Social Investment Policy

1. Purpose

In accordance with the internal rules adopted by Romi S.A. and/or its subsidiaries (“Romi or Company”) through its Code of Business Ethics and Conduct, especially those tangent to its social responsibility, integrity, honesty, transparency and respect for norms and current laws, this Social Investment Policy (“Policy”) represents Romi’s commitment to social development and aims to define the guidelines, focus, operation method and procedures of Romi’s Social Investment.

2. Main Settings

The main definitions necessary for the correct understanding of this Policy are as follows:

Social Investment: voluntary allocation of Company resources in a planned and monitored manner, for social purposes, that is, Romi’s contribution directed at meeting the needs and priorities, mainly of the communities and/or institutions supporting them, with a focus in the transformation, covering, for the purposes of this Policy, donations and sponsorships;

Ethics Committee: internal committee constituted in Romi, composed of the internal auditor and executives of the Company, who has, among other duties, to ensure the application of the Company’s Code of Ethics and Business Conduct.

3. Introduction

In the Company, Social Investment is one of the operation methods that contribute to the strengthening of the company’s relationship and its business role in society. It assumes importance as one of the operation methods to promote development, resulting from the company’s activities in the communities and in the country as a whole, strengthening the organization’s sustainability strategies and fomenting democracy.

Throughout its existence, Romi has been carrying out significant social practices through support to programs, projects and actions developed by civil society organizations, public and private institutions, with the strategic objective of keeping the company’s social commitment always alive and active.

In addition to the benefits to society, Social Investment also benefits the Company, insofar as:

  • It promotes its insertion in the communities, mainly those of the surroundings of the places where it develops its activities;
  • It generates economic and social value for society, reflecting on the Company, and its stakeholders;
  • It strengthens the Company’s image and recognition in society.

In this document, the Company presents Romi’s guidelines, objectives, focus, operation method and procedures for Social Investment.

4. Guidelines

The following guidelines of this Policy must be observed in all forms of Romi’s social activity:

4.1. Romi’s Social Investment practices must be aligned with the policies and principles, with the strategic planning and organizational budget of the Company.

4.2. Romi’s Social Investment will take place in the following ways, together or separately:

a. Support to programs, activities, projects and actions developed by third parties, through sponsorship and donations in pecuniary, assets or rights;
b. Partnership with public and private institutions; and
c. Use of tax benefits to support social, educational and cultural projects.

5. Social Investment

The projects eligible for Romi’s Social Investment will necessarily be developed through a proponent:

a. Legal entity of a private nature, organized in the form of (i) a non-profit company, such as associations and foundations, formally constituted and active in fact and in law or (ii) exceptionally, a for-profit company, at the discretion of the Executive Ethics Committee, as long as they are projects carried out directly or indirectly by cultural producers, under the laws of incentive to culture and sports, and that have incentive destination controls duly regulated by specific legislation;

Will not be eligible to receive Social Sponsorship and/or investment:

a. Individuals; and
b. Institutions of an ideological, political or religious nature.

Romi’s Social Investment may be allocated to the following areas:

a. Regular Education;
b. Education for Professional qualification;
c. Innovation;
d. Rights of the Child and Adolescent;
e. Culture;
f. Rights of the Child and Adolescent;
g. Sports;
h. Fairs and Events of a social nature; and
i. Other social projects adhering to this Policy.

6. Procedures

Annually, upon a proposal from the CEO, the Board of Directors will approve the financial budget to support projects or initiatives that may be characterized as Romi’s Social Investment, which will establish the minimum and maximum annual limits to be applied in Social Investment, in each category, as well as the individual limits for approval of financial support, above which the approval of the Board of Directors will be required.

The budgetary limits mentioned in the previous paragraph do not apply to donations through full use of tax benefits, for which there is no need for additional resources to be contributed by the Company.

All Social Investment projects must be carried out by the Institutional Relations Management, and must be structured and formalized with at least the following requirements: applicant, description, justification, objectives and expected results, target public, schedule, in addition to human resources, materials and financial information to be applied and their respective origins (“Project”).

The Institutional Relations Department shall analyze the Project in all its aspects and impacts, in accordance with the above paragraphs, including the availability of applicable budget funds. In case of validation of the Project, the Institutional Relations Department will it to the Internal Audit which, in turn, will submit it to the Ethics Committee of the Company.

After analyzing the Project validated by the Institutional Relations Department, the Committee will express its opinion, favorable or otherwise, on its adherence to this Policy and to the Company’s Code of Ethics and Business Conduct, other policies, as well as the legislation and ethical principles that Romi’s actions.

The Chief Executive Officer, in possession of the Project duly validated by the Institutional Relations Department, as well as the opinion of the Ethics Committee, shall decide whether or not to approve the project and, if applicable, submit it to the Board of Directors for approval, pursuant to the Company’s Bylaws and other approval limits defined by the Board of Directors.

Once the Project is approved, it will be executed under the coordination of the Institutional Relations Management, which will inform the Controller to make the necessary accounting and financial records.

The engagement of Romi employees in the practices related to Social Investment will occur in the scope of the exercise of their positions or through volunteer programs, in Social Investment projects to be developed in accordance with this Policy, being prohibited the performance of employees, on behalf of Romi, in any other way.

7. General Provisions

This Policy should be applied in accordance with the Company’s Anti-Corruption Policy.

In case of doubt regarding the interpretation of this Policy, the Ethics Committee should be consulted.

The Legal, Institutional Relations and Internal Audit Departments, jointly or separately, shall propose updates of this Policy, when necessary, especially, but not limited to, due to legislative changes, changes in the definitions used in this Policy, changes and/or additions arising of recommendations of good corporate governance practices and changes in the regulations of B³ S.A.- Brasil Bolsa Balcão in the segment to which the Company is listed, submitting it for the approval of the Committee.

This Policy became effective as of the date of its approval by the Board of Directors on June 12, 2018, amended on June 6, 2023, and will be available on the Company’s website: