Supplier Code of Ethics

Effective date: May 31, 2026  |  MR Motores Aeronáuticos Ltda. (MR Aero Engines Ltd.)

This Supplier Code of Ethics establishes the ethical, social, environmental and technical standards that all suppliers of MR Motores Aeronáuticos must observe as a condition for qualification and maintenance of the commercial relationship. This Code is complementary to MR Motores Aeronáuticos' Sustainable Procurement Policy and must be read in conjunction with it. Adherence to these principles is essential for preserving operational safety, reputation and the sustainability of the aeronautical supply chain.

1. Values and Corporate Ethics

Anti-Corruption

It is strictly prohibited to offer, promise, pay or authorize the payment of any undue advantage — in cash or in kind — to public officials, MR Motores Aeronáuticos employees or related third parties. The supplier must be acquainted with and comply with the Brazilian Anti-Corruption Act (Law No. 12,846/2013) and anti-corruption legislation applicable in every country where it operates.

Conflicts of Interest

The supplier must immediately disclose to MR Motores Aeronáuticos any situation that may constitute a conflict of interest, including family, corporate or commercial ties with MR Motores Aeronáuticos employees. The conflict-of-interest declaration must be renewed annually for all partners and officers of the supplier.

Gifts and Hospitality

Offering gifts, presents, entertainment or hospitality to MR Motores Aeronáuticos employees in excess of BRL 300.00 (three hundred reais) is not permitted. Gifts of higher value, or any invitation covering travel, accommodation or events, must be refused or reported in advance to MR Motores Aeronáuticos' Human Resources department. Cash gifts or equivalents (vouchers, gift cards) are prohibited in any amount.

Data Protection (LGPD)

The supplier must process personal data in compliance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais — Law No. 13,709/2018), maintaining processing records, obtaining consent terms where applicable, and adopting technical and administrative information security measures to prevent data breaches, unauthorised access and privacy incidents.

2. Labour Standards and Human Rights

Forced and Child Labour

The use of child labour (below the legally established minimum age), forced labour or labour in conditions analogous to slavery is strictly prohibited at every stage of the supplier's production chain, including its subcontractors and indirect suppliers.

Working Hours and Remuneration

The supplier must fully comply with labour legislation, including formal employment registration, payment of fair wages and overtime, provision of mandatory rest intervals, and adherence to occupational health and safety standards (Brazilian Regulatory Standards — NRs).

Diversity and Inclusion

We encourage practices that promote diversity and inclusion in the workplace, including non-discrimination on the grounds of race, gender, sexual orientation, religion, disability or any other condition protected by law. The supplier must comply with the legal quota for the employment of persons with disabilities (PCD) where applicable.

Subcontracting and Supply Chain

The supplier must ensure that its subcontractors and indirect suppliers also comply with the standards set out in this Code, including equivalent contractual clauses in their supply agreements. The supplier is responsible for any violations committed by its subcontractors within MR Motores Aeronáuticos' supply chain.

3. Occupational Health and Safety

Regulatory Compliance

Strict compliance with the Brazilian Ministry of Labour's Regulatory Standards (NRs) is required, with particular attention to NR-4 (SESMT), NR-5 (CIPA), NR-6 (PPE), NR-7 (PCMSO) and NR-9 (PGR).

Personal Protective Equipment

The supplier must provide, train employees in the use of, and enforce the use of Personal Protective Equipment (PPE) appropriate to each activity, with a current Certificate of Approval (CA) as required by Brazilian regulation.

Safety Indicators

The supplier must monitor and report, when requested, its occupational safety indicators, including accident frequency and severity rates, and must maintain records of all Workplace Accident Reports (Comunicações de Acidente de Trabalho — CAT).

4. Environmental Responsibility

Waste and Fluid Management

Suppliers of technical inputs and logistics services must present a Solid Waste Management Plan (Plano de Gerenciamento de Resíduos Sólidos — PGRS) and demonstrate environmentally appropriate disposal of waste and effluents, supported by Waste Transportation Records (Manifesto de Transporte de Resíduos — MTR).

Emissions and Energy

We encourage the adoption of renewable energy sources, measurement of the carbon footprint (Scopes 1, 2 and 3) and the implementation of energy efficiency and emissions reduction programmes.

Sustainable Packaging

The supplier must prioritise recyclable, returnable or recycled-content packaging, minimising the environmental impact of its packaging materials.

5. Aeronautical Rigour and Technical Integrity

Regulatory Compliance

All parts, components and services supplied must comply with ANAC, FAA and/or EASA regulations as applicable, and must be accompanied by the required traceability documentation (Form 1 or equivalent).

Suspect Unapproved Parts (SUP)

The supplier must maintain a documented procedure for the identification, segregation and notification of Suspect Unapproved Parts (SUP), in compliance with applicable aeronautical regulations.

Non-Conformance Management

The supplier must maintain a documented procedure for the treatment of technical non-conformances, including root cause analysis, corrective and preventive actions, and failure reporting where applicable.

6. Confidentiality and Intellectual Property

Confidentiality of Information

The supplier must maintain absolute confidentiality regarding technical, commercial, strategic and financial information of MR Motores Aeronáuticos accessed during the contractual relationship, including product specifications, production processes, engineering data and customer information. This obligation persists after the termination of the contractual relationship.

Intellectual Property

The supplier acknowledges that all technical knowledge, designs, drawings, specifications and methodologies shared by MR Motores Aeronáuticos are its intellectual property and may not be reproduced, assigned or used for any other purpose without express written authorisation.

7. Reporting Channel and Sanctions

Reporting Violations

Any violation of this Code or of applicable legislation must be reported immediately to MR Motores Aeronáuticos through the official reporting channel:

The channel guarantees the anonymity of the whistleblower and protection from retaliation against those who report in good faith. All reports shall be investigated within a maximum of 30 calendar days.

Due Diligence and Monitoring

MR Motores Aeronáuticos may conduct prior due diligence and periodic, scheduled or extraordinary audits to verify compliance with this Code. The supplier undertakes to cooperate fully with such verifications, providing documents, information and allowing visits to its premises.

Progressive Sanctions

Non-compliance with any provision of this Code shall subject the supplier to the following progressive sanctions:

  • 1st occurrence (minor non-conformance): Formal written notice with a 30-day period for correction.
  • 2nd occurrence (repeat offence or moderate violation): Temporary suspension of new orders for 90 days.
  • 3rd occurrence (serious violation or repeated non-compliance): Permanent disqualification from the supplier registry and contract termination, without prejudice to any other applicable legal sanctions.

Depending on the severity of the violation, MR Motores Aeronáuticos may apply a more severe sanction immediately, without observance of the progressive order set forth above.

NOTICE: Signing this document is a mandatory condition for qualification and maintenance of the supplier registry of MR Motores Aeronáuticos. Non-compliance with the standards described herein may result in the sanctions set out in Section 7, including disqualification and contract termination.
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