest safety and quality standards.

• Dedication to contribute to sustainable development.

• Integrity and honesty in everything we do.

• Respect for the human being and for our relationships.

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The foundation that supports the growth, development and strengthening of Atlantic on the market is based on its culture, corporate governance model and especially on its ethical conduct and transparency in conducting business.

Given these premises, we present our Code of Ethics and Conduct, which allows all direct and indirect partners to know, understand and practice the ethical standards in relations with the company.

The commitment of all related parties to the principles outlined in this material is irrevocable.

Atlantic is a company that aims to be a reference in the sector which it operates, but none of this is possible without credibility.

Credibility reflects the effective practice of actions performed in our daily lives such as integrity, honesty, transparency, safety, quality, clients and shareholders satisfaction, respect for employees, partners, legislation, environment and community.

Thus, it is the duty of all to know, understand and apply all the recommendations established in this Code of Ethics and Conduct, respecting the values on which they are inspired.

Regards,Jose Roberto de Moraes CEO

Atlantic welcomes you

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The Atlantic Code of Ethics and Conduct must be followed by everyone involved with the company in all functions, places and levels: employees, contractors, suppliers, directors, board members and any other person related to Atlantic or acting on behalf of the company. Regardless of position, non-compliance with this guideline will not be accepted. Non-compliance may result in serious damage to the image of the company in the market.

If employees or collaborators have any questions about the code, compliance and other policies or practices of the company, these questions should be taken to the Channel of Ethics and Conduct.

Learn more about our Channel of Ethics and Conduct Through the website www.contatoseguro.com.br or call 0800 601 8659

Introduction

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Atlantic recognizes the right of its collaborators to fair remuneration, fair and appropriate benefits in return for their work, competence, responsibilities and accomplishments.

• Transparency: Atlantic considers transparency in relationships with its collaborators a fundamental issue for the building of an environment of mutual trust and responsibility at all levels of the company;

• Discrimination: Atlantic does not accept any form of discrimination on race, age, sex, color, nationality, religion, sexual orientation, physical or mental disability;

• Harassment and moral damages: Atlantic does not tolerate any form of harassment, moral or sexual, or any other conduct that could be described as offensive or embarrassing and that might cause any form of moral damage to any collaborator;

• Use of illegal labour: Atlantic does not allow the use of forced, compulsory or child labour or any other way of exploitation that violates human dignity inside or outside the company;

Relationship with collaborators

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• Integrity: Collaborators must honor the principles established in this Code of Ethics and Conduct when representing the company, in social and professional situations;

• Company Assets: all collaborators are responsible for the maintenance, care and protection of assets and company property, and no collaborator, under any circumstance, can take ownership of assets or corporate resources, or use them for their own benefit or that of third parties;

• Preservation of information: each collaborator must ensure that the company’s proprietary information is adequately protected and unable to be accessed by unauthorized people;

• Employee recognition: Atlantic believes that our collaborators are a very important part of our success and the company incentives their development. Managers should use meritocracy as a criterion to promote the professional development of the company’s employees.

Atlantic endorses the restrictive government policy about the consumption of alcohol and illegal drugs as well as being under the influence of those substances during the workday. Smoking is not allowed indoors, according to the legislation.

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Atlantic’s relationships with clients must be based on the following guidelines:

• Courtesy, promptness and effective service;

• Respect for the client’s rights;

• Transparency in operations;

• Openness and appropriate treatment of suggestions and criticisms;

• Confidentiality of received information;

• Dignified and fair treatment, not providing misleading or false information about the company’s products;

• The disclosure of information related to clients is forbidden, unless formally authorized by the Internal Communications area of the company or for the compliance with legal requirements.

Relationship with clients


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Atlantic has the privilege of doing business in several different communities throughout Brazil, becoming a member of such communities. As a member of these communities, the company must always act responsibly. It means:

• Ensuring that all those who are involved with Atlantic’s activities work in the development and implementation of community action plans;

• Respecting the local culture where projects are implemented;

• Contributing to the sustainable development of communities.

Relationship with the community


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The contracting of suppliers and business partners must comply with technical and ethical criteria based on the good reputation, financial and professional capacity of the company, considering fair prices.

All collaborators must respect the contractual and commercial conditions and protect the confidentiality of information established between Atlantic and its suppliers, respecting conditions of mutual trust in the confidentiality and contractual guarantees, under risk of disruption of business relations.

Atlantic does not accept that employees use the influence of their position in the company to achieve personal advantages or benefits.

Suppliers and business partners contracted by Atlantic must comply with all existing legislation, including labour, tax, environmental, health and safety. Child labour or slavery are forbidden.

All suppliers and business partners must guide their behavior by the principles established in this Code of Ethics and Conduct. At any time, the supplier or business partner who fails to meet the aforementioned requirements will be disqualified.

Relationship with suppliers


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Atlantic does not offer or pay for any financial and personal benefit in its commercial relations. All appropriate measures will be taken to ensure that everyone involved in its activities comply with all legal and regulatory requirements.

Check the Anti-corruption Manual available atwww.atlanticenergias.com.br

Commercial Integrity


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All kinds of relationships with the Government and Regulatory Agencies are conducted with impartiality and transparency, in connection with the existing legislation, particularly with the Anti-Corruption Law.

Practices involving preferential treatment, promises or granting direct or indirect personal benefits of any kind to authorities or public officials are unacceptable and illegal, according to the applicable law.

When publicly representing Atlantic, collaborators should refrain from expressing opinions or comments of political nature.

The complete commitment to the laws concerning public administration, such as the Anti-Corruption Law is essential in conducting business. Therefore, there will be no tolerance for illegal practices such as corruption, extortion and bribery in all its forms.

Relationship with Government and

Regulatory Agencies


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Our relationship is based on transparency, credibility and trust, constantly observing the ethical values outlined in our marketing strategy as well as the delivery of company information.

Our authorised representatives will speak on behalf of the company and ensure the availability of accurate information about the business. Therefore, no employee of the company is allowed to speak on behalf of the company, either through the media and social networks.

If there is any occurrence or complaint regarding the company’s image:

• The veracity of information will be evaluated;

• Transparent and timely communication will be used;

• Information about actions will be disclosed.

Atlantic rejects considerations on company information without proper verification of the facts as described above.

Relationship with the Press


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Atlantic respects the principle of equal treatment of shareholders and the company is transparent in the distribution of dividends in the statements of financial position. Information is always available via restricted channel through the company’s website at Extranet.

Relationship with shareholders


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Atlantic meets all health and safety standards in the workplace, therefore, all employees must comply with the procedures and instructions that regulate and protect safety and health.

Atlantic identifies and evaluates all the dangers and health and safety risks of all operations and takes measures to mitigate them, reporting regularly on health and safety management systems and performance of the operating equipment.

In its facilities the company ensures:

• Compliance with all applicable laws, regulations and international standards;

• Development, implementation and maintenance of specific programs and procedures for health and safety facilities;

• Preparation to respond quickly and efficiently to health and safety incidents;

• Concern, awareness and respect for health and safety issues through communication and training for all employees, suppliers and business partners.

Health and Safety


Atlantic aims to protect the environment, biodiversity, fauna and natural resources and promote the continuous improvement of the areas with sustainable practices. The company is committed to the principles of sustainable development, such as:

• Take into account the environmental impact of all its operations and take measures to mitigate any risks;

• Ensure that operations examine the impact on diversity and implement appropriate mitigation measures;

• Present reports on the environmental management system and performance of their operations through the ESG Committee (Environmental, Safety and Health, Governance) on a regular basis;

• Review the actual and expected future benefits from investments in the context of production / savings and greenhouse gases every year;

• Atlantic respects the Brazilian environmental legislation and supports initiatives and activities aimed at the sustainable development of the country;

• Atlantic believes in the importance of sustainable actions for the conservation of natural resources and preservation of the planet;

• Employees must conduct their activities and projects with all due respect to the environment according to sanitary norms and regulations, in order not to harm the environmental balance.

Environmental

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Conflict of Interests

All executives and collaborators must be loyal in their activities related to the business and decision taking according to their levels of authority, aiming solely at the company’s interests.

• Personal activities that may lead to conflict of interests of the company are not allowed unless specifically approved in advance by the Board of Directors;

• Private investment activities are not prohibited, however, if the investment presents any potential conflict of interest with Atlantic and its businesses, it must be reported to the CEO. In the case of any Board of Directors member, it must be reported to the Board itself.

Situations that may create a conflict of interest, real or potential, must be discouraged by all.


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Atlantic allows the acceptance of gifts within its business relationships upon the observation o lowing rules:

• Corporate gifts such as diaries, pens, calendars and others may be received when directed to employees or the specific area;

• Other corporate gifts such as sports or cultural events tickets, meals, beverages, discounts not available to the general public and other goods or services must be directed and communicated to the Human Resources area for the adequate destination to NGOs and philanthropic institutions.

Please observe the rules regarding the acceptance of any gift from governmental agencies on the Anti-Corruption Manual available on our website.

Gifts and Entertainment


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Protection and use of information

and assets

Atlantic aims to preserve its information and assets through the following measures:

• Use of electronic means of information: all subjects regarding the disclosure of company information are available at our website www.atlanticenergias.com.br and social networks. Broadcasting any information or internal document on the Internet is prohibited;

• Electronic communication: collaborators must use the available electronic communication resources only and exclusively for business purposes within the legal requirements and following the ethical principles of this Code of Ethics and Conduct. The transmission of defamatory comments, offensive images or files that may lead to any form of discrimination or any type of cybercrime is prohibited;

• Integrity of information: all collaborators are responsible for the accurate and reliable information contained in the records and documentation that support the activities of the company, therefore, adequate data correction is necessary as well as the maintenance of all documentation in accordance with the established internal procedures policies and legal / tax requirements.


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It is necessary to be aware that these requirements help ensure that the company is running effectively and that reports provide accurate and reliable information on the financial performance of the company to shareholders.

Furthermore:

• All collaborators are responsible for property protection;

• It is the responsibility of all to protect confidential business information and not to use them, except if necessary for the proper performance of activities and under authorization;

• Employees must protect property, assets, equipment, including hardware, software, mobile phones, furniture, among others, and intellectual property of all kinds;

• Disposal of any property or asset must be informed to the responsible area for inventory control;

• Unauthorized copies of copyright protected content, such as software, music or videos are prohibited;

• Installation of personal software is not allowed in order to ensure the proper functioning of equipment and minimize risks to the internal network.


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All members of the Ethics and Conduct Committee have skills, experience and competence to occupy this position and have great credibility in the company.

The responsibilities of the Ethics and Conduct Committee are:

• Reply to all suggestions and complaints made through the Ethics Channel, based on analysis and investigation of the reported information;

• Report acts that are not in accordance with the Code of Ethics and Conduct to the Board of Directors, in order to solve the issues in cases defined as serious;

• Compliance with the Internal Rules of the Ethics and Conduct Committee.

Any member of the Ethics and Conduct Committee will be removed for further investigation if involved, directly or indirectly, in any complaint procedure.

The characteristics of the Ethics and Conduct Committee reflect the identity and organisational culture of the company and its activities are guided in the pillars and ethical principles highlighted here.

Ethics and Conduct Committee


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Atlantic believes we can build a great company to work for and be a reference through its credibility in the market. You can find the Channel of Ethics and Conduct on our website, which is managed by the company Contato Seguro CNPJ 10.916.727 / 0001.77 in order to ensure the confidentiality and security of information.

To access, send suggestions or inform any kind of behaviour deviation out of the principles contained in the Code of Ethics and Conduct, please contact us:

www.contatoseguro.com.br

Ethics Hotline: 0800 601 8659

Channel of Ethics and Conduct


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I hereby declare that I am in accordance with the Atlantic Code of Ethics and Conduct. I agree to follow the guidelines and principles of conduct established by Atlantic and I am aware of the importance of practicing and implementing the rules contained therein.

The acceptance of this term is a manifestation of my voluntary agreement.

Name:

Number:

Company:

Place and date:

Signature:

Code of Conduct Commitment Agreement


code of ethics and conduct

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