Whistleblower Protection Policy

Whistleblower Protection and Non-Retaliation Policy

ENGEVALE reinforces its commitment to whistleblower protection and non-retaliation.

Reaffirming its commitment to ethics, transparency, and the continuous improvement of its Integrity Program, ENGEVALE ENGENHARIA S.A. has formally adopted the Individual Acknowledgment and Non-Retaliation Commitment Agreement.

This instrument establishes guidelines designed to protect individuals who, in good faith, submit reports, raise concerns, provide information, present documentation, or cooperate with internal investigation proceedings.

ENGEVALE does not tolerate any form of direct or indirect retaliation against whistleblowers, witnesses, or any individuals who contribute in good faith to investigation and fact-finding processes.

Any measures involving intimidation, threats, harassment, duress, or professional detriment resulting from submitting a report or cooperating with an investigation are deemed strictly incompatible with Company principles.

EFFECTIVE IMPLEMENTATION

As an additional protection and governance measure, ENGEVALE has established that, where applicable, individuals holding positions of authority or decision-making power capable of affecting the whistleblower or protected employee may be formally notified of their obligations through the Individual Acknowledgment and Non-Retaliation Commitment Agreement.

The document expressly establishes the commitment to refrain from engaging in, ordering, encouraging, tolerating, or permitting any retaliatory action.

The process is conducted in strict compliance with the principles of confidentiality, need-to-know, impartiality, and mutual respect, aiming to preserve both the effectiveness of the investigations and the rights of all parties involved.

Execution of this Agreement does not constitute an acknowledgment of wrongdoing or liability by any party, serving strictly as a preventive measure for integrity and protection.

PROTECTION AND ACCOUNTABILITY

Protection against retaliation does not preclude the implementation of legitimate administrative or disciplinary actions, provided they are substantiated by objective facts, properly documented, and entirely unrelated to the reporting of concerns or participation in an investigation.

Any acts of retaliation may constitute a direct violation of ENGEVALE’s Code of Conduct and internal policies, subjecting those responsible to applicable disciplinary and legal measures.

OUR COMMITMENT

ENGEVALE believes that a secure environment for raising concerns is an essential pillar of an ethical corporate culture.

Accordingly, we maintain our steadfast commitment to:

Ethics • Integrity • Confidentiality • Impartiality • Whistleblower Protection • Non-Retaliation • Continuous Improvement

The implementation of the Individual Acknowledgment and Non-Retaliation Commitment Agreement represents yet another measure to strengthen ENGEVALE’s Integrity Program and consolidate an organizational culture founded on trust, accountability, and transparency.

 

ENGEVALE ENGENHARIA S.A.

Integrity is everyone’s responsibility.