Code of Conduct

PDG CODE OF CONDUCT

1. TO WHOM IT IS DESTINED

1.1. PDG’s Code of Conduct ("Code") must be complied with by our suppliers, partners, brokerage firms, brokers and all our employees in general, regardless of their hierarchical level or area ("Employees").

1.2. After reading and understanding the Code, our Employees must sign the term of compliance with the Code and deliver it to the local HR representative or management’s representative at the construction site.

2. HARASSEMENT, PREJUDICE AND DISCRIMINATION

2.1. We do not tolerate any type of harassment, prejudice or discrimination, including:

(a) undue preference, partiality or advantage of any kind arising from social or hierarchical position or length of service;

(b) intimidation, humiliation, threats or abusive behavior, by means of gestures, words or acts against the physical or moral integrity of another;

(c) acts or words that may be characterized as sexual harassment;

(d) discrimination based on race, gender, age, marital status, sexual orientation, special needs, appearance, nationality, political beliefs, or any other form of prejudice.

2.2. Some sentences may seem harmless, but characterize moral harassment. Employees must not use aggressive words, such as "incompetent", "slow" or "stupid" in the workplace.

2.3. We also condemn and repudiate any and all forms of sexual harassment, including physical attempts, messages, image exposure or any situation that might make an employee uncomfortable and sexually offended.

3. WORKING CONDITIONS

3.1. Our commitment is to promote a safe and healthy working environment, with freedom of expression and respect for the integrity of our employees, clients and visitors.

3.2. We do not allow our suppliers, partners and partner brokerage firms to adopt inadequate working conditions or use forced or child labor.

3.3. In this context, our employees are responsible for:

(a) respecting the prevailing laws, policies and internal regulations and occupational safety procedures;

(b) always using the individual protection equipment provided for their safety while performing their duties; and

(c) not consuming alcohol or other drugs that may affect their performance at work or put them or their colleagues at risk.

3.4. If any employee identifies a situation that represents a risk to the life or the integrity of the other employees, he or she must immediately report it to his or her manager.

4. CONFLICT OF INTEREST

4.1. If one employee uses his or her position or influence to promote private interests, this may cause conflict with the company. Situations to be avoided include:

(a) any and all types of material or financial advantages that an employee may receive from one of our suppliers or commercial partners;

(b) inappropriate use of privileged information obtained inside the company, especially for share trading purposes;

(c) family relations between employees and suppliers that compromise impartiality;

(d) performance by employees of other professional activities that may interfere in PDG’s business, even if performed outside business hours;

(e) any non-justifiable advantage granted to a given client to the detriment of other clients or the interests of PDG, by employees, especially when the employee has a social or romantic relationship with the favored client; and

(f) parallel activities performed by employees during business hours or with the Company’s resources.

4.2. When hiring one of PDG’s suppliers to perform a service at the home of an employee, for instance, it must be clear that: (i) the negotiation does not imply any type of future favor or retribution; and (ii) the manager must be informed of this fact.

4.3. Certain situations require specific actions, as follows:

(a) romantic relationships between employees when one is a direct subordinate of the other or within the same Executive Department may, under certain circumstances, cause a conflict of interest. If this occurs, employees must report the fact to their immediate manager, who will seek the human resources department for the relocation or dismissal of one of the parties; and

(b) family members of employees may apply for jobs and opportunities as a supplier, provided that they do not have a subordination relationship or influence any decision in the selection and recruitment/procurement process. In these cases, the involved employees must sign the Instrument of Transparency and send it to conduta@pdg.com.br.

5. GIFTS AND ENTERTAINMENT

5.1. We believe that gifts and entertainment opportunities help strengthen our relations with suppliers and business partners. In general, we allow our employees to receive these courtesies, provided that the amount does not exceed one hundred reais (R$100), and they do not influence the choice of supplier.

5.2. Inappropriate gifts and entertainment opportunities may harm the Company and lead to inappropriate business decisions. If any employee receives a courtesy above this stipulated amount, he or she should thank the giver and politely decline the offer, explaining our policy on the issue. The same principles apply when we offer gifts and invitations to our employees, suppliers and business partners. Any doubts on the issue should be discussed with management.

5.3. In general, appropriate gifts are those within the stipulated amount, normally featuring the Company’s logo and distributed in general to all stakeholders. Office supplies, such as mouse pads, calendars, notebooks are considered to be appropriate. Consumables, such as foodstuffs and chocolates, are also considered to be appropriate.

6. USE OF PHYSICAL RESOURCES

6.1. Each employee is responsible for using the Company’s resources carefully and consciously, not for private purposes, pursuant to the legislation in force and without any intention of harming them.

6.2. The use of IT resources must be in strict compliance with the guidelines of the information security policy, available on the intranet or with management’s representative at the construction site. Illegal copies of software, pirate products and access to websites unrelated to work are not allowed. All the messages distributed through our e-mail system are our property; therefore, we may monitor messages without prior notice, if we consider it to be necessary.

6.3. Employees may use their computer and the Internet to access content unrelated to work, but only on an occasional basis and for a limited amount of time. Consulting bank websites, checking test results or looking for telephone numbers are examples of permitted use. Accessing games and porn is strictly forbidden.

7. INFORMATION CONFIDENTIALITY

7.1. Our employees, partners, suppliers, brokerage firms and brokers are responsible for protecting the confidential information to which they have access. Confidentiality is indispensable when dealing with personal information of clients, employees or managers, contract amounts, market negotiations, product characteristics or any strategic issues for the Company.

7.2. The intellectual product resulting from our work or which is somehow related to our activities must also be protected. As a result, it is forbidden to copy, reproduce, transmit or distribute documents, files, models, methodologies, formulas, research, projects, analyses and reports produced by our activities.

7.3. Check the information security policy on the intranet or with management’s representative at the construction site.

7.4. Confidential information is the one that may cause us harm if it is unduly disclosed. Employees must be careful when leaving confidential information exposed in printers, meeting rooms, offices, as well as when disposing of these documents. It is recommended that these documents be fully destroyed before being disposed of. One should also avoid discussing corporate affairs on social media as well as in elevators, external meetings and training programs, taxis, airports or any other public spaces.

7.5. Confidential information includes:

(a) sales tables;

(b) business feasibility studies;

(c) information on the purchase of land;

(d) business results;

(e) employees‘ personal information;

(f) information on companies with which we do business.

8. EXTERNAL RELATIONS WITH CLIENTS

8.1. Our success is measured by client satisfaction. We are therefore committed to building sold and reliable relationships, and improving our service and the quality of the products and services we provide. We treat our clients with courtesy, respect and transparency, providing open communications channels.

8.2. Employees are responsible for acting in an ethical and simple manner, prioritizing clients at all times and must never provide unreliable information or promise something that is not in line with our internal processes and timetables.

9. EXTERNAL RELATIONS WITH SHAREHOLDERS AND THE CAPITAL MARKET

9.1. We have established an open communications channel between our management and the capital market, always seeking to create long-term value for shareholders.

9.2. We provide exclusively public strategic, financial and operational information to serve as the basis for investment decisions through disclosure with transparency, accessibility and authenticity, always respecting legal and ethical principles.

9.3. Only the employees in the investor relations area may have relations with shareholders and the capital market. No employee can benefit from privileged information for the purchase or sale of shares, either directly or through third parties (family members, friends, acquaintances, brokers, etc.).

10. EXTERNAL RELATIONS WITH SUPPLIERS AND CONTRACTORS

10.1. Our relations with our suppliers are based on professionalism and mutual respect. We work with transparent selection criteria and require compliance with all the legal and ethical requirements defined in this document, based on the signature of a Term of Commitment for Suppliers.

10.2. All the acquisitions of goods and services should seek the best cost-benefit balance, maintaining quality and complying with the established commitments and timetables.

10.3. We do not tolerate any act of corruption or fraud; therefore, our suppliers cannot be involved in any illegal activities.

11. EXTERNAL RELATIONS WITH PARTNERS

11.1. Partner companies in the projects must adhere to PDG‘s Code of Conduct and maintain the confidentiality and security of our clients‘ data. The use of this information must be limited to the previously agreed purpose.

11.2. We must treat our clients in a respectful, polite and transparent manner, in line with our values. We consider our partners as strong allies in our commitment to appropriately promote our brand. We work to ensure that our partnerships are successful for both parties, based on respect and mutual trust.

12. EXTERNAL RELATIONS WITH BROKERAGE FIRMS AND BROKERS

12.1. Brokerage firms and brokers are important in the presentation of our products and services to our clients. We value their work as promoters of our brand, products and objectives.

12.2. These relationships are based on professionalism and impartiality. We require brokerage firms and brokers to work in line with our ethical standards and not to provide inaccurate information to clients or to promise anything that cannot be delivered.

13. EXTERNAL RELATIONS WITH THE MEDIA

13.1. We seek to strengthen our image and reputation by establishing a dialogue with our clients, the community and other external stakeholders through the means of communication, which represent an important tool for divulging our facts and news.

13.2. Our relations with the press are based on trust, mutual respect, ethics and professionalism. The disclosure of our information to external stakeholders is under the responsibility of a media relations firm hired to represent PDG.

13.3. Only authorized spokespersons may talk to the media, and only through the media relations firm. The same applies to videos and interviews at construction sites and stands, which may only take place after the Company becomes aware of and analyzes the situation.

13.4. Employees invited to give speeches or lectures or to publish articles or academic papers on a topic related to PDG must consult the involved area and the human resources department and obtain their approval.

13.5. Employees who identify risk or non-compliance situations that may generate negative repercussions and consequently damage PDG’s image and reputation must immediately report it to the media relations firm, so that it can take the appropriate measures. The contacts of the media relations firm are available at www.pdg.com.br or may be obtained with management’s representative at the construction site.

14. EXTERNAL RELATIONS WITH THE COMMUNITY AND THE ENVIRONMENT

14.1. It is essential to maintain relations based on respect, transparency and cooperation with the communities where we operate.

14.2. In our decisions, we consider the impacts of our activities on the social space and in the area surrounding our projects and we are concerned about the preservation of historical and cultural heritage.

14.3. PDG is aware of its role as a driver of progress in the places where it is present and guides its activities so that it is always committed to sustainable development and focused on environment preservation.

14.4. We aim to identify and reduce any eventual environmental impacts resulting from our activities.

15. EXTERNAL RELATIONS WITH PUBLIC ENTITIES AND GOVERNMENT BODIES

15.1. We do not tolerate any type of favor or the payment of any sums to any civil servant in order to obtain advantageous decisions, or the use of influence to do business.

15.2. Any undue or illegal payment may harm our image, in addition to resulting in civil and even criminal responsibility for PDG and the involved employees. Some laws on corruption have very wide definitions for bribery. Individuals may be sued for practices they did not know were illegal. As a result, employees must be very careful about these issues.

16. EXTERNAL RELATIONS WITH UNIONS

16.1. We value our relations with unions and their importance to the relations with our employees. We respect our employees’ right of free association and collective bargaining, recognizing its legitimacy and complying with collective agreements.

17. EXTERNAL RELATIONS WITH COMPETITORS

17.1. PDG is committed to fair competition; it seeks to maintain professional relations based on transparency, respect and courtesy with its competitors, including regarding the exchange of information in the pursuit of common goals.

17.2. We condemn corruption, cartel or any act that may fraud the mechanisms that oversee the sector.

18. ETHICAL ATTITUDE CHANNEL

18.1. PDG offers its employees, suppliers and partners an exclusive channel for reporting situations considered as unethical or which violate this Code and/or the legislation in effect.

18.2. Said events may be reported anonymously. Anonymity is guaranteed for those who request it. The information is received by an independent specialized firm, which ensures absolute confidentiality and the appropriate treatment of each situation, without any conflicts of interest. The information is not tracked, fully protecting the employee’s identity.

18.3. Reports can be made at any time at atitudeetica.pdg.com.br or by calling 0800 721 3221.

18.4. Managers are usually in a better position to help employees with their ethical concerns. For issues regarding the working environment, it is also possible to contact the human resources area.

18.5. Before deciding whether a behavior or activity is inappropriate and should be reported, employees must check if:

(a) it is against the law;

(b) it is against this Code or our policies; and

(c) it is inconsistent with our values.

18.6. We have an Ethics Committee responsible for analyzing exceptional occurrences of unethical situations reported by employees, suppliers our partners, including those not mentioned in this document.

18.7. The Committee is also responsible for maintaining the confidentiality of the received reports.

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