CODE OF CONDUCT

CODE OF CONDUCT

CODE OF CONDUCT

The Code of Conduct represents the commitment of SIPCAM NICHINO BRASIL S.A. (further mentioned as SIPCAM NICHINO, or simply Company), in the provision of products and services that meet customers’ needs and effectively contribute to the development of the agricultural activities in an environment that fosters the sustainability of its activities and business.

The Code of Conduct is composed of rules intended to

ensure and search for sustainable growth based on respect for customers, in the products and services quality, in attention to the needs of the employees and, in general, of the interested parties.

The purpose of the Code of Conduct is to clearly define the

values and principles which compliances are completely essential, so that our activities are developed correctly. The Code of Conduct also defines the principles of the conduct of business and commitments; however, it does not provide finished solutions to all daily issues, but it is believed that this code encourages the continuous reflection on the values and principles that SIPCAM NICHINO wishes to employ in its professional practice.

This Code of Conduct reaches the relationship among board

members, directors, employees, workers, suppliers, partners, customers and other interested parties related to the business with SIPCAM NICHINO BRASIL S.A.

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CODE OF CONDUCT

STATUTE OF VALUES

OUR MISSION:

Introduce solutions through products and services developed by us, our shareholders and strategic partners, contributing to the improvement in the quality, quantity and profitability of the agricultural production in Brazil.

OUR VISION:

Through a portfolio of different and competitive solutions and of an inspirer and productive team, to be considered by our main customers as a key-customer for its business.

OUR VALUES:

Teamwork;

Flexibility and agility;

Innovative thinking;

Reliable behavior;

Compliance with the laws and regulations;

Respect to the environment and human

health; Commitment to the organizational

objectives; Commitment to quality;

Safety as key factor;

Appreciation of people and respect to diversities.

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CODE OF CONDUCT

GENERAL RULES

We are committed to manage the Company maximizing the safety and financial return and complying with: (I) a fair competition and market functional rules, (II) the environment, (III) the rights and dignity of all workers.

The relationships with the public and political administrations, the organizations of labor and government unions, the controlling and regulatory authorities of the agricultural pesticides industry are considered and conducted with honest, integrity, impartiality, transparency and independence.

We repudiate the use of slave labor and child labor.

We do not admit any types of measures that may be related to the money laundering and bribery, as well as any illegal acts.

The members of the Company's administration, as well as employees and workers are prohibited to offer or accept gifts, hospitality or any other type of benefit that may affect its independence of judgment in all and any situation.

Communications and financial estimates are submitted to our shareholders with reliability and transparency, aiming at providing complete, clear and extensive information of economic, financial and equity nature.

Being one of the Shareholders listed in the Stock Exchange, the members of the Board of Directors, Directors, as well as employees with access to privileged, reserved and confidential information on the Company are prohibited to use such information to conduct personal transactions, even by intermediaries.

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CODE OF CONDUCT

The principles and measures contained in the Code of Conduct are directed towards to Director, to those who are in SIPCAM NICHINO's payroll

("Employees") and all those who work for SIPCAM NICHINO ("Workers").

A copy of the Code of Conduct shall be distributed to those involved and mentioned, who should undertake by signing and complying it in full.

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CODE OF CONDUCT

BOARD MEMBERS AND EXECUTIVE DIRECTORS

We consider those who work in the Company as essential

components of the company´s asset, and we are committed to comply with the ability, personality and dignity of each one.

We are completely committed to offer equal opportunities, as well as ensure treatments equal to all workers. We fight against discrimination and prejudice of any nature of race, color, religion, age range, gender, political conviction, social position, cultural level, nationality, marital status, sexual orientation, physical capacity, among other diversities.

We undertake to create an adequate and appropriate work environment to our Employees, maintaining the physical integrity of all.

We undertake to inform the strategies and goals of the Company.

We aim at a reliable, transparent and impartial performance, disregarding in our practices and measures any personal interests that constitute favor and conflict of interest.

We ensure that our documents and accounting and financial statements reflect with clarity, simplicity and consistency with our reality.

We respect loving and family relationships among employees within the work environment, provided that they act in different areas and service stations, and with no subordinate relationship.

We do not accept harassment of any type, such as: moral, sexual, physical, psychological or oral, or situations that constitute intimidations or threats in the relationship among the several audiences, irrespective of the hierarchical level.

We maintain our neutral stance and exemption with regard to

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CODE OF CONDUCT

candidates and political parties.

We strongly repudiate all illegal acts involving frauds, theft, robbery, injury to property, embezzlement, misappropriation, bribery, forgery, simulation, dissimulation, corruption, money laundering, as well as the acts of discrimination, prejudice, racism, traffic, fundamentalism, torture and terrorism.

It is prohibited the disclosure of internal information that may have effect on the market and/or for own benefit that conflict with Company´s and its Shareholders' interests.

We do not accept promises or personal advantages for employees, organizations, public bodies, either in the country or abroad.

We fight against favoritism, patronage, nepotism and corruption in all its forms.

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CODE OF CONDUCT

EMPLOYEES AND WORKERS

We undertake to not develop activities related to other

companies, commercialize goods or provide services or any other analogous activities during the working hours or in the premises of Sipcam Nichino.

We reject the acts of indiscipline and non-compliance with the internal procedures and rules of SNB, as well as the procedures and instructions related to the performed activities.

We undertake to not work under alcoholic beverages effects, or any illegal drugs.

We repudiate illegal acts involving frauds, theft, robbery, injury to property, embezzlement, misappropriation, bribery, forgery, simulation, dissimulation, corruption, as well as the acts of discrimination, prejudice, racism.

We care about our personal presentation, by using discreet and appropriate clothing, both in work environment and external events where Company is represented.

We repudiate the reproduction of rumors, gossips, libel, defamation, bullying or any other social slanders.

We undertake to not take credit on behalf of third-parties or grant loans in our name to co-workers.

The passwords needed for access, authorization and entries in the Company, as well as computing information, are non-transferable, and everyone is responsible for the correct use and protection.

We undertake to ensure an appropriate work environment, not tolerating any type of discrimination, either physical, oral, psychological,

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CODE OF CONDUCT

sexual or anything that prejudices our workers' personal dignity.

Employee/worker is expressly prohibited to disclose false or distorted information in the Company. Information on confidential internal proceeds and procedures may also not be used for private purposes or to reach personal benefits.

The use and handling of assets belonging to Company should be carried out in a responsible form. It is considered as property of Sipcam Nichino the material values: vehicles, equipment, raw material, products and non- materials, such as, for example: technology, rules, guidelines, policies, records, our inventions and confidential information.

Installations and objects of the company cannot be used or removed from the Company without the direct Board's express authorization with the knowledge of the Superintendent Director.

Confidential information should be maintained confidential and protected against its misuse. It is also applied to information that are entrusted by third-parties.

The adoption of principles ethically correct is obligation of our

Members of the Board, Directors, Employees and Workers in the conduction of the business of Sipcam Nichino Brasil S.A.

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OUR CUSTOMERS

We undertake to promote and maintain stable and constructive

relations with our customers, based on our values.

We undertake to provide solutions to our customers in a

simple, practical and ethical manner, based on its actual needs.

We promote a responsible commerce of our products, ensuring

that we are fulfilling our customers' need and, at the same time, meeting and complying with the laws regulating the market and publicity activities.

Negotiations are made ethically, and with a fair competition with

our competitors, always complying with all applicable law, standards and rules.

We provide clear, reliable and timely guidance and information

to our customers, and we expose the advantages and limitations regarding our products and services, not promising what cannot be fulfilled, meeting the freedom of choice and allowing to take the best decision.

We do not provide services and commercial agreements with

which we have family relationship until second degree, for affinity or any bond.

We respect our Customers' privacy, maintaining their

information and operations confidential.

We deliver our products and services within the agreed terms,

and we do not carry out operations of any nature without Customer's consent.

We reject any type of financial transaction of fraudulent origin or

with indications of laundry of money. 9

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OUR COMPETITORS

We search for information on the market and competitors

through transparent and reputable practices, by adopting an attitude that does not affect our competitors' image.

We treat our competitors with respect.

We value our services and products, without depreciating our competitors' image.

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OUR SUPPLIERS

We choose our suppliers following the rules of ISO Certifications,

as well as through the assessment of quality, price of products, services offered by them, technical reasons and compliance with the terms.

It is mandatory that supplier complies with the Code of Conduct of Sipcam Nichino Brasil S.A., because we expect from our Suppliers the same attitude listed in this Code of Conduct.

We reject the act to perform or receive irregular payments in our negotiations with partners and suppliers, obtain advantages, influence decisions or induce people to grant undue permits, constituting bribery or kickback.

We only accept invitations for events of any nature with expenses incurred by suppliers, government bodies and others, after authorized by the Director of the area and of knowledge of the CEO.

We act in order to not accept or offer, directly or indirectly, gifts or favors that constitute commitment of our professional situation and of SIPCAM NICHINO´s objectives, and giveaways and gifts may be accepted of commercial value of up to One Hundred Reais (R$100.00), and the director of the area should always be aware of it.

If it is necessary to receive gifts to maintain the commercial relationship, such fact should be formally informed to the immediate Director, who should inform the CEO to establish the destination of the received gift.

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OUR ENVIRONMENT AND

THE COMMUNITY AS A WHOLE

We responsibly use the natural resources, such as water and

electric power.

We maintain channels for dialog permanently opened with the communities where we are inserted.

Our purpose is to prevent pollution and minimize any damage that may be caused by our activities, services and products.

We promote the continuous improvement of our Environmental Management System.

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GOVERNMENT BODIES AND REGULATORY BODIES

We are in strictly compliance with the laws of our country, the

rules applicable to our business model and those established by regulatory bodies.

We reject benefits arising out the relationships and political influences for the performance of business and obtaining of privileged information.

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CODE OF CONDUCT

PROCEDURES FOR APPLICATION OF THE CODE OF CONDUCT

Any violation of this Code of Conduct should be informed through: - Web at SIPCAM NICHINO’s website; - Intranet; - Mail / Report sent to the Vice Chairman of The Board Mr. Antonio

Carlos Motta Guimarães, by mail or delivered at the main gate of SIPCAM NICHINO. The report should be prepared in good-faith and should contain:

· the name of the person (or persons) that drafted it; · the articles of the Code of Conduct supposedly infringed; · a detailed description of the circumstances;

The reports will be received and evaluated by the Vice Chairman of

the Board and will be take the appropriate measures for each situation. The procedure ensures anonymity of the person that indicated such

violation. It is considered violation to the Code of Conduct any type of threat to the person that, in good-faith, has indicated possible violations to the Code. Likewise, any person that falsely accuses others to have violated the Code will also be considered violator of the same Code of Conduct.

The Vice Chairman of the Board can request the investigation of the

complaint to the Supervisory Committee or through another way that he may find necessary to verify the complaint received, without identifying the sender, ensuring their anonymity.

In case of convocation from the Vice Chairman of the Board, the

Supervisory Committee should meet immediately for discussion of the received report, and the sender must be kept confidential.

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CODE OF CONDUCT

The Supervisory Committee, which members are appointed by the

CEO, is responsible to monitor the compliance of the Code of Conduct and take appropriate action when needed. The Vice Chairman of the Board shall receive the minutes of each meeting of the Supervisory Committee.

The proved violation of this Code of Conduct constitutes illegal act

subject to punishment by recipients and may lead, according to severity, to the rendering of sanctions, including the removal of employee, in compliance with the content of the applicable laws and with eventual legal consequences in the case of illegal acts.

The proved violation of the Code by External Employees or Suppliers

allows the Company to take the applicable measures to fight it, which may lead to the breach of agreements and complete dismissal of the Company.

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ADDITIONAL INFORMATION

COMPOSITION OF THE SUPERVISORY

COMMITTEE

The President of the Supervisory Committee is the CEO and the members by him appointed and internally known by e-mail and intranet.

It is responsibility of the Supervisory Committee:

Meet the request of the Vice Chairman of the Board;

Acting Promptly and freely in the investigation of the complaint;

Keep the anonymity of the complainant / sender;

Ensure the compliance of the Code of Conduct;

Clarify any doubts of all the publics involved in this code;

HOW TO SEND A REPORT:

1. By mail 2. Personal delivery

C/o: Mr. Antonio Carlos Motta Guimarães - Confidential

Av. Brigadeiro Faria Lima, 1478 “Edifício Monumento” 21º Floor

Rooms 2101-2108, São Paulo – SP CEP: 01472-900

At the main gate of SNB, c/o Mr. Antonio Carlos Motta

Guimarães - Confidential

Uberaba, January 01st, 2019.

Luiz José Fraga Moreira Traldi CEO

Planting confidence, reaping innovation.