Effective date: May 31, 2026 | MR Motores Aeronáuticos Ltda. (MR Aero Engines Ltd.)
Contents
MR Motores Aeronáuticos reaffirms its unwavering commitment to ethical conduct, integrity and transparency in all its operations. This Anti-Corruption and Integrity Policy establishes mandatory guidelines for the prevention, detection and remediation of unlawful practices related to corruption, bribery, extortion and fraud, in compliance with Brazilian Federal Law No. 12,846/2013 (Brazilian Anti-Corruption Act), Federal Law No. 8,429/1992 (Administrative Improbity Act), the International Anti-Corruption Conventions (OECD, UN, OAS) and applicable aerospace sector integrity standards (ANAC, FAA, EASA). MR Motores Aeronáuticos adopts a zero-tolerance stance towards any act of corruption, regardless of its value or justification.
The provisions of this Policy apply mandatorily to:
3.1.1. Offering to Third Parties
It is prohibited to offer, promise or authorize the delivery of any item of value to public officials or business partners with the intent to influence decisions or obtain illicit advantages. Institutional gifts of symbolic value are permitted solely on commemorative dates or at marketing events, provided they are duly recorded and carry no expectation of reciprocation.
3.1.2. Receipt by MR Motores Aeronáuticos
Employees may receive institutional gifts of symbolic value, provided they do not exceed BRL 300.00 (three hundred reais) per occasion or event. Gifts of higher value, as well as invitations covering travel, accommodation or entertainment, must be refused and immediately reported to the Compliance area. The receipt of cash, gift cards, vouchers or any equivalent is prohibited under any circumstances, regardless of the amount. All gifts received with a value above BRL 100.00 must be recorded in MR Motores Aeronáuticos' compliance system.
Expenses related to travel and hospitality for public officials or business partners are permitted only when strictly necessary for legitimate professional purposes, such as technical visits, regulatory audits or authorized training. All expenses must be paid directly by MR Motores Aeronáuticos to the service providers; cash reimbursement to the beneficiary is prohibited.
3.2.1. Travel and Accommodation Standards
The following limits apply to business travel:
Domestic Travel:
International Travel:
Economy class for domestic flights and international flights up to 8 hours; business class for flights over 8 hours, subject to prior approval from the Board of Directors.
All employees must immediately report to the Compliance Committee any situation that may constitute a conflict of interest, including family, corporate or commercial ties with suppliers, customers or public officials involved in aeronautical certification processes. The conflict-of-interest declaration is required annually for all employees working in the Procurement, Audit, Quality and Legal departments, as well as for directors and managers. Suppliers must also declare, at the time of qualification, any ties with MR Motores Aeronáuticos employees. Declarations will be reviewed by the Compliance Committee, which will take appropriate measures to mitigate identified conflicts.
Donations and sponsorships made by MR Motores Aeronáuticos must undergo a rigorous due diligence process, including verification of final beneficiaries and the intended use of funds, to prevent diversion to political, partisan or improper purposes. Donations to political parties are expressly prohibited. All contributions must be formalized by contract, with compliance and accountability clauses.
The engagement of third parties, consultants, commercial representatives, intermediaries and business partners is subject to prior integrity due diligence. The process shall include, at a minimum: (a) reputation and background verification; (b) screening against restrictive lists (CEIS, CNEP, CEPIM, Slave Labour Registry, OFAC/SDN); (c) identification of ultimate beneficial owners; (d) verification of judicial or administrative proceedings related to corruption; and (e) risk analysis based on the contractor's size, country of origin and sector. Due diligence must be renewed every 24 months.
MR Motores Aeronáuticos ensures that the processing of personal data under this policy — including data collected in due diligence processes, reports and investigations — shall be conducted in accordance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais — Law No. 13,709/2018). Data pertaining to whistleblowers, investigated employees and third parties shall be treated confidentially, with access restricted to those involved in the investigation and with appropriate information security measures in place.
MR Motores Aeronáuticos provides an independent, impartial and accessible reporting channel available to all employees, suppliers and third parties through the following means:
The channel guarantees the anonymity of the whistleblower upon request, the confidentiality of information provided, and protection from retaliation against good-faith reporters — retaliation being considered a serious violation subject to disciplinary sanction. Reports shall be investigated within a maximum of 30 calendar days, extendable by an equal period upon justification by the Compliance Committee. The whistleblower shall be informed of the outcome of the investigation when identified.
5.1. ESG Committee (Comitê ESG)
The Comitê ESG is the body responsible for the governance of this policy, composed of representatives from the Legal, Human Resources, Engineering and Quality departments. The Committee shall meet quarterly in ordinary session and extraordinarily when required, being responsible for deliberating on conflicts of interest, approving high-risk due diligences, overseeing the investigation of reports and proposing periodic revisions to this policy.
5.2. Auditing and Monitoring
The Comitê ESG shall conduct periodic audits of procurement processes, payments to third parties, interactions with public officials and documentary compliance. Accounting, contractual and tax records must be maintained with accuracy and completeness for a minimum period of five years.
5.3. Training and Communication
All MR Motores Aeronáuticos employees must complete mandatory annual training on this policy and on the Anti-Corruption Act. New employees must be trained within 30 days of hiring. High-risk suppliers shall receive specific training on the anti-corruption guidelines applicable to their relationship with the company.
Non-compliance with any provision of this policy shall subject the offender to the following progressive sanctions, according to the severity of the violation:
a) Minor Violation
Examples: failure to register a received gift; delay in conflict-of-interest declaration. Sanction: formal written warning and mandatory participation in an integrity training programme.
b) Moderate Violation
Examples: undisclosed conflict of interest; receipt of a gift above the permitted limit without reporting. Sanction: temporary suspension from activities for up to 30 days, or suspension of new orders for suppliers.
c) Serious Violation
Examples: bribery, kickbacks, document fraud, collusion in bidding processes, retaliation against a whistleblower. Sanctions: termination of employment for cause; immediate termination of commercial contracts with third parties and disqualification from the supplier registry; referral to the competent authorities for civil and criminal prosecution pursuant to Law No. 12,846/2013. In the event of a serious violation, a more severe sanction may be applied immediately, without observance of the progressive order set forth above. All sanctions applied shall be recorded in the employee's file or in the supplier's registry.