1. OBJECTIVE:

This Internal Whistleblower Policy aims to establish clear guidelines for receiving, handling, and investigating reports related to illegal, unethical behavior, or violations of internal rules, applicable laws, and ethical principles adopted by Nutrire Indústria de Alimentos Ltda, at its headquarters and subsidiaries, ensuring confidentiality, protection of the whistleblower, and impartial treatment of the received information.

  1. SCOPE:

This Policy applies to all employees, administrators, directors, interns, apprentices, service providers, suppliers, business partners, and other interested parties involved with the company.

  1. GUIDING PRINCIPLES

The Whistleblower Channel will necessarily observe the following principles:

  • Ethics and integrity;
  • Confidentiality of information;
  • Good faith;
  • Impartiality and independence in investigation;
  • Protection against retaliation;
  • Compliance with applicable legislation, especially the General Data Protection Law (Law No. 13,709/2018 – LGPD);
  1. WHAT CAN BE REPORTED:

Among others, the following can be reported:

  • Moral or sexual harassment;
  • Discrimination of any nature;
  • Violation of laws, regulations, or internal norms;
  • Conflict of interest;
  • Misuse of confidential information or personal data;
  • Personal gain from the exercise of office;
  • Practices of corruption, fraud, bribery, or misappropriation of resources;
  • Accounting, financial, or labor irregularities;
  • Acts that could harm the company’s image, assets, or reputation;
  1. AVAILABLE CHANNELS:

The company provides the following means for reporting:

  • Electronic Channel (form on the company’s website)

This channel can be used either identified or anonymously, at the discretion of the whistleblower, ensuring the confidentiality of the provided information.

  1. ANONYMITY AND CONFIDENTIALITY:

The company guarantees absolute secrecy of the information received, as well as the preservation of the whistleblower’s identity. The information will be accessed exclusively by the members of the Whistleblower Channel Review Committee.

  1. GOOD FAITH AND RESPONSIBILITY OF THE WHISTLEBLOWER:

The whistleblower must act in good faith, reporting truthful facts and, whenever possible, providing information or evidence to assist in the investigation. Reported false complaints, made with malice or bad faith, will result in appropriate disciplinary measures, according to the law and the company's internal regulations.

  1. INVESTIGATION COMMITTEE:

The Investigation Committee is responsible for managing, receiving, analyzing, and conducting investigations of the reports submitted to the Whistleblower Channel. It will consist of 04 (four) members, representing the People Management, Legal, and Executive areas.

  1. HANDLING OF REPORTS:

The Committee will receive reports submitted to the Whistleblower Channel and take necessary actions for proper investigation, utilizing all available investigation methods, possibly involving other internal areas or external consultants, while maintaining confidentiality.

  1. INTERNAL WORKFLOW OF THE WHISTLEBLOWER CHANNEL:

The internal handling flow of reports will follow these steps:

  • Receiving the report via the available channel;
  • Registering the report;
  • Preliminary analysis for admissibility, conducted by the Investigation Committee;
  • If admissible, starting the investigation procedure;
  • Gathering and analyzing information, documents, evidence, and interviews;
  • Conclusion of the investigation, with the preparation of a final report;
  • Decision on corrective and disciplinary measures, if applicable;
  • Closing the case and securely archiving the information;
  • Responding to the whistleblower, if requested, in which case the whistleblower will need to identify themselves to enable a response, respecting confidentiality and applicable legislation.
  1. MEASURES AND SANCTIONS:

After due investigation and conclusion, the company will adopt appropriate corrective and disciplinary measures, which may include warnings, suspensions, contract termination, communication to competent authorities, revision of internal procedures, and other actions prescribed by law or internal rules.

  1. PERSONAL DATA PROTECTION:

The handling of personal data within the Whistleblower Channel will be conducted in compliance with the LGPD, respecting the principles of purpose, necessity, adequacy, and security, and the data will be used exclusively for investigation and legal and regulatory compliance.

  1. DISCLOSURE AND TRAINING:

This Policy will be widely disclosed to all relevant internal and external parties and will be available through the company’s institutional channels. The company will periodically promote training and awareness initiatives about the proper use of the Whistleblower Channel.

  1. FINAL PROVISIONS:

This Policy takes effect on the date of its approval and may be revised at any time, whenever necessary, to ensure its update and compliance with legal norms and best governance practices. Questions about this Policy can be clarified with the company's Legal Department.


Gerson Simonaggio (Sócio-Diretor)


Alvonir Anderle (Diretor Executivo)


Willian Santos (Gerente Corporativo de Pessoas e Cultura)


Franciele Monique Cipriani (Analista de Relações Trabalhistas e Sindicais)