Code of Ethical

Policy and Conduct

I. Who is the ABA Infra Group&'s Code of Ethical Policy and Conduct for?

First, we emphasize that, when we approach the ABA Infra Group, we are mentioning the nine companies that are part of it: Eudmarco, FCA Log, Adonai, Adonai East, Toronto, Argemil, Concais, Contermas and Pier Mauá.

The general rules presented in this Code must be followed by all Managers, Employees, service providers, third parties and by anyone who acts on behalf of the ABA Infra Group and its controlled companies, as they present elements considered essential that must be followed in the relationships established with the different audiences for the creation of successful partnerships.

The Code of Ethical Policy and Conduct considers the following audiences, although it is not limited to them: shareholders and investors, trade associations, trade unions, banks, customers, employees and other internal audiences, community and society, competitors, suppliers, Government, regulatory bodies and the press.

It is of utmost importance that everyone understands and respects our Code, in addition to all company policies and standards, laws and regulations in the locations where we operate.

If any employee has any doubts about the correct way to act or interpret any point of the Group's Code, he / she should ask his Manager or the Human Resources Department for guidance.

If you are a service provider, you should contact your company representative or seek help from your contract manager.

The ABA Infra Group has the collaboration of everyone so that this Code of Ethical Policy and Conduct is practiced daily.

II. Our purpose

Our mission is to undertake with excellence, prioritizing ethics and safety, carrying out innovative operations.

Our destiny is to be among the main companies in the sectors of port infrastructure and logistics, fuel and tourism.

And we intend to follow this, following the values ​​of making a difference, acting ethically and building partnerships based on trust.

We at ABA Infra Group have the following principles as pillars:

- Achieve recognition from Customers, the State and Society;

- Provide services with quality, punctuality, innovation and security;

- Keep employees engaged and motivated;

- Orient management to results, profitability and competitiveness;

- Employ innovative solutions with appropriate technology;

- Practice integrated and participative management;

- To act with ethics and citizen responsibility.

III. Basic principles of conduct

Respect, legality, impersonality, morality and efficiency are basic principles and highly valued by Grupo ABA Infra. No type of disrespect among its employees is tolerated in any of the Group's companies. Employees must have behaviors that follow our basic principles with all the different audiences that deal with their routine inside or outside their work environment, ensuring the confidentiality of confidential and relevant information to which they may have access, not using it to obtain advantages even if they no longer belong to the ABA Infra Group's staff. Everyone must comply with the rules, laws, regulations and procedures, acting in a transparent and integral manner, regardless of the function occupied or the area of ​​operation, and it is forbidden to use their function within the ABA Infra Group to influence decisions that favor interests (themselves or third parties) that cause losses to any of the Group's businesses.

IV. About respect

At Grupo ABA Infra, we value the diversity of employees to build a team. We always seek to build a work environment with a productive and creative focus, promoting equal opportunities, meritocracy and seeking that our employees act in a harmonious and respectful manner to all the characteristics and options of all, regardless of their differences.

In the same way that we expect the respect of our employees, we seek to promote a respectful, welcoming, dialogue and safe environment for our employees, with management practices aimed at preventing accidents, equipment and safe installations in terminals and offices. We encourage everyone to adopt responsible behavior and we do not accept that the attitude of a person (whether he is a collaborator, supplier or customer) puts the health and safety of himself and that of other employees at risk.

The ABA Infra Group respects and promotes Human Rights by not engaging in practices such as discrimination, sexual exploitation of children and adolescents, child labor, degrading and forced labor or analogous to slavery.

V. On the relationship with suppliers

Healthy, fair and sustainable relationships with customers and suppliers are valued by Grupo ABA Infra.

For this, it is essential that everyone obey the legislation and that there is fair treatment between our suppliers and their employees.

We encourage supplier relationships to be built ethically. For this reason, the receipt of gifts and gifts is authorized by the ABA Infra Group, as long as it does not occur to influence decisions or obtain undue advantages and there is a formal approval from our Executive Board.

VI. About social networks

The ABA Infra Group, as well as its member companies, has official channels on social networks and only they can represent companies.

Employees who choose to register on social media must act on their own and with private resources. When publishing their opinions, they must act in a totally personal way, without associating the companies, not disclosing information or any opinion that compromises the Group or the companies.

Profiles of social networks associated with the ABA Infra Group or companies should only be used by the area responsible for authorizations and publications in the media.

VII. On the repudiation of corruption and ideological falsehood

The ABA Infra Group guides its employees to promote their services in a clear and truthful manner, not authorizing any form of favoring their audiences (whether they are suppliers, customers or representatives of the government) and repudiating any form of corrupt conduct, whether bribery, deviations, concessions of undue advantages, among others.

In addition, we do not accept the amendment of our documents and records or the omission of the truth to obtain any kind of privilege or advantage.

VIII. Cases of violation of the Code of Ethical Policy and Conduct

Anyone can report cases of violations of the Code of Ethical Policy and Conduct.

To do so, you must report the fact to your superior or forward the complaint to the Conduct and Ethics Committee. The information and / or complaints received will be treated confidentially and the informant's identity will be preserved. Violation of any conduct or practice is subject to penalty upon assessment by the Conduct and Ethics Committee and will be subject to the application of current Brazilian laws