1971 to 2006: Between 1971 and 2006, the Cabovel brand was initiated and developed by other companies, which developed and progressed along with the national automobile industry; 2007: In 2007, the Cabovel brand was acquired by the Alka3 company, making the brand expand to other markets. Quality and technology have always been part of the company’s principle; 2009: Begins supplying the gearshift lever to Agrale; Starts supplying gearshift cables to TAC, the company that makes Stark (Jeep); Supplies oil dipstick to Detroit Diesel Corp – USA; 2010: Development and start supply of shift cables for Stara Agromach; 2011: Development and start of cables and supply for IVECO; Starts supply of shifter and cables for VOLVO BUS; 2012: Begins the supply of shifter and cables for IVECOTRUCK, and MERCEDES BENZ ÔNIBUS; 2013: In mid-2012 / 2013 CABOVEL intends to further expand its exports to several countries

With its factory headquartered in Osasco – SP, in an area of ​​2400m² with more than 150 employees, Alka3 has the most modern production line. With state-of-the-art equipment and highly qualified and trained employees, all products undergo quality tests.

ALKA3 Indústria de Autopeças Ltda, manufacturer of original automotive components for the national and international market, headquartered in Osasco – SP, committed to meeting the requirements of IATF 16949:16, ISO 14001:15, ISO 45001:2018 and Liability Requirements Social, assumes the following commitments: Ensure customer satisfaction through the quality of products and services; Continuously improve the organization’s products, production, administrative and management processes; Develop human resources, respecting employees’ rights and curbing abusive and discriminatory practices; Protect the environment, through the involvement of employees and suppliers in environmental issues, preventing pollution and minimizing waste generation; Ensure a safe working environment, through actions to prevent injuries and work-related health problems; Eliminate hazards and reduce occupational health and safety risks; Ensure consultation and participation of employees and their representatives in matters of occupational health and safety; Comply with applicable laws, standards, international conventions and other requirements; Review 05 – 05/27/2019 Board of Directors

CODE OF CONDUCT Alka3

To whom this Code applies

To all employees, contractors, temporary workers, apprentices, interns and service providers
in general.

We ask our representatives, suppliers and sub-suppliers who work with us to
apply the principles of this Code or work to their own similar standards.

General Guidelines / Work Environment
Alka3 does not accept the
following behaviors from its employees or suppliers and service providers:
·Use of child labor and/or work before the age of 16 (except as an apprentice, between
14 and 24 years);
·Exploitation of slave or forced labor;
·Discrimination of any kind, including discrimination due to age, race, color, national origin,
sexual orientation, gender, political orientation, religion or creed, physical disabilities or limitations,
geographic origin and social class, physical appearance, health problems and people with HIV ;
·Conduct that causes embarrassment or is disrespectful to subordinates or other people
in the company, such as offensive words, intimidation, sexual harassment and psychological or
physical aggression;
·Use of offensive nicknames (those that the nickname expresses its displeasure for the use);
·Consumption of alcoholic beverages or illicit drugs or being under the influence of these during the
working day or in the service of the company;
·Illegal, unethical behavior, bribery or misconduct where any member of the organization
could gain personal advantage;
·Commercial or abusive practices of any nature with customers, service providers and
suppliers that could be interpreted as unprofessional conduct.
Alka3 also maintains the privacy of its employees with regard to
sensitive personal information (including medical) and information from its dependents obtained and maintained under
the responsibility of the Human Resources area through compliance with the requirements of the LGPD.
Based on the LGPD, processing of personal data is understood to mean any operation carried out that
refers to the collection, production, reception, classification, use, access, reproduction, transmission,
distribution, processing, archiving, storage, elimination, evaluation or control of the
information, modification, communication, transfer, dissemination or extraction.
Alka3 expects cordiality, trust, respect and
dignified and honest conduct in the relationships between its employees, regardless of any hierarchical position.

Compensation/Working
Hours Alka3 provides its staff with compensation that meets at least minimum
industry standards. Alka3 does not deduct wages for disciplinary reasons, except as provided
by law. The normal working day strictly complies with the legislation, that is, 44 hours per week.

Commercial Relations
Alka3 expects its employees to conduct commercial relations in compliance with laws,
legal market practices and, in particular, national and international norms relating to the
economic order. All Alka3 employees are expressly prohibited from making any
improper, dubious or illegal payment, or favoring, by granting undue benefits, outside the
usual commercial practices, customers, suppliers and competitors, to the detriment of others; as well as making
such payments or granting privileges or advantages to public officials or the like, either
directly or through third parties.

Relationship with Customers
Satisfying the customer is the foundation of ALKA3’s existence. Therefore, it is a basic principle to serve the customer,
with an emphasis on quality, productivity and innovation, with social, community and
environmental responsibility, and with full respect for the laws and regulations of each product and region in which they operate.
In the relationship with its customers, ALKA3 is committed to:
·Serving with cordiality and efficiency;
·Deliver what was promised;
·Don’t sacrifice the quality of your products;
·Do not allow bribery to obtain a decision to purchase products or services;
·Maintain privacy protection of the customer’s private information;
·Ensure the security and privacy of any personal data processed;
·Maintaining the Confidentiality of Customers’ Products and Processes

Relationship with Suppliers and Service Providers
Alka3 adopts, with suppliers and service providers, a posture of transparency and
impartiality, in order to preserve mutual trust and contribute to the construction of a
lasting relationship and does not tolerate commercial or abusive practices of any nature that
could be interpreted as unprofessional conduct.
The choice and contracting of suppliers and service providers must always be based on
technical, professional and ethical criteria that guarantee the best cost/benefit
ratio Relationship with Competitors
Alka3 understands that free competition is a factor that provides innovation and
quality improvement of products and services. So that free competition is exercised in a fair manner. Alka3
prohibits its employees from:
·Promoting Alka3’s products and services by demonstrating deficiencies in
its competitors’ products and services;
·Provide strategic, confidential or otherwise harmful information to
Alka3’s business to any third parties, including, but not limited to, competitors.
Relationship with Unions
Alka3 understands the importance of unions and their initiatives, respecting the right of its
employees to join the union of their category. It also maintains a collective agreement and
provides basic information on the rights and duties of the category, such as collective bargaining,
union contributions, etc.

Relationship with the Government / Political Activities
Alka3 employees are prohibited, unless duly authorized by the Board of Directors:
·Any participation in political and/or partisan campaigns or activities, using the name
of Alka3;
·Make contributions or gifts to government officials, political parties or
candidates on behalf of Alka3.
Safety, Health, Environment and Social Responsibility
Alka3 promotes the preservation of the safety and health of its employees and the environment,
through the establishment of its Management Policy.

Alka3’s LGPD Policy Alka3
promotes compliance with the General Law for the Protection of Personal Data (LGPD), in the
processing of personal data of employees and their dependents, outsourced workers,
representatives, service providers, temporary workers, apprentices, interns, customers,
suppliers, competitors, union employees and public agency employees, through
the establishment of the following GDPR Policy.
ü Meet the rights of holders of personal data, ensuring free access,
data quality, and information transparency;
ü Treat personal data with responsibility and confidentiality, observing the
purpose, its adequacy, the real need for the information, security measures,
damage prevention, and non-use of data for discriminatory purposes, demonstrating
compliance with the law;
ü Implement actions to mitigate and eliminate the risks of misuse of data that may
impact people’s lives, carrying out structured processes for collection,
treatment, access control, storage and sharing of personal data;
ü Act in the constant search for security technologies, and work on raising awareness,
sensitization and training of the personnel involved, seeking the continuous improvement
of data protection processes;
ü Immediately inform your supervisor when you receive a request or a
complaint from a Data Subject, and also when you identify any incidents
related to personal data.

Press agencies
Any contact with press agencies must be made by the Board of Directors or employees duly
authorized by the same.
When identifying incorrect transmission of data or news that affect Alka3’s image,
employees must immediately inform the Board of Directors.

Conflict of interests
Our employees must ensure that their actions do not conflict with the interests of
Alka3 or cause damage to its image and reputation. The following conducts are prohibited:
·Develop, directly or indirectly, concurrently with your work at the company, activities that are
concurrent and/or complementary to Alka3’s business, without the express authorization of the Board of Directors,
except in cases of academic activities;
·To be the owner or partner of a company or of any economic activity that may represent a conflict
of interest with Alka3;
·Use or pass on to third parties, without authorization from the Board, confidential information;
·Give lectures, seminars or academic works on ALKA3 processes, without
authorization from the Board;
·Have confidential information that, if used, can bring personal benefits;
·Accept benefits, direct or indirect, that can be interpreted as retribution or to obtain
a favorable position for Alka3 in business of interest to third parties;
·Use Alka3 resources to meet private interests;
·Maintain private business relationships through which you may obtain privileges, as a result of your
duties at Alka3, with client companies, suppliers, service providers or
competitors.

Use and Preservation of Alka3’s assets Employees are
responsible for ensuring the conservation of Alka3’s assets, which include facilities,
machinery, equipment, furniture, vehicles, values, brands, patents, technologies and others.
It is not allowed to use Alka3 equipment and other assets for private use.
Internet and telephone access, as well as the use of e-mails, software and hardware must be restricted
to the member’s professional activity, observing the other provisions established in

Alka3’s policies, procedures, regulations or guidelines.
Members are not authorized to use the Alka3 address to receive
private correspondence, except in authorized cases.
Use of E-mail, Social Media, WhatsApp and Brand
Alka3’s corporate e-mail must be used in a professional and ethical manner. The
use of private e-mail for company activities is not allowed.
Access to pornographic and pedophile sites is not allowed.
The WhatsApp application and the like can be used when strictly necessary,
according to the policy and regulations established by the company. Employees are responsible for the
security and privacy of personal data processed in these applications.
Alka3 employees must:
· In external or internal social media (blogs, collaborative sites, poadcasts, linkedin,
instagram, among others), participate in collaborative dialogues, with constructive posts;
· Obtain Board approvals for publishing content associated with Alka3;
· Communicate thoughtfully and never post content that is disrespectful,
discriminatory or hostile in any messages or publications relating to the company,
our business, our customers, our business partners and our members.
· Protect business-related private information, and any personal information
(sensitive or not) and information of minors and adolescents;
· Contribute responsibly to the meaning and power of the Cabovel brand.

Accuracy and Integrity of Business
Records We maintain accurate and complete records of our business, including all transactions between our
business units and external individuals and organizations, and of all expenses and
labor charges;
We act in accordance with applicable legislation and technical and professional regulations;
We prepare our financial records in a timely manner, representing the facts accurately
and completely;
We maintain a strict financial, operational and compliance control system and an effective
risk management system.
We are committed to fraud prevention and detection and will investigate any suspected
fraudulent activity. Fraud is a crime we will not tolerate.
Export Controls and Import Obligations /

Economic Sanctions
The export of certain Alka3 technologies, products, services and information to other countries is
subject to legal restrictions.
We will comply with all applicable import and export control laws, regulations and procedures
where we operate.
We will respect national and international sanctions and embargoes and the
company’s specific destination policies when doing business with entities in other countries;

Anti-Bribery and Anti-Corruption Policy
Alka3 has a policy of complying with all anti-bribery and anti-corruption practices applicable to its
activities. It is also the Organization’s policy to require suppliers, third parties and business partners
to comply with these same practices. Making payments or providing
business courtesies or anything else of value may violate anti-bribery and anti-
corruption conduct. Alka3 employees are prohibited from requesting, receiving or offering gifts,
commercial courtesy of any kind and nature that may characterize any type of advantage
and/or favor in professional relationships, especially with regard to
purchase processes and/or contracting of services.
Counterfeiting of Parts
Counterfeiting of parts is considered an illegal conduct by Brazilian law, and may give rise to
civil and criminal penalties.
Thus, it is the obligation of employees to follow the procedures and regularity protocols
used by the company. If the employee is found to be forgery or imminent,
the appropriate disciplinary and/or judicial sanctions will be applied.

Intellectual Property
Employees may only use the company’s name or brand with the prior and express
authorization of managers or superiors who are empowered to do so.
The ownership of all programs, projects, images, documents, activities, information,
systems, results, reports and software (that is, everything that comprises the object and result
of the services provided by the company) developed in the work environment belongs
exclusively to the company, even after the employee leaves, and the reproduction
and disclosure, in whole or in part, of any company information is prohibited.
In this way, Alka3 clarifies to the employee that the property right, as well as the
copyright and related rights, over the object and the results of the activities performed in the company, are not
and will not be transferred to him, so that the employee does not may use them, nor practice any
imitation, counterfeiting or variation thereof, unless expressly authorized by the company.
Alka3 may use its intellectual property as it sees fit, including to subsidize
consulting activities of any third party that may hire it.

Deviation of Conduct and Escalation
All employees must work to ensure prompt and appropriate action against
violations of this Code of Conduct. However, in some situations it is difficult to determine whether an action
will or has already resulted in a violation. These are the steps that Alka3 Employees should keep
in mind in the event of a possible Code violation situation:
· Make sure you have all the information;
· Use your good judgment and common sense;
· If you’re not sure what to do in a situation, seek guidance before
taking action.
Alka3 will not allow retaliation against an Employee who reports, in good faith, misconduct or
unethical illegal behavior.
Deviations from conduct based on this Code must be reported directly to
the Human Resources Manager or through the Suggestions/Complaints Box. In cases involving
personal data, immediately contact the LGPD

Manager (Human Resources Manager).

Preparation: HRM

Approval: Board

Review 03 08/01/2022