1. OBJECTIVE:

This Internal Policy of the Ombudsman Channel aims to establish clear guidelines for receiving, processing, and investigating reports related to illegal, unethical conduct, or non-compliance with internal standards, applicable legislation, and ethical principles adopted by Nutrire Indústria de Alimentos Ltda, in its headquarters and subsidiaries, ensuring confidentiality, protection of the whistleblower, and impartial handling of the information received.

2. SCOPE:

This Policy applies to all employees, administrators, directors, interns, apprentices, service providers, suppliers, business partners, and other stakeholders who interact with the company.

3. GUIDING PRINCIPLES

The Ombudsman Channel will obligatorily observe the following principles:

  • Ethics and integrity;
  • Confidentiality of information;
  • Good faith;
  • Impartiality and independence in investigations;
  • Protection against retaliation;
  • Protection against retaliation;
  • Compliance with applicable legislation, especially the General Data Protection Law (Law No. 13.709/2018 – LGPD);

4. WHAT CAN BE REPORTED:

The following may be reported, among others:

  • Moral or sexual harassment;
  • Discrimination of any kind;
  • Violation of laws, regulations, or internal norms;
  • Conflict of interest;
  • Misuse of confidential information or personal data;
  • Personal gain through the exercise of the position;
  • Corruption, fraud, bribery, or embezzlement practices;
  • Accounting, financial, or labor irregularities;
  • Acts that may damage the company’s image, assets, or reputation;

5. AVAILABLE CHANNELS:

The company provides the following means for registering reports:

  • Electronic channel (form on the company’s website)

The aforementioned channel may be used in an identified or anonymous manner, at the discretion of the whistleblower, ensuring the confidentiality of the information provided.

6. ANONYMITY AND CONFIDENTIALITY:

The company guarantees the absolute confidentiality of the information received, as well as the preservation of the whistleblower’s identity. The information will only be accessed by members of the Ombudsman Channel Investigation Committee.

7. GOOD FAITH AND RESPONSIBILITY OF THE WHISTLEBLOWER:

The whistleblower must act in good faith, reporting truthful facts and, whenever possible, presenting information or evidence that helps with the investigation. Proven false reports made with malicious intent or bad faith will result in applicable disciplinary measures, in accordance with the company’s legislation and internal norms.

8. INVESTIGATION COMMITTEE:

The Investigation Committee is responsible for managing, receiving, analyzing, and conducting the investigations of reports submitted to the Ombudsman Channel, and will be composed of 04 (four) members, representing the People Management, Legal, and Executive Director departments.

9. HANDLING OF REPORTS:

The Committee will receive the reports submitted through the Ombudsman Channel and will proceed with the necessary investigation using all available investigation methods, which may include assistance from other internal departments or external consultants, always observing confidentiality.

All received reports will be:

  • Registered;
  • Preliminarily assessed for admissibility;
  • Investigated impartially, confidentially, and independently;
  • Handled within reasonable timeframes, depending on the case’s complexity, respecting the maximum deadline of 30 (thirty) days for investigation completion, which may be extended if the complexity of the facts requires it.

Sempre que possível, será fornecido retorno ao denunciante, respeitados o sigilo e as limitações legais.

10. INTERNAL FLOW OF THE OMBUDSMAN CHANNEL:

The internal flow of handling reports will observe the following steps:

  • Receiving the report through the provided channel;
  • Registering the report;
  • Preliminary analysis for admissibility, conducted by the Investigation Committee, based on evidence;
  • If the report is admitted, the investigation procedure will be opened;
  • Collection and analysis of information, documents, evidence, and interviews;
  • Investigation conclusion, with the creation of a final report;
  • Decision on corrective and disciplinary measures, when applicable;
  • Case closure and secure archiving of information;
  • Feedback to the whistleblower, whenever requested, in which case the whistleblower must identify themselves to allow feedback, respecting confidentiality and applicable legislation.

11. MEASURES AND SANCTIONS:

After due investigation and conclusion, the company will adopt appropriate corrective and disciplinary measures, which may include warnings, suspensions, termination, communication to the competent authorities, internal procedure revisions, and other legal or internal actions.

12. PERSONAL DATA PROTECTION:

The handling of personal data in the Ombudsman Channel will comply with the LGPD, observing the principles of purpose, necessity, adequacy, and security, with the data being used exclusively for investigation and compliance with legal and regulatory obligations.

13. DISCLOSURE AND TRAINING:

This Policy will be widely disclosed to all relevant internal and external audiences, being available through the company’s institutional channels. The company will periodically promote training and awareness activities on the proper use of the Ombudsman Channel.

14. FINAL PROVISIONS:

This Policy comes into effect on the date of its approval and may be reviewed at any time, whenever necessary, to ensure its update and adherence to legal standards and best governance practices. Any doubts regarding this Policy may be clarified with the company’s Legal Department.

Gerson Simonaggio (Managing Partner)

Alvonir Anderle (Executive Director)

Willian Santos (Corporate People and Culture Manager)

Franciele Monique Cipriani (Labor and Union Relations Analyst)