Anti-bribery Policy

Estaleiro Jurong Aracruz Ltd (EJA) is dedicated to ensuring that its products and services fully meet its business objectives and customer requirements, and in relation to bribery the Company determines that:

1. Bribery is forbidden;
2. In order to avoid a conflict of interest, its employees or third parties must always keep the company's interests separate from their own;
3. Comply with national and international anti-corruption laws currently applicable;
4. This policy is always up to date and appropriate for the company;
5. Resources are provided to establish, critically analyze and achieve its anti-bribery objectives;
6. Everyone must commit to follow the requirements of the anti-bribery management system;
7. Any reported anti-bribery concerns raised, based on good faith or reasonable conviction, will be investigated and dealt without fear of retaliation;
8. The company is committed to the continuous improvement of the anti-bribery management system;
9. The Compliance Department has the authority and independence to carry out its activities, without internal and / or external interferences;
10. Failure to comply with this policy may result in disciplinary action applicable by law.

In support of this policy, EJA's objective is:

• Zero tolerance for bribery
• Encourage the use of the Whistleblowing Channel
• Promote integrity with business partners