Code of ethics and conduct

Code_of_Ethics_and_Conduct.indd 1 10/13/16 2:38 PM

1 Organisational Guidelines...................................................................................04
2 Atlantic welcomes you...........................................................................................07
3 Introduction..................................................................................................................08
4 Relationship with collaborators......................................................................10
5 Relationship with clients......................................................................................12
6 Relationship with the communities..............................................................13
7 Relationship with suppliers................................................................................14
8 Commercial integrity..............................................................................................15
9 Relationship with Governmental and Regulatory Agencies......16
10 Relationship with the Press................................................................................17
11 Relationship with stakeholders.......................................................................18
12 Health and Safety......................................................................................................19
13 Environmental..............................................................................................................20
14 Conflict of interests..................................................................................................22
15 Gifts and entertainment.......................................................................................23
16 Protection and use of information and assets......................................24
17 Ethics and Conduct Committee.......................................................................26
18 Channel of Ethics and Conduct........................................................................27
19 Commitment agreement......................................................................................29

Organisational
Guidelines
04

MISSION
Togeneraterenewableenergyinasocialandenvironmentally
responsible manner, while investing in technology and
human resources so as to contribute to the country’s
development.
VISION
To be a leading company in the Brazilian renewable
energy market, seeking the best outcome for our
shareholders, for our staff and for the communities
where we operate.
VALUES
• Constant search for the best results, while upholding
the highest safety and quality standards.
• Dedication to contribute to sustainable development.
• Integrity and honesty in everything we do.
• Respect for the human being and for our relationships.
05

06

The foundation that supports the growth, development and strengthening
of Atlantic on the market is based on its culture, corporate governance
model and especially on its ethical conduct and transparency in conducting
business.
Given these premises, we present our Code of Ethics and Conduct, which
allows all direct and indirect partners to know, understand and practice
the ethical standards in relations with the company.
The commitment of all related parties to the principles outlined in this
material is irrevocable.
Atlantic is a company that aims to be a reference in the sector which it
operates, but none of this is possible without credibility.
Credibility reflects the effective practice of actions performed in our daily
lives such as integrity, honesty, transparency, safety, quality, clients and
shareholders satisfaction, respect for employees, partners, legislation,
environment and community.
Thus, it is the duty of all to know, understand and apply all the
recommendations established in this Code of Ethics and Conduct, respecting
the values on which they are inspired.
Regards,
Jose Roberto de Moraes
CEO
Atlantic welcomes you
07

The Atlantic Code of Ethics and Conduct must be followed by
everyone involved with the company in all functions, places and levels:
employees, contractors, suppliers, directors, board members and any
other person related to Atlantic or acting on behalf of the company.
Regardless of position, non-compliance with this guideline will not be
accepted. Non-compliance may result in serious damage to the image
of the company in the market.
If employees or collaborators have any questions about the code,
compliance and other policies or practices of the company, these
questions should be taken to the Channel of Ethics and Conduct.
Learn more about our Channel of Ethics and Conduct
Through the website www.contatoseguro.com.br
or call 0800 601 8659
Introduction
08

09

Atlantic recognizes the right of its collaborators to fair remuneration,
fair and appropriate benefits in return for their work, competence,
responsibilities and accomplishments.
• Transparency: Atlantic considers transparency in relationships
with its collaborators a fundamental issue for the building of an
environment of mutual trust and responsibility at all levels of the
company;
• Discrimination:Atlantic does not accept any form of discrimination on
race, age, sex, color, nationality, religion, sexual orientation, physical
or mental disability;
• Harassment and moral damages: Atlantic does not tolerate any form
of harassment, moral or sexual, or any other conduct that could be
described as offensive or embarrassing and that might cause any
form of moral damage to any collaborator;
• Use of illegal labour: Atlantic does not allow the use of forced,
compulsory or child labour or any other way of exploitation that
violates human dignity inside or outside the company;
Relationship with
collaborators
10

• Integrity: Collaborators must honor the principles established in this
Code of Ethics and Conduct when representing the company, in social
and professional situations;
• Company Assets: all collaborators are responsible for the
maintenance, care and protection of assets and company property,
and no collaborator, under any circumstance, can take ownership of
assets or corporate resources, or use them for their own benefit or
that of third parties;
• Preservation of information: each collaborator must ensure that
the company’s proprietary information is adequately protected and
unable to be accessed by unauthorized people;
• Employee recognition: Atlantic believes that our collaborators are a
very important part of our success and the company incentives their
development. Managers should use meritocracy as a criterion to
promote the professional development of the company’s employees.
Atlantic endorses the restrictive government policy about the
consumption of alcohol and illegal drugs as well as being under the
influence of those substances during the workday. Smoking is not
allowed indoors, according to the legislation.
11

12
Atlantic’s relationships with clients must be based on the following
guidelines:
• Courtesy, promptness and effective service;
• Respect for the client’s rights;
• Transparency in operations;
• Openness and appropriate treatment of suggestions and criticisms;
• Confidentiality of received information;
• Dignified and fair treatment, not providing misleading or false
information about the company’s products;
• The disclosure of information related to clients is forbidden, unless
formally authorized by the Internal Communications area of the
company or for the compliance with legal requirements.
Relationship
with clients

13
Atlantic has the privilege of doing business in several different
communities throughout Brazil, becoming a member of such
communities. As a member of these communities, the company must
always act responsibly. It means:
• Ensuring that all those who are involved with Atlantic’s activities
work in the development and implementation of community action
plans;
• Respecting the local culture where projects are implemented;
• Contributing to the sustainable development of communities.
Relationship with
the community

14
The contracting of suppliers and business partners must comply with
technical and ethical criteria based on the good reputation, financial
and professional capacity of the company, considering fair prices.
All collaborators must respect the contractual and commercial
conditions and protect the confidentiality of information established
between Atlantic and its suppliers, respecting conditions of mutual
trust in the confidentiality and contractual guarantees, under risk of
disruption of business relations.
Atlantic does not accept that employees use the influence of their
position in the company to achieve personal advantages or benefits.
Suppliers and business partners contracted by Atlantic must comply
with all existing legislation, including labour, tax, environmental, health
and safety. Child labour or slavery are forbidden.
All suppliers and business partners must guide their behavior by the
principles established in this Code of Ethics and Conduct. At any time,
the supplier or business partner who fails to meet the aforementioned
requirements will be disqualified.
Relationship with
suppliers

15
Atlantic does not offer or pay for any financial and personal benefit
in its commercial relations. All appropriate measures will be taken to
ensure that everyone involved in its activities comply with all legal and
regulatory requirements.
Check the Anti-corruption Manual available at
www.atlanticenergias.com.br
Commercial Integrity

16
AllkindsofrelationshipswiththeGovernmentandRegulatoryAgencies
are conducted with impartiality and transparency, in connection with
the existing legislation, particularly with the Anti-Corruption Law.
Practices involving preferential treatment, promises or granting direct
or indirect personal benefits of any kind to authorities or public officials
are unacceptable and illegal, according to the applicable law.
When publicly representing Atlantic, collaborators should refrain from
expressing opinions or comments of political nature.
Thecompletecommitmenttothelawsconcerningpublicadministration,
such as the Anti-Corruption Law is essential in conducting business.
Therefore, there will be no tolerance for illegal practices such as
corruption, extortion and bribery in all its forms.
Relationship with
Government and
Regulatory Agencies

17
Our relationship is based on transparency, credibility and trust,
constantly observing the ethical values outlined in our marketing
strategy as well as the delivery of company information.
Our authorised representatives will speak on behalf of the company
and ensure the availability of accurate information about the business.
Therefore, no employee of the company is allowed to speak on behalf
of the company, either through the media and social networks.
If there is any occurrence or complaint regarding the company’s image:
• The veracity of information will be evaluated;
• Transparent and timely communication will be used;
• Information about actions will be disclosed.
Atlantic rejects considerations on company information without proper
verification of the facts as described above.
Relationship with
the Press

18
Atlantic respects the principle of equal treatment of shareholders
and the company is transparent in the distribution of dividends in the
statements of financial position. Information is always available via
restricted channel through the company’s website at Extranet.
Relationship with
shareholders

19
Atlantic meets all health and safety standards in the workplace,
therefore, all employees must comply with the procedures and
instructions that regulate and protect safety and health.
Atlantic identifies and evaluates all the dangers and health and safety
risks of all operations and takes measures to mitigate them, reporting
regularly on health and safety management systems and performance
of the operating equipment.
In its facilities the company ensures:
• Compliance with all applicable laws, regulations and international
standards;
• Development, implementation and maintenance of specific programs
and procedures for health and safety facilities;
• Preparation to respond quickly and efficiently to health and safety
incidents;
• Concern, awareness and respect for health and safety issues through
communication and training for all employees, suppliers and business
partners.
Health and Safety

Atlanticaimstoprotecttheenvironment,biodiversity,faunaandnatural
resources and promote the continuous improvement of the areas with
sustainable practices. The company is committed to the principles of
sustainable development, such as:
• Take into account the environmental impact of all its operations and
take measures to mitigate any risks;
• Ensure that operations examine the impact on diversity and
implement appropriate mitigation measures;
• Present reports on the environmental management system and
performance of their operations through the ESG Committee
(Environmental, Safety and Health, Governance) on a regular basis;
• Review the actual and expected future benefits from investments in
the context of production / savings and greenhouse gases every year;
• AtlanticrespectstheBrazilianenvironmentallegislationandsupports
initiatives and activities aimed at the sustainable development of
the country;
• Atlantic believes in the importance of sustainable actions for the
conservation of natural resources and preservation of the planet;
• Employees must conduct their activities and projects with all
due respect to the environment according to sanitary norms and
regulations, in order not to harm the environmental balance.
Environmental
20

21

22
Conflict of Interests
All executives and collaborators must be loyal in their activities related
tothebusinessanddecisiontakingaccordingtotheirlevelsofauthority,
aiming solely at the company’s interests.
• Personal activities that may lead to conflict of interests of the
company are not allowed unless specifically approved in advance by
the Board of Directors;
• Private investment activities are not prohibited, however, if the
investment presents any potential conflict of interest with Atlantic
and its businesses, it must be reported to the CEO. In the case of any
Board of Directors member, it must be reported to the Board itself.
Situations that may create a conflict of interest, real or potential, must
be discouraged by all.

23
Atlantic allows the acceptance of gifts within its business relationships
upon the observation o lowing rules:
• Corporate gifts such as diaries, pens, calendars and others may be
received when directed to employees or the specific area;
• Other corporate gifts such as sports or cultural events tickets,
meals, beverages, discounts not available to the general public and
other goods or services must be directed and communicated to the
Human Resources area for the adequate destination to NGOs and
philanthropic institutions.
Please observe the rules regarding the acceptance of any gift from
governmental agencies on the Anti-Corruption Manual available on
our website.
Gifts and Entertainment

24
Protection and
use of information
and assets
Atlantic aims to preserve its information and assets through the
following measures:
• Use of electronic means of information: all subjects regarding the
disclosure of company information are available at our website
www.atlanticenergias.com.br and social networks. Broadcasting any
information or internal document on the Internet is prohibited;
• Electronic communication: collaborators must use the available
electroniccommunicationresourcesonlyandexclusivelyforbusiness
purposes within the legal requirements and following the ethical
principles of this Code of Ethics and Conduct. The transmission of
defamatory comments, offensive images or files that may lead to any
form of discrimination or any type of cybercrime is prohibited;
• Integrity of information: all collaborators are responsible for the
accurate and reliable information contained in the records and
documentation that support the activities of the company, therefore,
adequate data correction is necessary as well as the maintenance
of all documentation in accordance with the established internal
procedures policies and legal / tax requirements.

25
It is necessary to be aware that these requirements help ensure that
the company is running effectively and that reports provide accurate
and reliable information on the financial performance of the company
to shareholders.
Furthermore:
• All collaborators are responsible for property protection;
• It is the responsibility of all to protect confidential business
information and not to use them, except if necessary for the proper
performance of activities and under authorization;
• Employees must protect property, assets, equipment, including
hardware, software, mobile phones, furniture, among others, and
intellectual property of all kinds;
• Disposal of any property or asset must be informed to the responsible
area for inventory control;
• Unauthorized copies of copyright protected content, such as
software, music or videos are prohibited;
• Installation of personal software is not allowed in order to ensure
the proper functioning of equipment and minimize risks to the
internal network.

26
All members of the Ethics and Conduct Committee have skills,
experience and competence to occupy this position and have great
credibility in the company.
The responsibilities of the Ethics and Conduct Committee are:
• Reply to all suggestions and complaints made through the Ethics
Channel, based on analysis and investigation of the reported
information;
• Report acts that are not in accordance with the Code of Ethics and
Conduct to the Board of Directors, in order to solve the issues in
cases defined as serious;
• Compliance with the Internal Rules of the Ethics and Conduct
Committee.
Any member of the Ethics and Conduct Committee will be removed for
further investigation if involved, directly or indirectly, in any complaint
procedure.
The characteristics of the Ethics and Conduct Committee reflect the
identity and organisational culture of the company and its activities are
guided in the pillars and ethical principles highlighted here.
Ethics and Conduct
Committee

27
Atlantic believes we can build a great company to work for and be a
reference through its credibility in the market. You can find the Channel
of Ethics and Conduct on our website, which is managed by the company
Contato Seguro CNPJ 10.916.727 / 0001.77 in order to ensure the
confidentiality and security of information.
To access, send suggestions or inform any kind of behaviour deviation
out of the principles contained in the Code of Ethics and Conduct,
please contact us:
www.contatoseguro.com.br
Ethics Hotline: 0800 601 8659
Channel of Ethics
and Conduct

28

29
I hereby declare that I am in accordance with the Atlantic Code of Ethics
and Conduct. I agree to follow the guidelines and principles of conduct
established by Atlantic and I am aware of the importance of practicing
and implementing the rules contained therein.
The acceptance of this term is a manifestation of my voluntary
agreement.
Name:
Number:
Company:
Place and date:
Signature:
Code of Conduct
Commitment Agreement

Code of ethics and conduct

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