Code of Ethicsand

Conduct

Principles:

The Code of Ethics and Conduct of G.C. Global Catering reflects the commitment to achieve business objectives with social responsibility, valuing its relationship with employees, customers and suppliers, preserving the environment, ensuring excellent quality standards, good food safety, health and safety practices at work and also contributing to the development of the communities where we operate.

The Code is based on the corporate values of G.C. Global Catering and the principles set out by the UN Global Compact and supports the search for the good corporate and financial governance practices, for a transparent, objective and timely communication, and actions and decisions ever made with responsibility, quality, honesty, trust, respect and loyalty.

It is the duty of all members of the G.C. Global Catering (management and employees) in all working units to comply with and enforce the provisions of this Code, being assigned to the leaders the additional duty to disclose and ensure the fulfillment of this document in their respective Workspaces.

Therefore, it is understood that conduct that would characterize any violation of the principles of this Code and those in violation of laws and ethical standards of society at large, will be considered serious offenses .

In order to ensure the commitment and application of the Code, G.C. Global Catering features the Ethics and Conduct Committee formed by directors and managers.

The code is valid indefinitely. Ir should be distributed to all members of the G.C. Global Catering, who may not claim in any case or in any case, lack of guidelines and principles contained therein. Partners, suppliers, customers and communities can also access it via website: www.globalcatering.com.br

UN Global Compact

Ethics

HUMAN RIGHTS, HUMAN RIGHTS, which are derived from the Universal Declaration of Human Rights::

1. The Company should support and respect the protection of internationally proclaimed human rights

2. The Company must ensure that it does not condone any human rights abuses

WORK, which are derived from the Declaration of ILO - International Labor Organization - onFundamental Principles and Rights at Work::

3. The Company must ensure the right of association in work and the effective recognition of the right to collective bargaining4. The Company should support the abolition of all forms     of forced or compulsory labor5. The Company should support the effective abolition of child labor6. The Company should support the elimination of discrimination in respect of employment and occupation

ENVIRONMENT, which are derived from the Declaration of Rio on Environment and Development:

7. The Company should support a precautionary approach to environmental challenges8. The Company must commit itself to the promotion of greater environmental responsibility9. The Company should encourage the development and diffusion of technologies that do not harm the environment

ANTI-CORRUPTION, which it is derived from Convention of United Nations Against Corruption::

10. The Company should work against corruption in all its       forms, including extortion and bribery

Code of Ethics and Conduct

“The G.C. Global Catering guided by the UN Global Compact, whose ten principles endorse and systematically practices, integrating them into its processes. "

Corporative Values:“The practice of our Corporate Values unites usand shapes our attitudes, enhancing ourresults and ensuring perpetuity of the Company. "

We encourage individual development, but work as a team. We value the expertise, individuality and contribution of all employees who work helping each other and readily share best practices for achieving common goals.

We always set the highest ethical and professional standards. We hope that all our relationships are based on honesty, respect, justice and a commitment towards open dialogue and transparency.

Passion for Quality.

We take responsibility for our actions, individually and as a group. We always seek to make a positive contribution to the health and well-being of our customers, employees, the communities where we work and the world in which we live..

We ensure that no activity is started or the work to be stopped if adequate measures for the control of HSE risks are not in force. We will do it safely or we will not do it.

Openness, Trust and Integrity

The supply of products and service of superior quality is our passion, and we are proud to reach it. We seek to replicate success, learn from mistakes and develop the ideas, innovations and practices that will help us improve and lead the market..

Safety, Environment and Health.

Success through teamwork

Responsibility

1. Conduct of Company:

a) No form of discrimination is tolerable, whether by religion, philosophical or political conviction, nationality, family economic status, national origin, sex, color, ethnicity, disability, age, obstetric status, sexual preference, biotype, health status or marital status.

b) It is forbidden any kind of harassment within the Company, especially of moral and sexual nature, involving any verbal or physical conduct of humiliation, coercion or threat to the Company's members, or creating a hostile work environment that unreasonably interferes with individual performance or affects the working conditions involved.

c) In hiring and while there is an employment relationship with the company, people who have direct family relationship with the other (s) employee (s) shall ensure that no conflicts of interest as per human resources management.

d) It is guaranteed the freedom of association of employees to any trade associations legitimately constituted, as well as the right to collective bargaining in the workplace is Recognized.

1.1 With its members and administrators

e) The existence of any form of child labor, forced or compulsory within the company is prohibited.

f) The Company shall not relate to companies who practice child labor, forced or compulsory, as suppliers, contractors, customers or partners.

g) It is unacceptable the occurrence of any form of protectionism or privilege in the relationship between leader and led.

h) The privacy and confidentiality of personal information should be respected.

i) The Company must provide an environment and working conditions safe and healthy.

j) The Company must provide an environment and working conditions safe and healthy.

1. Conduct of Company:

a) The relationship of G.C. Global Catering with their partners should be based on the existing rules and on accurate communication, transparent and timely information they needs to follow the Company's activities and evaluate their performance and potential.

b) The Company should generate and maintain its records and financial statements in strict consistency with the rules, standards and best practices, allowing a reliable basis for evaluation and disclosure of its operations.

1.2 With its stakeholders and the market in general

1.3 With its customers, suppliers, partners and Governments

a) The Company must always conduct its negotiations with honesty and ethics, both with customers and with suppliers, partners and governments.

b) The suppliers and partners hiring decisions should be guided by objective criteria covering all key aspects of selection, among them technical compliance, performance, quality, price and payment terms, terms, guarantees, risk, post-sale conditions and what is most relevant in each case.

c) The Company shall not take action that would detract from the image of its clients, suppliers, partners and governments.

d) The Company must adopt, in their interactions and practices, in all situations, the highest ethical and integrity standards in business, which includes fully comply with applicable law and the principles and values of the Company as well as its applicable policies and procedures.

1. Conduct of Company:

a) It is not permissible to use unethical or illegal methods to obtain information about competitors such as trade secrets, inducing the disclosure of confidential information of its employees or theft of sensitive and confidential information, among others.

b) The Company must not take actions that could harm the image of its competitors and their products and services.

1.4 With your competitors 1.5 With the environment

The Company must give priority to preventive action with respect to environmental challenges in its processes. Likewise, it should undertake initiatives to promote greater environmental responsibility in the environments in which it operates, demanding the same of its suppliers, partners and service providers.

1.6 With the bodies representing legally constituted employees

The Company recognizes the right to collective work bargaining of its employees and must always act with integrity in the processes of communication and discussion with their legally constituted representative bodies, always in full compliance with applicable legislation.

1. Conduct of Company

1.7 As for conflict of interest

a) The members of G.C. Global Catering have a duty of loyalty towards the Company, and defend the legitimate interests of whenever necessary, basing their behavior on attitudes that do not jeopardize the image and financial and property security of the Company.

b) The private interests of G.C. Global Catering members must not interfere with the interests of the Company. Accordingly, it should be avoided any and all relationships that have or appear to present a conflict of interest between the Company and its members, including conflicts involving family members or people of their close relationship, both professionally and personally.

c) Company members can not have economic or financial interest in a competitor, customer, distributor or supplier, to the extent that such interest could influence or appear to influence their actions taken on behalf of G.C. Global Catering .

d) A situation that is occurring or is likely to conflict of interest or situation where it is not possible to avoid such conflict, the member of the involved company should formally take the matter to his immediate superior, fully reporting in writing all the circumstances relating to the case.

e) Is forbidden for Company's members to solicit gifts, gratuities, hospitality or other benefits, both for their own benefit as well as for family members or people from their close relationship, both professional or personal.

f) The members of the Company, except when clearly do not represent a conflict of interest, may not work for or receive compensation for services rendered to any competitor, customer, distributor or supplier.

g) It is forbidden to perform work unrelated to the activities of the Company, characterized as odd jobs, is prohibited also selling the product or any service on company premises, whether during or outside normal working hours

h) It is not allowed to use Company assets, such as telephones, various devices, materials, or proprietary information for odd jobs to activities developed by G.C. Global Catering .

1. Conduct of Company:

1.8 Gifts and presentes

a) The members of the Company may accept low-value gifts (reference up to R$ 50) always assured that there is no impairment of his judgment assessment and that there is no understanding, express or implied, that is somehow obligated to do something in return to the good offered. If the gift or premium is received in conditions that do not allow the member of the Company refuse it, or if there is reasonable doubt that the value of the gift exceeds the reference value, it should be sent to the respective Manager or Director, to decide which will be the proper disposal. The Directors may, in exceptional circumstances, authorize the receipt of presents , gifts or other things of value or utility that exceed the reference value.

b) The granting of gifts, favors or things of value or usefulness to commercial counterparts is prohibited (including prospective counterparties) and its members, except for promotional or sales campaign items whose value does not exceed the reference value (up to R$ 50 ) and are used for the purpose of institutional or commercial dissemination of the Company or its products and also they do not interfere or might interfere with making a business decision of the other party. The Directors may, in exceptional circumstances, authorize the granting of gifts or other things of value or utility that exceed the reference value.

1. Conduct of Company:

1.9 As for corruption and other crimes

a) Active or passive corruption is strictly intolerable, as well as extortion, bribery and money laundering, as well as any other similar criminal conduct.

b) G.C. Global Catering has the film commitment to strictly comply with applicable law for its operations and to conducting its business, and its members should faithfully fulfill that commitment.

c) G.C. Global Catering do not accept the practice of any act that could constitute business offense or jeopardize the image or the conduct of the Company.

d)All legislation relating to the topics covered in this item must be fully complied with by G.C. Global Catering and its members, notably domestic or foreign legislation, dealing with:

(i) Preventing and combating corruption, as well as any other similar conduct, including any form of bribe, offering or receipt of goods, values, favors or undue advantages, even in the face of people linked to organizations or private companies;

(ii) Prevent and combat money laundering;

(iii) Preventing and combating terrorism in all its forms, and its financing;

(iv) Preventing and combating unfair competition and other unfair trade practices; and

(v) Preventing and combating slave or child labor.

2. Conduct of Members:

2.1 Insider information

It is forbidden that the information of the Company, which are not in the public domain, is disclosed by its members, the same applies with respect to information relating to their customers and suppliers.

2.2 Environment, health and safety

The members of the Company should ensure that the environment for their personal health and that of their co-workers, and the working environment, eliminating any unsafe acts in the execution of their tasks and assignments.

2.3 Company resources

The members of the G.C. Global Catering should ensure the proper allocation and use of goods and Company property, such as equipment, provisions, buildings, tools, inventory, systems, software and vehicles, among others. Such assets and facilities, as well as financial resources of any kind, data and information, should be used for the exclusive benefit of the Company.

"The attitudes and behaviors of employees and managers should respect the rules of G.C. Global Catering, as well as business conduct set forth in this Code."

2. Conduct of Members:

2.4 Conflitct of interest

a) Os integrantes da Empresa que, porventura, tenham familiares ou pessoas do seu relacionamento próximo, tanto profissional quanto pessoal, trabalhando em negócios que têm por objetivo prestar serviços ou fornecer bens para a Empresa não podem usar de sua influência pessoal no andamento de negociações, decisão de escolha ou fechamento de negócios.

b) É vedado aos integrantes da Empresa o exercício de atividades externas, remuneradas ou não, que possam caracterizar conflito de interesses com os negócios da Empresa ou utilização indevida de informações, tecnologias, conhecimentos ou quaisquer outros meios, tangíveis ou intangíveis, que sejam de propriedade da G.C. Global Catering.

2.5 Relations with competitors

It is not allowed to discuss and talk to competitors about private information regarding competitive advantages, such as pricing, contract terms, costs, inventories, marketing and product plans, market research or similar, in particular that may characterize infringement of the principles of free competition or market reserve.

2.6 Politics and religion

Company dependencies constitute the workplace of all employees, the most varied and diverse religious and political cultures, making any and all manifestations of religious or political nature should be in principle be avoided.

3. Doubts and omissions:

The guidelines of the Code of Ethics and Conduct of G.C. Global Catering, allow to evaluate most situations and minimize the subjectivity of interpretations of ethical principles and conduct, but not necessarily detail all situations that may arise in the daily life of each member of the Company.

Thus, in case of doubt in applying the guidelines of this code in certain situations, the immediate leader must first be consulted.