ETHICAL COMMITMENT
IN ALL ITS RELATIONS

We reaffirm our ethical commitment in all our relations, promoting transparency in our activities and strengthening our organizational values and principles, essential for the survival, growth, and perpetuity of the company.

The Ocyan Compliance System consists of a set of measures designed to guide, prevent, detect, interrupt, and remedy irregularities in a structured, continuous, and sustainable manner, within the best market practices.

We were one of the first Brazilian companies in the oil and gas sector to achieve ISO 37001 certification, in recognition of the company's compliance practices adhering to international standards, rules, and anti-bribery management standards. The seal is valid for three years, starting from April 19, 2021.

To prevent

The governance structure of Ocyan allows all matters to be addressed with due importance, independence, and transparency.

Various guidelines, guides, and procedures are being disseminated with the aim of keeping our environment in compliance with current laws and regulations.

We need to identify the risks existing in our company so that we can monitor, remediate, and control these risks.

Several training sessions and awareness campaigns are being consistently offered to our team members to act with ethics, integrity, and transparency in their daily activities. The more knowledge we acquire, the better prepared we are to deal with the subject.

We need to know who Ocyan is dealing with. That's why we conduct ongoing assessments of our suppliers, service providers, and partners.

The participation of Ocyan in business groups combating corruption reinforces our commitment and dedication to a more ethical and transparent future.

To detect

What to do when you suspect or know of wrongdoing? Reporting is the correct path.

Ocyan provides, for both internal and external stakeholders, a secure and independent channel operated by a specialized company, ensuring confidentiality and non-retaliation against the whistleblower.

All reports are registered, analyzed, and forwarded for appropriate handling by the Compliance department in a fair and transparent manner.

Maintaining a monitored business environment helps prevent irregularities and losses to the company. That's why Ocyan relies on an independent Internal Audit and various controls in different areas of our business.

To remediate

The effectiveness of this process is fundamental for improving business performance and the effectiveness of the Compliance System.

In case of misconduct or violation of internal laws and regulations, disciplinary measures will be applied to those responsible for the actions taken.

POLICY ON THE COMPLIANCE SYSTEM OF OCYAN S.A.

Concepts and principles that should guide business actions and relationships among employees, shareholders, clients, suppliers, competitors, governments, communities, and society in general.

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OCYAN ETHICS LINES

An exclusive and confidential tool for secure communication (anonymous or not) of behaviors that violate the Ocyan Code of Conduct or any policy, guideline, internal regulation, and current legislation. All information recorded in the Channel is strictly confidential.

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ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Principles and guidelines related to the prevention and combating of bribery and corruption, in alignment with the Anti-Bribery Management System (ABMS) and Ocyan's Code of Conduct.

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CODE OF CONDUCT

Ocyan's members, in their daily activities and in the performance of their respective roles, are responsible for acting ethically, with integrity, and transparently, in accordance with the Code of Conduct.

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THIRD-PARTY CODE OF CONDUCT

Guidance for third parties on the key guidelines that govern our relationships, with good practices of corporate governance and ethics.

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As a follow-up to the Compliance Policy, Ocyan has developed and made available the following Guidelines to its members: Anti-Corruption Guideline, Third-Party Compliance Guideline (Integrity Due Diligence), Disciplinary Measures Guideline, Public Agent Relationship Guideline, Gifts, Presents, Entertainment and Hospitality Guideline (BPEH), and Donations and Sponsorships Guideline.

Internal Audit

Independent and objective activity of assessment and consulting, designed to add value to the organization's operations. It helps the company achieve its objectives through a systematic and disciplined approach to assessing and improving the efficiency of risk management processes, internal controls, and governance. (Source: IIA Brazil).

Data Protection

Ana Povina | Responsible Officer | E-mail: protecaodedados@ocyan-sa.com

Ana Povina
| Responsible Officer |
E-mail: protecaodedados@ocyan-sa.com