Diversity and Inclusion (“D&I”) Policy

1. Purpose

Establish ROMI S.A. (“ROMI” or “Company”) and its subsidiaries’ commitments related to Diversity and Inclusion (“D&I”), encompassing corporate policies and guidelines, and exerting every effort so the Company’s culture is capable of translating and consolidating the values and principles described in this Policy and in the Code of Ethics and Business Conduct.

2. Main Definitions

For the purposes of this Policy, the terms provided below must be understood and construed according to the following concepts:

AFFIRMATIVE ACTIONS: These are measures to fight discrimination, and to promote the engagement, access, and retention of minorities in the activities developed by the Company and its subsidiaries.

MORAL HARASSMENT: This means exposing people to humiliating and embarrassing situations, in a repetitive and prolonged manner. It can be characterized by the deliberate repetition of gestures, words, or behaviors that cause offense to the personality, dignity, or physical or mental integrity.

SEXUAL HARASSMENT: The act of “embarrassing someone, with the aim of obtaining sexual advantage or favor” (Criminal Code, Article 216-A). It is not necessary for there to be physical contact to characterize sexual harassment, nor for the act to be committed inside the Company.

DIVERSITY AND INCLUSION COMMITTEE: This means an internal, non-statutory Company body, whose members are elected annually by the Executive Board, responsible for advising it on D&I issues, by suggesting affirmative actions in accordance with the best practices defined by law, by the market, or by society.

COMPLIANCE: This means complying with, being in accordance with, and enforcing the compliance with rules and regulations, whether internal or external, voluntarily assumed or imposed on the Company’s activities.

DISCRIMINATION: To breach a person’s rights, in an unfair and unfounded manner, due to their race, nationality, color, gender, sexual orientation, language, special needs, religious belief, political conviction, social origin, or any other condition, through harassment, offense, hostility, ridicule, intimidation, or humiliation.

DIVERSITY: To promote coexistence and respect among people of different races, sexual orientation, gender, physical condition (PWD), age group, etc.

EQUALITY: To guarantee impartial access to fundamental rights. This means recognizing inequalities, seeking to suppress them, in favor of justice.

MANAGERS: People in leadership offices at the Company.

AFFINITY GROUPS: responsible for disseminating the D&I culture in the Company, who work under the management of the Diversity Committee. They are made up of collaborators with common interests and demands.

INCLUSION: This means inserting minority groups into society, encouraging and valuing the social coexistence of these groups, and aiming at eliminating prejudice or discriminatory attitudes and speeches.

MINORITIES: These are groups of people who have historically had their fundamental rights violated for various reasons, involving ethnic, origin, financial, gender, sexuality, age, or physical condition issues, etc. Such groups include black people, indigenous people, the LGBTQIAP+ community, women, the elderly, people with disabilities (PwD), etc.

MONITORS: Technical leadership office at the Company, with no management authority.

UNCONSCIOUS BIAS: They are opinions developed from past experiences that remain in the unconscious mind, automatically guiding our judgment regarding attitudes and decisions, which may negatively influence our choices.

PSYCHOLOGICAL SAFETY: To guarantee that all people feel respected, welcomed, and valued, free from any form of embarrassment, prejudice, or discrimination.

STAKEHOLDERS: It involves all people or companies that, in some way, are interested in the Company’s projects, activities, and results. This includes all customers, suppliers, service providers, investors, partners, public authorities, and the civil society, in their involvement with the Company.

3. Coverage

This policy is applicable to all employees, administration members, committees’ and the audit committees’ members, interns, minor apprentices (“collaborators”), and the Company’s stakeholders, who must strive for its application, repressing any form of violation of its provisions.

4. Supplementary Documents and Guidelines

5. Responsibilities

All ROMI’s collaborators and stakeholders and its subsidiaries are responsible for disseminating this Policy, which shall be the basis for conducting the Company’s business and decision-making at any level. The following are express obligations:

Ensure that the Company’s businesses and strategies respect this Policy and monitor, sponsor, and engage collaborators and stakeholders in initiatives on the subject, making sure the dissemination and evolution of the Company’s inclusive and equalitarian culture.

Advise ROMI’s Executive Board on matters related to and aimed at D&I, suggesting affirmative actions that promote access, development, and retention of minorities, recommending to the Executive Board the best practices on the subject, defined by law, by the market, or by society.

Within the respective attributions of the office, commit not to discriminate against minorities when hiring and promoting collaborators and to develop diversity in the Company, in addition to promoting and providing conditions for the engagement of teams in D&I initiatives, also assuring safety psychology in the work environment.

The duty of every manager and monitor is to support such initiatives and to communicate in an inclusive form, inhibiting any act of discrimination and/or prejudice in the Company, as well as reporting to the Ethics Committee all noncompliance with ROMI’s Policy or the Code of Ethics provisions.

To act with respect in the performance of their activities and duties, maintaining non-discriminatory behavior, complying with this Policy in an integral and unconditional manner, reporting to the Ethics Committee any situation that may violate its terms and/or breach the Company’s Code of Ethics.

To act as multipliers of D&I practices, encouraging engagement with the topic in all areas of the Company, in accordance with the guidelines of the Diversity Committee; besides discussing, proposing, and contributing to the implementation of initiatives aimed at diversity, equality, and the evolution of an inclusive culture, working on strategic issues for the Company.

To be aware of, comply with, and make efforts to disseminate this Policy, orienting themselves according to its provisions to prevent them from acting in conflict or violation.

6. Principles

The Company is committed to promoting Diversity and Inclusion, through the implementation of affirmative actions aimed at minorities, in order to guarantee a more inclusive and diverse work environment.

The guiding principles and values of this Policy are:
(i) Administration Commitment – Administration’s direct and unconditional action, including the Executive Board and Board of Directors, in promoting Diversity and Inclusion.
(ii) Ethics and Compliance – This Policy is part of the guidelines and practices recommended for all collaborators, including Administration members, Committees and Audit Committee members, interns, minor apprentices, and stakeholders, who relate to ROMI or act on its behalf.
(iii) Respect and Empathy – Act with respect and empathy towards people, valuing diversity in all its aspects and places.
(iv) Knowledge and Communication – All collaborators must be trained and made aware of this Policy, in order to ensure its application and full and invariable compliance with its provisions.
(v) Psychological Safety – Ensure that all people, during their relationship with the Company and its subsidiaries, feel respected, welcomed, and valued, free from any form of embarrassment, prejudice, or discrimination.

7. Affirmative Actions

For Diversity and Inclusion to happen, ROMI is committed to the following activities:

Incentive Actions: This means the adoption of measures aimed at minorities, ranging from the guarantee of fundamental rights and protection of dignity to the focus on professional development, including salary equalization by gender and increased representation of minorities in leadership and senior administration offices at the Company, upon consideration of individual performance criteria, assuring total equality in career promotion.

Reporting Channel: This means the maintenance of an anonymous access mechanism, which enables the communication to the Company’s Executive Ethics Committee of conduct that violates this Policy or any guideline related to it.

Engagement Channel: This means the creation of tools to stimulate the involvement of all collaborators in the D&I agendas and initiatives developed by ROMI, contributing to the improvement of an inclusive culture in the Company and in society.

Due Diligence: Is the commitment to make efforts to preventively inspect business partners regarding compliance with the D&I practices recommended by the market and required by this Policy.

Internal Investigations: This means the procedure that aims to guarantee the proper investigation and penalty, if applicable, of all acts or facts that may expose improper conduct and its related aspects, without prejudice to the penalties provided for in the law in force.

Disclosure: This means the promotion and development of collaborators’ knowledge regarding the D&I topic, at all hierarchical levels, through training, surveys, educational activities, indicators, and internal communication.

Prohibition of Nicknames: It is the prohibition of the use of pejorative, discriminatory, or embarrassing nicknames, especially when related to any physical or behavioral characteristic, or that may cause psychological distress, even if practiced unintentionally.

Leadership Program: This means the inclusion of onboarding, training, and development programs for managers and monitors, of practices that guide decision-making based on D&I principles, making sure that their actions reflect the Company’s values and principles.

Projects and Investments: It is the sponsorship of social projects or investments aimed at training and valuing minorities, and promoting diversity and inclusion in the Company, respecting the Company’s Social Investment Policy.

Normative Review: This means the identification and suitability of institutional policies, to eliminate possible barriers to the promotion of D&I culture and practices.

8. Treatment of Actions in Disagreement with the Policy

Any violation of this Policy terms must be reported using the Reporting Channel or directly to any member of the Executive Ethics Committee or the Company’s Diversity Committee, for the due and possible adoption of the appropriate measures.

The Executive Ethics Committee shall analyzeany noncompliance with this Policy, under the terms of its regulation, and shall establish the appropriate treatment; the Diversity Committee may be consulted for such purpose.

No business relationship must be maintained with ROMI if a conscious and intentional violation of this Policy terms or its guidelines is demonstrated by any of the Company’s collaborators or stakeholders.
It is also up to the Executive Ethics Committee, supporting the Diversity Committee, to impartially establish criteria for dealing with situations not foreseen in the Program, settle controversial situations, equate ethical dilemmas, and ensure uniformity of the criteria used in the resolution of similar cases.

9. Reviews

The Diversity Committee, together with the Compliance Area, shall be responsible for proposing recommendations for improving this Policy, with a view to its permanent updating, noting that any changes must be submitted to prior analysis by the Board of Directors.

This Policy was approved by the Company’s Board of Directors at the meeting held on June 6, 2023, and will be in force from the approval date, for an indefinite period, until there is a resolution otherwise, and can be consulted on the Company’s website, through the link