CODE OFCONDUCT

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Ceo message 3About citrosuco’s code of conduct 4Applicability 4

01. Conduct in the relationship with stakeholders 51.EMPLOYEES 51.1. Human Rights 51.2. Compliance with the laws, rules and regulations 61.2.1. Strict compliance with Labor Laws 61.3. Harassment and abuse of power 71.4. Conflict of interest 71.5. Privileged information 91.6. Use of company’s assets 91.7. Offer or receipt of promotional gifts and gifts 101.8. Family relationships and relationships among employees 111.9. Conduct outside of the company 111.10. Political participation 121.11. Union relationship 121.12. Use of alcohol, drugs and possession of weapons 131.13. Sale of merchandise 131.14. Management posture 132. SHAREHOLDERS 143. CUSTOMERS 144. SUPPLIERS AND BUSINESS PARTNERS 145. COMPETITION 166. COMMUNITY AND THIRD SECTOR 167. GOVERNMENT 168. ADVERTISING INDUSTRY 179. MEDIA 17

02. GENERAL INTEREST MATTERS 181. Health, safety and environment 182. Agreements and accounting records 193. Intellectual property 194. Lectures and external presentations 20

03. COMMUNICATION AND EXPLANATIONS 211. Ombudsman 212. Conduct committee 223. Audit 224. Disciplinary measures 225. Code of conduct management 23

04. STATEMENT OF RESPONSIBILITY FOR AND COMMITMENT TO CITROSUCO’S CODE OF CONDUCT 25

CODE OFCONDUCT

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Dear Citrosuco’s employees,

Citrosuco recognizes the importance of people in building a strong brand and making a successful business, and for that reason, it is engaged in strengthening relationships, both inside and outside of the company.

Our company has values, on which we build our vision: integrity, where we value trust, transparency, respect and ethics in our relationships; sustainability, where we take on our responsibility for the social, environmental and economic impacts arising out of our operations; meritocracy, to value and develop people, and fostering recognition of the individual’s performance, the group where such individual is included and the organization’s results as a whole; our entrepreneurship, which, along with generation of value, represents an ongoing pursuit of exploring opportunities beyond the available resources with focus on results; safety and health, that reflect our commitment to our employees’ lives and care of their health and safety.

This Code of Conduct is intended to provide better clarity about the behavior to be adopted by all those people who interact, directly or indirectly, with Citrosuco, and share our fundamental values, in addition to being an important tool to ensure compliance with the laws and regulations relevant to the business, throughout the organization levels.

The issuing of this Code represents the formalization and disclosure of the principles to be customarily experienced, shared and looked after in our corporate daily activities.

I hope you read, understand and use this Code as a valuable reference in your day-to-day activities. If you have any doubts, do not hesitate in seeking explanation in the Ombudsman or the Conduct Committee, in accordance with information available in this Code, in our other internal policies and rules.

Mario Bavaresco JuniorCitrosuco S/A Agroindústria

CEO MESSAGE

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Citrosuco is committed to maintaining the highest corporate ethical conduct standard. For such purpose, this Code establishes the principles and the ethical limits of its operation.

Citrosuco’s decisions and actions will be based on the principles set forth in this Code, as well as on the current laws and commitments undertaken with its stakeholders, by professionally, responsibly and carefully complying with its obligations. Citrosuco’s management goals as to corporate ethics are:

To ensure a high level of awareness and ethical requirement;To minimize the risk of occurrence of ethically bad practices;To maintain a culture consistent with the assumed values.

About Citrosuco’s code of conduct

The principles and guidelines contained in this Code of Conduct must be practiced and applied by all shareholders, directors, officers, employees (regardless of being company’s employees, interns or temps, and despite their job or position), customers, suppliers, contractors, business partners and controlled or affiliated companies.

Citrosuco encourages its customers, suppliers, contractors and business partners to share its values and ethics. At any Citrosuco unit, the guideline to contractors’ employees must be given by the contracted company, in accordance with the provisions set out in Citrosuco’s Code of Conduct, as well as to employees of customers, suppliers and other business partners.

Applicability

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1. Employees

Citrosuco treats its employees with respect and dignity, contributing to a work environment that ensures equal professional and personal growth, valuing individual freedom and diversity in work relationships, and providing an inclusive and productive environment.

1.1. Human rights

Respect to human rights is a constant in Citrosuco’s day-to-day activities, where relationships are based on freedom of thought and expression, valuation of personal safety, offer and maintenance of fair and favorable work conditions, and equality of rights to employees and communities where it is present.

Citrosuco does not tolerate any type of discrimination, including, but not limited to prejudice related to race, religion, age, gender, political conviction, nationality, marital status, sexual orientation, physical condition or any others.

01.Conduct in the relationship with stakeholders

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1.2. Compliance with the laws, rules and regulations

Lack of knowledge of a legal or normative obligation may not be used as a defense against the possible consequences of misconduct; therefore, each Citrosuco employee is responsible for complying with all laws and rules in force and applicable to the professional activities they conduct, including in connection with the countries where they work and international laws, regardless of the cultural differences that may exist between the parties involved.

All employees are strictly forbidden to, direct or indirectly, offer, promise, authorize, cause and/or grant advantage or anything of value to a government official, customer, supplier or any other person with the purpose of influencing decisions, even if favorable to Citrosuco’s business, or that aims at any direct or indirect way of personal, pecuniary or non-pecuniary gain or advantage. Similarly, no employee is to accept any kind of benefit or advantage that may corrupt, compromise or influence their decisions in connection with Citrosuco’s business.

Citrosuco’s employees are responsible for, and encouraged to report in good faith any breaches of the local laws to the company’s management, either through their direct managers or through the internal communication channels. Said employees’ direct management and leadership are responsible for providing conditions for such warning, as well as ensuring the non-retaliation of employees when they perform such obligation.

1.2.1. Strict compliance with Labor Laws

Citrosuco complies with the labor rules and requires its managers and employees also to abide by labor laws.

Citrosuco is strictly against forced, mandatory or child labor, and for that reason, it continuously invests in the fight against this degrading practice, and has as a premise to terminate the business relationship with customers, partners or suppliers that use this type of workforce.

In the form of the special laws applicable, Citrosuco hires underage people between 16 and 18 years of age under the special hiring condition of “underage apprentice”, encouraging the

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regular study of said adolescents and offering activities that also contribute to a citizenship formation.

1.3. Harassment and abuse of power

Citrosuco does not tolerate harassment of any nature, regardless of being sexual, economic or moral, nor situations that constitute disrespect, bullying or threat in the relationship among employees, despite their hierarchical level.

Harassment is typified when a person in a privileged position uses such advantage to humiliate, disrespect, embarrass or offend their subordinates. Moral harassment occurs when a person is exposed to humiliating situations during his/her working hours. Sexual harassment is intended to gain sexual advantage or value, including sexual or discriminatory jokes.

The employee who suffers or witnesses any of said situations must discuss the matter with his/her manager or, if he/she feels embarrassed to do so, he/she must communicate the fact to the Conduct Committee, by using the Ombudsman channels.

1.4. Conflict of interest

The conflict of interest in the employee-company relationship occurs when the employee uses his/her influence or takes actions for the purpose of benefiting private interests, and which oppose Citrosuco’s interest or may cause damage or losses to the company.

A Citrosuco employee must not take part in situations that characterize conflict of interest. For that purpose, Citrosuco encourages its employees to inform their managers about possible cases of conflict of interest, in addition to offering channels for explanations and inquiries, if situations that may generate doubt arise.

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Consequently, Citrosuco’s employees must not consent to, for example, some situations that characterize a conflict of interest, such as:

•To accept external work, or to own a contractor company, either compensated or not, which is inconsistent with Citrosuco’s interests and values;

•To allow influence from a personal relationship on a business decision, such as hiring a person or company that belongs to or is managed by a family member;

•To use the finding of a possible business opportunity to Citrosuco for his/her own benefit.

•To maintain a direct or indirect subordination in romantic relationship or family relationships existing among employees, or in the event of a candidate applying for a job that may involve subordination relation;

In addition to those, there are other situations that may characterize conflict of interest. Examples of said situations, and which the employees must immediately inform their manager or the Conduct Committee, so that Citrosuco assesses the characterization of situation of conflict of interest:

• Contractual or professional connection not through Citrosuco, with other professionals from the Citrosuco’s list of employees, management members and members of the Board of Directors, shareholders or shareholders’ representatives and their family members;

• Any other connection, direct or indirect, not through their professional position at Citrosuco, including romantic relationship with (i) suppliers or customers who maintain direct relationship with their work area at Citrosuco; (ii) government officials who maintain a direct relationship with their work area at Citrosuco; or (iii) Citrosuco’s competitors;

• Romantic or family relationships among employees with no direct or indirect subordination relation , including in the event of a candidate applying for a job at Citrosuco;

• Gifts or entertainment offer that affect or may affect the objectivity of their work.

After being informed of any of the above situations, or after being aware of any situation that may represent a conflict of interest, the manager must submit the fact to the Conduct Committee’s knowledge. The Conduct Committee, in turn, and in accordance with its Internal Rules, will be responsible for, and competent to decide on the actual existence of a conflict of interest in each of the concrete cases.

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1.5. Privileged information

1.6. Use of company’s assets

Information is an important asset of corporate activity operation, and must be properly used and safeguarded by all, so as to prevent its improper and/or unauthorized use.

The employee with access to business, strategic or confidential information about Citrosuco, such as financial results, acquisitions or sales, industrial secrecy, investments and related matters, the disclosure of which may affect Citrosuco’s operations or results, is forbidden to disclose it, and may only do so when expressly authorized.

In addition to being a duty of each employee to keep secrecy and not to disclose Citrosuco’s privileged information, all employees must also take the steps to prevent other employees from disclosing such information.

To comply with legit requests from government authorities, confidential information will be provided in accordance with the law, based on assessment and follow up from Citrosuco’s Legal Department.

Citrosuco’s assets must be used for the benefit of Citrosuco, and not for the personal benefit of employees or third parties.

The use of premises, materials, equipment and other physical assets, including corporate credit cards, must occur only for the authorized purposes and for purposes related to work responsibilities; therefore, employees must use them properly.

Communication means must be used for business purposes, and must be used to the minimum extent possible for personal purposes. Excessive personal phone calls or e-mails constitute improper use of assets.

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E-mail, Internet, telephone and other communication systems are not to be used in a way that may be considered illegal, inopportune or offensive, or that may negatively reflect Citrosuco’s image. That is applied to the use of Citrosuco’s equipment, during and beyond working hours, both at the office and a remote location. Logins and passwords are for individual use and must not be shared with other people.

Employees and users in general are not to expect privacy when using the communication means offered by Citrosuco, in particular electronic means. Citrosuco may, at its discretion, use and monitor any information transmitted or residing in its information means. That rule encompasses information written or stored in electronic system and any other related means. It also includes information technically developed, acquired by associations, acquisition, license, and purchase or trusted to Citrosuco.

All files and information related to the professional activity created, received or stored in the electronic systems are Citrosuco’s property and constitute business and legal properties. Consequently, in case of change or dismissal of an employee, such information kept by him/her are to be forwarded to his/her manager.

Any types of software and programs must not be copied into or installed in Citrosuco’s computers without previous authorization from the Information Technology department, in particular to safeguard copyrights and third parties’ intellectual property.

If the employee faces a situation that involves offer or receipt of gifts, such employee must carefully review said situation based on local legal respects and ethical principles.

Gifts, gratuities or granting of favors to public and/or government officials are strictly forbidden, under penalty of disciplinary sanctions.

Gifts or institutional promotional gifts (on which there is a printed trademark) or intended to promote a technical discussion or features directly related to the employee’s activity at Citrosuco may be accepted and/or provided upon the manager’s authorization. Said offers must be taken impartially, not interfering with the relationship objectivity between the parties. Gifts or promotional gifts involving leisure, entertainment or other aspects not related to the employee’s professional activities at Citrosuco are not authorized.

1.7. Offer or receipt of promotional gifts and gifts

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For the avoidance of conflicts, the employee must make the conduct adopted as to promotional gifts and gifts clear to the entities he/she maintains relationships with on behalf of Citrosuco Objects received as prizes, which represent distinction or tribute to Citrosuco must be forwarded to Citrosuco’s HOD/Social Communication Department.

1.8. Family relationships and relationships among employees

1.9. Conduct outside of the company

In addition to the provisions set out in item “Conflict of Interest”, in cases where there is a subordination relation, Citrosuco’s employees must refrain from directly or indirectly hiring or influencing the hiring of, family members or people with whom they maintain a romantic relationship.

In the event of a candidate applying for a job where there is no subordination relation, the employee must inform the HOD/Social Communication Department about the family or romantic relationship, so that, based on objective criteria (without any type of favoritism), the candidate’s technical skills are assessed.

For the purposes of this Code, family members are deemed as those up to the third degree: father, mother, son, daughter, siblings, grandfather, grandmother, great-grandfather, great-grandmother, grandson, granddaughter, great-grandson, great-granddaughter, uncle, aunt and nephew and niece. Family members with no blood relation are also considered, such as: spouse, partner, son-in-law, daughter-in-law, father-in-law, mother-in-law, stepfather, stepmother, stepson, stepdaughter and brother-in-law, sister-in-law and godson and goddaughter.

Building and strengthening of Citrosuco’s image and reputation also occur through dialog with and behavior towards its stakeholders. For that purpose, Citrosuco values its employees

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who maintain a conduct that is consonant with Citrosuco’s principles and values outside of the company.

Accordingly, the employee must be careful as to his/her conduct in public environments, including social networks/media; and the use of Citrosuco’s images or information without the company’s express authorization is forbidden.

Citrosuco does not tolerate the fact of an employee taking part in actions that involve fraud, theft, embezzlement or any other unlawful activities, even in his/her own private life.

Citrosuco respects the employee’s individual right to engage in civil matters and to participate in the political process. However, such participation must occur during his/her free time, at his/her own expense and without any connection with Citrosuco; and any employee’s action that involves contribution, on behalf of Citrosuco, to political campaigns or causes in money, properties or services is also restricted.

1.10. Political participation

Citrosuco respects free association and acknowledges unions as legal representatives of its employees.

Negotiations and dialog between Citrosuco and unions are to be held only by formally authorized people, in pursuit of building productive and harmonious work relations.

1.11. Union relationship

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Use and possession of illegal drugs, undue use of legal drugs or other substances within working hours, as well as performance of professional job and presence in the workplace in an altered state of consciousness are forbidden.

Weapons of any type within Citrosuco’s premises are not allowed, except for the professionals expressly authorized to such.

1.12. Use of alcohol, drugs and possession of weapons

The selling and/or exchange of goods of private purpose is prohibited, as well as the presence of people alien to the company for the purpose of buying or selling any goods within Citrosuco’s premises.

1.13. Sale of merchandise

Citrosuco values the management that promotes work team and individual professional growth, and encourages growth opportunities of employees, including by means of participating in internal hiring procedures.

At Citrosuco, we value that employee who is willing to learn from mistakes, to acknowledge and not to repeat them. Regardless of their hierarchical position, those who take on responsibility for what they do deserve to be highlighted.

Mistakes possibly made in the ordinary course of business, and in an attempt of obtaining right actions and doing the best to Citrosuco, are to be deemed as learning opportunities.

1.14. Management posture

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The conduct expected from all is to hear and consider new ideas, different opinions, questions and arguments that represent improvement to the current work conditions and procedures.

Citrosuco values synergy among the departments, cooperation among employees and all its Units and sharing as a way of learning and disseminating best practices.

Managers are to encourage and put meritocracy into practice, by fairly acknowledging high performance employees, and using objective and technical - rather than personal and subjective - criteria in such assessment.

2. SHAREHOLDERS Relationship with shareholders must be based on correct, transparent and opportune communication, which will enable them to follow Citrosuco’s activities and performance, through the Board of Directors.

Trade relations among shareholders and their family members and Citrosuco are allowed and must occur in compliance with market conditions and the provisions set out in this Code of Conduct.

In the event of trade relations among shareholders and/or their family members, either as individuals or through the companies in which they hold direct or indirect interest, transactions will require previous approval from Citrosuco’s Board of Directors, and must strictly abide by the principles of exemption and transparency, ethics, competitiveness and nonexistence of conflict of interest; and for that reason, shareholders and family members are not to develop businesses or activities whose feasibility depends exclusively on Citrosuco.

Citrosuco’s employees are to adopt the same rules and attitude (disclosure, price, payment method, contractual terms, etc.) towards shareholder’s family members that they adopt when they are dealing with other parties.

People or companies interested in developing a trade relationship with Citrosuco must inform, if any, the existence of the family connections set out above.

3. CUSTOMERSCustomers’ requirements and expectations are extremely important and must be taken into consideration, conserving their trust in our products. We must be committed to strictly comply with the terms agreed upon in the negotiations, acting in compliance with ethics and applicable laws.

Citrosuco reserves the right to terminate any trade relationship whenever its interests are not being met; where such relationship represents a legal, social or environmental risk, or where a certain customer thwarts the compliance with the principles, values and rules set out in this Code of Conduct.

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Information about our goods and services must be always clear and true. Technical data, in particular safety, health and environment requirements, are obligatorily informed to the customer. Each product must strictly comply with the legal requirements of the industry it is intended to.

Making any improper payments or adopting unethical conduct for the purpose of facilitating the sales of our goods or services is forbidden, even if we lose a business opportunity.

4. SUPPLIERS AND BUSINESS PARTNERS Citrosuco maintains a relationship with its suppliers and business partners based on respect, transparency and integrity, and the application of the rules provided in this Code of Conduct is mandatory in the conduction of any negotiation, in addition to being a condition for effectiveness of businesses.

In addition to the terms of their agreements, all suppliers and business partners must be aware of Citrosuco’s own values and policies, which are designed to define, explain and equalize the conducts in accordance with the highest level of respect for economic, social, environmental, ethical and human rights.

Accordingly, Citrosuco expects its suppliers and business partners also to commit to strict compliance with all Laws, Rules and Regulations, in particular in terms of:

1). forbidding forced work;2). forbidding child work; 3). respect to workers, who are to be provided with safe and healthy work

environments; 4). anti-corruption commitment; and 5). sustainable use of the environment.

Assessment of suppliers and business partners must be based on objective and discrimination-free criteria. The decision to contract must be based on technical and economic aspects and reputation. Clarity in typifying goods and/or services is crucial for negotiations.

By virtue of contract, suppliers and business partners may have access to classified and/or confidential information, and they must undertake not to disclose such information to third parties without previous and express authorization.

As a way to conserve Citrosuco’s integrity and reputation, business relationships must be terminated whenever there is loss of interests or disregard of any legal or ethical matters by the supplier (including contracted companies) or business partner; or also when certain supplier or business partner thwarts the compliance with the principles, values and rules of this Code of Conduct.

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5. COMPETITIONCitrosuco respects the principle of free competition, and is committed to ethical competition, repudiating any type of agreement intended to abuse economic power or arbitrary business practices.

All employees, in particular those who are in contact with competition on a regular basis, are responsible for ensuring that they are familiar with the applicable competition and anti-trust laws. If the employee has any doubt about the matter, he/she must seek previous guidance, including from Citrosuco’s Legal Department.

Employees must also ensure the adoption of attitude and conduct that respect the principles of free competition and anti-trust laws, refraining from practicing any action that represents or may represent any anti-economic practice, which is expressly unaccepted by Citrosuco.

All employees that become aware of any illegal (possible or actual) conduct have the duty to manifest themselves and inform the Conduct Committee, and if they have any doubt about the matter, they are to seek previous guidance from the company, including its Legal Department.

6. COMMUNITY AND THIRD SECTORCitrosuco is committed to the economic and social development of the communities in which it is present.

In order to disseminate sustainable development, it maintains open channels of permanent dialog with the communities and constantly invests in social actions and partnerships with non-governmental organizations, including through sponsorships and donations intended to the social, economic, educational, cultural and environmental development of the communities to which it relates.

Citrosuco’s employees are encouraged to participate in voluntary programs and projects sponsored by Citrosuco.

7. GOVERNMENTCitrosuco strictly complies with all laws and regulations inherent to it, respecting all authorities at all levels of the government and the public administration as a whole.

Employees, suppliers or business partners that act on behalf of Citrosuco are strictly forbidden to make payments as gratuity, or offer any advantage, gifts, or hospitality to public or government employees, as well as their representatives, to speed up licenses, regular services or administrative actions, as well as to obtain favorable decisions of any nature to the Company or to obtain private advantages.

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8. ADVERTISING INDUSTRYCitrosuco disapproves misleading advertisement; therefore, each advertising disclosure related to it must be true and objective, causing its advertising efforts to be characterized by the respect for current laws, ethics and local and international reference rules.

9. MEDIACitrosuco’s relationship with media must privilege disclosure of important facts, which will be disclosed clearly and objectively.

Each contact with the media is to be made exclusively by the spokespersons appointed by Citrosuco, and unauthorized persons are forbidden to disclose confidential or untrue information to the press.

Contact with professionals from media may never be treated as a business relationship, and involving favors or payments of any type is forbidden.

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Employees’ health and physical integrity, environment protection and sustainable development are priorities to Citrosuco, and are above economic or production matters, since it seeks to imprint the principles and values of its responsible operation on the agribusiness, to increasingly conduct its businesses in an ethical, socially responsible and ecologically correct way.

Citrosuco provides its employees with continuous training sessions, so that they master their daily activities, become familiar with health, safety and environment policies, procedures and practices, for the purpose of all being able to work in strict compliance with the conveyed guidance. For such purpose, employees’ proactive behavior is encouraged as to noticing and informing any type of problem within the work environment.

If there is any emergency situation, such as occupational or environmental accidents, the persons involved are to adopt the procedures set out to such situation and swiftly report those facts to their manager. If there is the need for reporting to the authorities, community or the press, Citrosuco will appoint the officially authorized spokespersons.

Information related to health, safety and environment that may have an impact on its employees, the society or nature, will be treated by Citrosuco objectively and transparently.

Business partners and contractors contracted by Citrosuco must comply with all health, safety and environment procedures set out in specific policy for their activities, in addition to the applicable laws.

1. Health, safety and environment

02.General interest matters

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2. Agreements and accounting records

The agreements to which Citrosuco is a party must be clearly and precisely written, not allowing any margin for ambiguous interpretation. Documents not attached to the main text may only be accepted or provided with Citrosuco’s Legal Department help.

Payments and commitments undertaken must be authorized by the competent hierarchical level and supported by legal documents, thus preventing any type of conflict of interest.

All financial and business transactions must be immediately and faithfully transcribed in Citrosuco’s books and records, maintaining the highest levels of transparency in the matters related to accounting, financial controls, internal report and taxation.

Citrosuco cares for the reliability of its records, and for that reason it constantly conducts internal and external audits intended to show its compliance with the information entered.

3. Intellectual property

Intellectual property is a strategic asset to Citrosuco. It includes patents, trademarks, know-how, technical data, financial data, information on procedures and the market, among other items that would benefit a competitor should the latter become aware of them.

The outcome of work of intellectual nature and strategic information generated at Citrosuco is the exclusive property of Citrosuco.

Each employee is responsible for treating information under intellectual property to which he/she has access as a result of his/her work as confidential, and must use such information carefully. Citrosuco does not allow disclosure of such information without the express authorization of the Executive Board, and requires respect to the property right and exclusive information of other companies.

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4. Lectures and external presentations

Even in the event of lectures and attendance to seminars or other public events, secrecy of confidential information and strategic businesses of Citrosuco must be strictly respected.

When attending an event related to his/her work or Citrosuco as an exhibitor/lecturer, the employee must previously inform his/her manager about the themes that will be exhibited, so that the manager may assess and provide guidance if necessary.

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In order to know, review and resolve any matter related to the Code of Conduct, Citrosuco maintains an Ombudsman, which may be accessed by internal and external persons through the following tools:

Phone service: • Brazil: 0800-892-0704 • Austria: 0-800-200-288 • Belgium:0-800-100-10 • Japan: 0034-811-001 or 00-539-111 or 00-663-5111

Interpretation issues, cases not covered and communications of any non-compliance with this Code may be forwarded to the employee’s direct manager or to the Ombudsman, if possible, by concrete facts and data.

In the events where the matter may cause embarrassment if discussed with his/her manager, the employee may submit his/her question directly to Citrosuco’s Conduct Committee, through the Ombudsman.

Each communication or complaint received by Citrosuco will be treated as confidential. Citrosuco will not tolerate any type of retaliation against the employee that provides information in good faith. If the employee suffers or becomes aware of any retaliation of any type, he/she must immediately inform the Conduct Committee.

1. Ombudsman

03.Communication and explanations

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• USA: 1-855-840-0066 • Australia: 1-800-551-155 or 1-800-881-011 • For all location, at the English prompt dial 855-840-0066.

• Website: www.citrosuco.com

Impartial and transparent, the Ombudsman ensures confidentiality of information, safeguarding the identity of the people involved, and promoting a better environment for all. Through the Ombudsman it is possible to clarify interpretation issues and submit complaints of non-compliance with the Code of Conduct, such as corruption, bribery, fraud, assault to the environment, false information, improper accounting records, misuse of Citrosuco’s assets, discrimination on the basis of race, color, religion, gender, physical or social condition, and unethical behavior and procedure.

2. Conduct committee

The Conduct Committee is responsible for dealing with the cases submitted to it, for establishing the criteria for cases not covered by the Code, and for the good operation of the Ombudsman.

The Committee is in charge of reviewing the matters submitted to the Ombudsman in an exempt and serious way, seeking solutions for the situations presented and giving feedback to the people who complained and chose to identify themselves.

3. Audit

Cases of misappropriation of funds and damage to property will be dealt with by Citrosuco’s Internal Audit department.

The independence in dealing with the matters and secrecy of identity of the people involved are ensured in all situations.

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4. Disciplinary Measures

Non-compliance with Citrosuco’s standards and rules will not be tolerated and is subject to enforcement of disciplinary and/or legal measures. Recidivism, including non-compliance with action plans dealt with by audit procedures, after the due guidance is also subject to disciplinary measures.

Possible measures to Citrosuco’s employees are:

1. Verbal warning; 2. Written warning; 3. Suspension;

The gravity or repetition of the faulty conduct may entail dismissal with cause.Possible measures to other people related to Citrosuco:

1. Enforcement of contractual fines; 2. Suspension of purchase, services or supply; 3. Payment retention; 2. Contractual termination; 3. Legal lawsuit.

Enforcement of penalties must be conducted, to the possible extent, as soon as possible and in accordance with the decision made by the Conduct Committee. Sanctions are to be objective, fair, reasonable and proportional to the fault committed. Similar faults must receive similar sanctions.

The Human and Organizational Development (HOD) must always be consulted as to the disciplinary measure to be applied to the employees, and, if necessary, it will consult with the Legal Department for guidance.

The employee must request guidance from his/her manager if there is no infrastructure for the full compliance with the rule, or even if he/she understands that some rule is not coherent. His/her manager must submit the case to the competent department to seek a solution.

Positive outcomes, due to compliance with the rules, must be treated by Citrosuco’s recognition systems, which along with communication actions contribute to the construction of a respect and value culture.

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Approval of this Code and its updates are responsibility of Citrosuco’s Executive Board.

The managers, at all hierarchical levels, are in charge of ensuring that their subordinates and contractors be aware of and apply the provisions set out in this Code, which must set an example of conduct to be followed by all.

Suggestions of improvement may be forwarded to the Conduct Committee through each leadership or though the Ombudsman. The Committee is in charge of reviewing them and including them in the next edition, if they are considered relevant.

5. Code of conduct management

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___________________________________________________________________Name

___________________________________________________________________Register Nº

___________________________________________________________________Department

___________________________________________________________________Unit

____/_____/_____ ________________________________________________Date Signature

I acknowledge in the terms of this Code of Conduct the main guidelines and principles of Citrosuco’s ethical conduct, and I am aware of the importance of fully practicing and applying the rules set out in it.

By accepting this commitment, I express my free agreement.

04.Statement of responsibility for and commitment to Citrosuco’s Code of Conduct

CODE OFCONDUCT