1 –FRAMEWORK

Silvestre Silva Group (Transportadora Ideal do Bairro de Alcântara, Lda. and Repnunmar - Logística e Trânsitos,Lda.) is committed to ensuring and respecting the Anti-Corruption and Bribery policy.

2 –AMBIT

Acts of bribery, corruption, fraud, money laundering and counterfeiting have very serious consequences, permanently damaging the image and reputation of GSS companies, as well as their employees, customers, suppliers and other stakeholders.

• POSSIBLE CONSEQUENCES: Damage to personal and business reputation, fines, lawsuits and claims for damages, financial losses due to invalid contracts, blacklisting, exclusion of access to financial funds, lawsuits, damage to career, disciplinary proceedings that can lead to dismissal.

3 - VALUES AND PRINCIPLES

COMPLIANCE WITH THESE VALUES AND PRINCIPLES OF CONDUCT START WITH YOU!

BRIBERY: It is accepting or offering anything of value with the intention of obtaining a business or personal advantage in an illegitimate way. This does not always involve money, it can be gifts, entertainment, hospitality or employment. You should never accept, offer or request a bribe, directly through third parties or intermediaries, in order to favor the interests of others. If you think you have witnessed a bribe or have doubts about a payment, you should report it to your superior. Attempting to receive or offer a bribe is as serious as the act itself.

CONFLICT OF INTEREST: Giving to third parties is sometimes necessary for the development of good business relationships. However, these should not be made in a personal capacity, so that there is no conflict of interest or they are considered bribery. The exchange or acceptance of gifts, in cash or equivalent, whether for personal use or close relatives, should not be encouraged. Any practice of corruption, in any of its forms, is prohibited.

Declare any conflict of interest. You can avoid or control a conflict of interest by excluding yourself from further participation and decision-making on a matter. A situation where commercial interests collide with personal interests is considered to be a conflict of interest, as it may, in these situations, be unable to have an objective view or act in the best interest of the companies. From a conflict of interest, do not seek personal gain or allow it to affect the way you do your job. The best interests of GSS companies must always be kept in mind.

FRAUD: You must always comply with the processes defined by the GSS companies to register or carry out (if authorized) commercial transactions, or other financial operations. Fraud is a crime and jeopardizes the trust image of companies vis-à-vis third parties. You must not falsify records, or allow others to do so. Maintain the integrity and accuracy of any type of company information, namely financial, complying with the applicable accounting principles and rules.

IMPROPER USE OF ASSETS/THEFT: All assets, physical property (ex: facilities and equipment) or intellectual property (ex: commercial information, trademarks) of GSS companies are essential for their activity. You must not use or remove company assets without proper permission. Do not misappropriate, damage or waste.

Protect company property from misuse, loss, fraud or theft. Always protect the intellectual property rights of companies. Undue disclosure of information or images abroad is prohibited.

COUNTERFEITING/MONEY LAUNDERING: Counterfeiting is the counterfeit/pirated production of an article or product of a different nature, without authorization from the entity that owns its intellectual property, for illicit commercial purposes. Money laundering or “money laundering” implies commercial transactions by criminals with GSS companies, with the aim of disguising money, fraudulent or stolen, turning it into legally reusable capital. Never deal with people or entities of questionable reputation. Look for signs of suspicious behavior. Always validate vendors and customers for changes in activity that look suspicious. Report any and all transactions that appear suspicious and involve the use of criminal or counterfeit property.

DUE DELIGENCE: We maintain an attitude of due diligence in our relationship with third parties (interested parties), carrying out background/integrity verification procedures whenever is necessary within the scope of business expansion operations (merger, acquisition or others), as well as commercial relationships with customers, suppliers or others, for example, when hiring employees.

We assume a Zero Tolerance Policy in relation to acts of this nature, practiced by any employee or business partners.