Ethics and Integrity

Our work is to give confidence to those who bring food and beverages to market. That confidence depends on every process being handled with integrity, through official channels and with documentation that accurately reflects the product and the transaction.

This Policy brings together the principles that have guided Romera Jr since its founding and sets out the due diligence procedures we apply to clients, exporters and partners. It applies to everyone acting on our behalf in any country and is a public commitment to those who place their trust in us.

Maicon Romera — Founder & Chairman

This Policy establishes the ethical principles and integrity and due diligence procedures that guide the conduct of ROMERA JR CONSULTORIA E ADMINISTRAÇÃO LTDA and its affiliates ("Romera Jr").

It applies to partners, directors, employees, associated consultants, interns and all third parties acting on behalf of Romera Jr, in Brazil and abroad. Where local law is more stringent, the more stringent rule prevails.

• Integrity: We act honestly and transparently, in strict compliance with the law.
• Technical independence: Our recommendations are based solely on applicable regulations and the client's legitimate interests.
• Confidentiality: We handle client and partner information in confidence.
• Responsibility: We are committed to the safety of food and beverages reaching consumers.
• Respect: We maintain respectful relationships with clients, employees, partners and public officials.

In accordance with Law No. 12.846/2013 (Brazil's Clean Company Act), Decree No. 11.129/2022 and the anti-corruption laws of the countries in which we operate, Romera Jr:

• Prohibits offering, promising, authorizing or providing, directly or indirectly, any improper advantage to a domestic or foreign public official, or to a person associated with that official.
• Does not make facilitation payments to expedite processes with MAPA (Brazil's Ministry of Agriculture and Livestock), ANVISA (Brazil's National Health Surveillance Agency), the Brazilian Federal Revenue Service or any other authority.
• Conducts all interactions with public authorities through official channels, with proper documentation and traceability.
• Pays official fees and charges only through formal channels, with proof of payment in the name of the relevant party.
• Requires third parties engaged to act on behalf of clients to follow the same standards.

• Offering gifts, presents, hospitality or entertainment to public officials is prohibited.
• For private-sector clients and partners, only nominal-value corporate gifts are permitted, with no expectation of anything in return and never during a negotiation or decision-making period.
• Employees may not accept gifts or advantages that could compromise their independence. If in doubt, the matter must be reported to management.

Partners and employees must avoid situations in which personal, financial or family interests could interfere with their professional judgment. Any potential conflict must be disclosed to management in advance and in writing; management will decide whether the person may continue working on the matter.

Professionals who have held a position with a public authority must observe applicable legal restrictions and must not use privileged information obtained in that capacity.

• Client information—formulas, labels, commercial documents, supplier data and strategies—is used exclusively to perform the contracted services.
• Personal data is processed in accordance with Law No. 13.709/2018 (Brazil's General Data Protection Law, LGPD) and, where applicable, the European Union's General Data Protection Regulation (GDPR) and Singapore's Personal Data Protection Act (PDPA), with restricted access, secure storage and retention only for as long as necessary.
• The duty of confidentiality continues after the contractual relationship ends.

Before entering into a business relationship, and periodically throughout its term, Romera Jr conducts risk-proportionate due diligence in accordance with Annex I.

8.1 Clients

• Verification of corporate registration and standing: CNPJ (Brazilian corporate taxpayer ID), status with the Brazilian Federal Revenue Service, ownership structure and ultimate beneficial owners.
• Screening against restricted-party and sanctions lists, including the National Register of Disbarred and Suspended Companies (CEIS), the National Register of Punished Companies (CNEP) and international sanctions lists.
• Identification of Politically Exposed Persons (PEPs) among partners and directors.
• Reputational checks using public sources.
• Verification of consistency among the declared business activity, imported or exported products and supplier origins.

8.2 Suppliers, exporters and partners

• Verification of the legal existence and good standing of the exporter and producer in the country of origin.
• Confirmation, where applicable, that foreign laboratories and organizations are approved by MAPA (Brazil's Ministry of Agriculture and Livestock).
• Assessment of the technical capability and reputation of recommended customs brokers, laboratories and other service providers.
• Inclusion of compliance, anti-corruption and data protection clauses in contracts.

8.3 Refusal and termination

Romera Jr may refuse or terminate a relationship if warning signs (Annex II) are not satisfactorily resolved, regardless of the contract value.

In line with Law No. 9.613/1998, Romera Jr does not participate in transactions showing signs of money laundering, undervaluation, false declarations of origin or contents, or document tampering. Documents submitted to regulatory authorities must accurately reflect the product and transaction: reports, certificates of origin, labels and declarations must not be altered to circumvent requirements.

Romera Jr competes fairly, does not disseminate false information about competitors, does not promise outcomes of decisions reserved to public authorities, and uses client names and trademarks only with permission.

Reports of conduct contrary to this Policy may be sent to contato@romerajr.com with the subject line "Ethics Channel." Reports are handled confidentially, may be submitted anonymously and are investigated impartially. A response will be provided to the reporter whenever a means of contact is available.

Any form of retaliation against anyone who, in good faith, reports suspected violations or assists with an investigation is prohibited.

Violations of this Policy may result in appropriate disciplinary and contractual measures, including a warning, suspension or termination of employment or contract, without prejudice to legal sanctions or notification to the competent authorities where required.

This Policy takes effect on the date of publication, is reviewed annually or whenever there is a material change in law or Romera Jr's activities, and is publicly available at romerajr.com.

São Paulo, November 2026.

Maicon Romera Founder & Chairman ROMERA JR CONSULTORIA E ADMINISTRAÇÃO LTDA

The risk level is assigned when a client or partner is onboarded and reassessed at each contract renewal or material change.

• Refusal or unjustified delay in providing corporate information or documents.
• Inconsistencies among documents (invoice, packing list, certificate of origin, report and label).
• Signs of forgery or tampering involving reports, certificates or labels.
• Requests to declare an origin, contents, value or classification that differs from the facts.
• Unjustifiably complex ownership structures or an unidentified ultimate beneficial owner.
• Payments by third parties unrelated to the transaction, in cash or to overseas accounts without justification.
• Requests to "expedite" processes through informal means or to contact a public official outside official channels.
• Prices substantially below or above those prevailing in the market for the same product.

I acknowledge that I have received, read and understood Romera Jr's Ethics, Integrity and Due Diligence Policy (POL-001, version 1.0), and undertake to comply with it fully in carrying out my duties and to report, through the Ethics Channel, any situation that may constitute a violation.

Full name

Company / Role

Identification document (CPF / CNPJ / Passport)

Place and date

Signature