Code of Ethics

Technology and intellectual
property rights

GOALS AND CORE VALUES

The BB&G Group focuses on the manufacture of chemical products and other basic inorganic and organic products, the production of recovered carbon black and

petroleum products from waste tires, as well as the wholesale trade of petroleum products.

The BB&G Group bases its actions on criteria of excellence and commitment, associating itself with initiatives that promote ethical values as the foundation of

management and business culture, which is why it assumes the following essential objectives:

• Practice the highest values of ethics and personal integrity;

• Respect the quality of life of the Employees who are part of it.

I – SCOPE

The Code of Ethics applies to all people who work at the BB&G Group, whatever their employment relationship or mandate in executive or non-executive social bodies

designated as “Employees”.

II – QUALITY, ENVIRONMENTAL AND SAFETY POLICY

The Policy integrated within the scope of Quality Management Systems, Health and Safety at Work and environmental sustainability, and in line with BB&G Group’s mission and vision, aims to consolidate the positioning and operations of the BB&G Group within a framework of full respect in a socially responsible and sustained, based on transparency of information and mutual respect for the relationships it establishes with interested parties, and is committed to the following values and principles:

Code of Ethics and Good Conduct

• Comply with the legal and regulatory requirements applicable to the entity, as well as other requirements that are subscribed by BB&G Group;

• Anticipate, evaluate, and promote in a continuous and systematic way the satisfaction of the needs and expectations of all interested parties, progressively aiming at their confidence in products and services;

• Simplify and optimize processes and resources, through transversal management for sustainable development and the search for continuous improvement;

• Continuously improve your activities, methods, and equipment in the workplace, in order to prevent injuries, and damage to the health of the Employees;

• Continuously and progressively improve the performance of the integrated management system and the activities developed, carrying out a periodic review of the system, based on the results of the analysis of the objectives and indicators defined in each area of the organization. These must be in line with the results obtained through the dialogue process with interested parties and contingency plans;

• Promote the personal and professional development of employees, their motivation, training, updating, permanent awareness in order to actively contribute to achieving the results desired by the organization;

• Promote and ensure the minimization of the impacts of our activities, goods, and services at any stage of the life cycle, taking measures and actions to protect the environment, prevent pollution, ensure the sustainable use of resources, mitigation and adaptation climate change, the conservation of biodiversity and ecosystems, maintaining the balance between socioeconomic demands and the continuous improvement of the environmental management system and its environmental performance;

• Condemn child labor, forced and compulsory labor, not condoning such practices on the part of third parties who provide us with products or services;

• Promote the physical and emotional well-being of all people working at the BB&G Group.

Code of Ethics and Good Conduct

III – GENERAL VALUES

1. Responsibility

The Employees have the following duties:

• Respect and treat all other Employees, including their superiors, executive and non-executive directors, as well as all people who interact with the BB&G Group with politeness and probity;

• Attend work assiduously and punctually;

• Carry out the work with care and diligence;

• Participate diligently in professional training activities provided by the BB&G Group;

• Comply with the orders and instructions of the BB&G Group regarding the execution or discipline of work, as well as safety and health at work;

• Maintain loyalty to the BB&G Group, namely not negotiating on its own or on behalf of others in competition with the BB&G Group, nor disclosing information regarding its organization, production methods or business;

• Ensure the conservation and good use of work-related assets entrusted to you by the BB&G Group;

• Promote or carry out acts aimed at improving the company’s productivity;

• Cooperate to improve safety and health at work;

• Comply with the requirements on safety and health at work that arise from the law, this Code of Ethics, or any other Code/Procedure of the BB&G Group.

2. Independence

The interests of the BB&G Group must be the only ones to be taken into account in all relationships with third parties, respecting and assuming the values of seriousness and impartiality.

Code of Ethics and Good Conduct

3. Conflicts of Interest

a. BB&G Group Employees may not engage in any activity that is contrary to the interests of the BB&G Group, harms its reputation or its relationship with third parties, or interferes with their responsibilities as a worker or member of a Social Body;

b. BB&G Group Employees may not use their position, influence, information, assets, or resources for the undue benefit of themselves or third parties;

c. Employees and members of Governing Bodies cannot use for their own benefit opportunities discovered through assets, information, or position of the BB&G Group;

d. Whenever, in the exercise of his activity, the Employee has to intervene in decision-making processes or becomes aware of processes that in some way involve real or personal interests related to the Employee or someone in his family, he must adopt the necessary measures to ensure avoid, or, if it is not possible, communicate it to their respective managers or to the Social Body that elected them.

4. Professional Development

BB&G Group Employees must, throughout their professional lives at BB&G Group, dedicate their best efforts to carrying out the tasks entrusted to them and always seek to improve and update their knowledge.

5. Confidentiality

a. BB&G Group Employees must maintain confidentiality in relation to all facts relating to the life of the BB&G Group that they become aware of within the scope of their duties or because of them;

b. Personal information about Employees is subject to the principle of confidentiality, and its use is restricted to the Employee and the personnel responsible for the storage, maintenance, and processing of this information.

Code of Ethics and Good Conduct

III – SPECIAL DUTIES

1. Relationship with the Market

The BB&G Group will operate in the market in a transparent manner and in fair competition, aiming at greater transaction efficiency and customer and partner satisfaction.

2. Relationship with the Customer

BB&G Group will maintain a transparent relationship with its customers based on the principles of:

a. Correct and complete information about the services it provides;

b. Use of commercial practices that respect the customer’s freedom of choice;

c. Adoption of advertising messages that respect the principles of correction, identification, and truth, in strict compliance with the rights of third parties;

d. Maintaining effective complaints services in responding to customer requests;

e. Timely response to questions asked by customers, providing clear and appropriate information.

3. Relationship with Competitors

a. The BB&G Group, in its relations with all companies in general, will adopt fair competition practices, accepting and respecting the operating rules of a market economy.

b. Its actions will be governed by principles of transparency and correctness, based on a competitive valuation centered on the performance, merit and quality of its offer, not using unfair means to divert customers, nor disseminating false and misleading advertising messages.

Code of Ethics and Good Conduct

4. Relationship with Suppliers/Partners

The BB&G Group maintains a loyal partnership relationship with its suppliers and partners, based on procedures that, in compliance with market rules, ensure a fair sharing of the benefits and responsibilities of the value chain in which they operate:

a. The BB&G Group will choose its suppliers and partners according to identical ethical criteria;

b. Relationships with suppliers and partners will be carried out according to transparent processes, with strict observance of negotiated contractual conditions;

5. Relationship with Employees

BB&G Group management will develop policies that guarantee:

1. The dignity of the person, not allowing discriminatory practices or practices that, in any way, undermine the personal and professional integrity of Workers;

2. Platforms of understanding based on compatibility between flexibility resulting from competitiveness requirements and the safety and employability of its Workers;

3. Respect for the quality of life of Employees, recognizing merit as a factor in productivity gains;

4. Investment in human capital, promoting the continuous professional training of all Employees and valuing free initiative;

5. The recruitment, selection and development of the Employees based on transparent, objective and technically based criteria, ensuring their guidance by professionals in the respective areas.

6. Encouraging the Employees to participate in a culture of quality and productivity, which encourages an incessant search for opportunities to improve performance.

6. Interpersonal Relationships

Code of Ethics and Good Conduct

The BB&G Group will seek to promote and sustain urban conduct and interpersonal relationships. Any behavior that unfoundably harms the reputation of co-workers is unacceptable, namely through prejudiced judgments, rumors or unsubstantiated information, and intimidation, discrimination, threats and moral or sexual harassment of Employees will not be tolerated.

6.1. Harassment

The article 29, paragraph 1 of the Portuguese Labor Code, determines the prohibition of harassment. It further defines the harassment as unwanted behavior, namely that based on a factor of discrimination, practiced when accessing employment or in the job itself, work or professional training, with the aim or effect of disturbing or embarrassing the person, affect their dignity, or create an intimidating, hostile, degrading, humiliating, or destabilizing environment for them. The paragraph 2 adds that sexual harassment is an unwanted behavior, of a sexual nature, in verbal, nonverbal or physical form, with the objective or effect referred to as harassment in general.

Therefore, it is important to understand that:

• Sexual harassment or harassment with sexual connotations constitutes sexual harassment when an unwanted and hostile behavior has sexual connotations;

• Discriminatory harassment constitutes discrimination in which the unwanted and hostile behavior is based on a discriminatory factor other than sex, such as, for example, sexual orientation or race (“discriminatory harassment”);

• Non-discriminatory moral harassment constitutes that in which the unwanted behavior is not based on a discriminatory factor, but which, due to its connotation and insidiousness, has the same effects and aims to remove the Employee from the BB&G Group (“mobbing”).

• Any form of harassment in the workplace is prohibited, whether carried out by an Employee or carried out by the employer or his representative.

• Any form of harassment of the people referred to in the previous paragraph outside the workplace, for reasons related to this, is also prohibited.

Code of Ethics and Good Conduct

Furthermore, it is established that the procedures to be adopted in the event of harassment are:

• Anyone who witnesses harassment in the workplace must report it to their superior or employer;

• Reporting or witnessing situations of workplace harassment does not constitute the complainant or witness in disciplinary, judicial, or administrative liability unless

the witness or complainant acts with intent;

• The holder of disciplinary power at the BB&G Group has the duty to take disciplinary action against the person or people accused of harassment;

• Those targeted by disciplinary action for harassment have the right to a fair hearing.

Finally, it is also established that the consequences for the practice of harassment are:

• The practice of harassment constitutes a very serious offense, without prejudice to possible criminal liability provided for by law;

• The practice of harassment entitles the victim to compensation for material and non-material damage;

• The worker who is a victim of harassment can terminate the contract with just cause and the right to compensation;

• The responsibility for paying damages arising from occupational illness resulting from harassment lies with social security, which is subrogated to the Workers’ rights, referred to in the previous paragraphs.

7. Protection of Personal Rights

a. Special efforts will be made to guarantee full equality of opportunities for all who work professionally with the BB&G Group, persistently combating any forms of discrimination;

b. The principle of non-discrimination will be observed, particularly in relation to ancestry, disability, gender, ethnicity, language, territory of origin, religion, political beliefs, and trade union membership;

c. In the event of a discriminatory act to the detriment of an Employee or job candidate, will be entitled for a compensation for material and non-material damage, under the general terms of law, as provided for in article 28 of the Portuguese Labor Code;

d. The right to reserve privacy must be respected in all situations;

e. Workers with a non-contagious disease must remain in the workplace, as long as the evolution of their health status and the demands of the job allow.

8. Safety and Wellbeing in the Workplace

The BB&G Group will seek to promote a healthy and safe work environment, which aims to enhance and well-being, promoting trust, respect, justice and encouraging innovation.

a. It will create conditions to allow Employees an environment that facilitates active participation in the prevention of professional risks;

b. It will ensure conditions for the BB&G Group’s services to evaluate and report on the requirements of jobs and professional risks, thus enabling the optimization and adaptation of Employees to the work situation and ensuring health surveillance, depending on the risks to which they are exposed at your workplace;

c. It will ensure the conditions for an adequate and responsible functioning of the BB&G Group’s Safety, Hygiene, and Health services, with a view to eliminating/reducing professional risks, improving quality, and increasing productivity.

8. The Use of BB&G Group Assets

a. The BB&G Group’s resources exist to pursue their business objectives and therefore can only be used for the purposes defined by them.

b. Employees must make judicious use of the goods and services provided to them and avoid waste and misuse.

9. Environment

The BB&G Group considers that its sustained growth presupposes the compatibility of economic performance with the responsibility it assumes towards society and the environment. It also recognizes that protecting the environment is everyone’s responsibility, and therefore seeks to integrate environmental issues into all its activities.

Therefore, it assumes the following guiding principles:

a. Promote the continuous improvement of its environmental performance, through the development and implementation of an Environmental Management Plan;

b. Use eco-efficient practices and technologies that combine growth with environmental protection;

c. Adopt a preventive approach to environmental issues;

d. Prevent pollution at source, reducing the amount of waste produced, promoting its recovery/recycling;

e. Promote publicity and environmental awareness initiatives for Employees and suppliers;

f. Promote environmental quality in all BB&G Group activities.

10. Social Responsibility

The management and Employees of the BB&G Group will pay attention to the themes of social responsibility, sustainability, and corporate citizenship:

a. Promoting BB&G Group policies that develop social responsibility, both internally and externally;

b. Participating directly or indirectly in social intervention projects, civic, social, and cultural activities within the communities in which they are located;

c. Seeking to encourage the availability of their skills in community projects, namely through volunteering.

IV– FINAL DISPOSITIONS

1. This Code of Ethics and Good Conduct comes into force on the date of its publication, being disclosed internally, to Employees, via email and/or in paper format, and is available for consultation by customers, partners, suppliers, and entities/institutions.

2. Disrespect or non-compliance, by any Employee, with the rules of ethics and good conduct contained in this Code may result in disciplinary or other applicable liability, depending on the severity of the case.

3. Compliance with this Code does not prevent the simultaneous application of legal standards, general or special, as well as specific internal standards of conduct already in force at the BB&G Group.

Code of Ethics

Technology and intellectual property rights

Technology and intellectual
property rights