COMPLIANCE AND INTEGRITY POLICY

PLAN CONSULTING MARKETING LTDA

PLAN CONSULTING MARKETING LTDA's mission is to act ethically and responsibly, contributing to the sustainable development of public health and public management in Brazil. Our commitment is to ensure that all operations are conducted in strict compliance with applicable legislation and the highest standards of integrity.

Scope and Application

This policy applies to all employees, directors, partners, suppliers and any interested party acting on behalf of PLAN CONSULTING MARKETING LTDA. Adherence to this compliance program is an essential condition for everyone who participates in our operations, whether directly or indirectly.

Principles and Values

I. ETHICS AND INTEGRITY

At PLAN CONSULTING MARKETING LTDA, ethics and integrity are the foundations of all our activities and decisions. These values ​​guide our commitment to transparency, honesty and respect in all relationships, whether internal or external, ensuring that our actions contribute to sustainable development and the construction of a fairer society.

Our Commitment to Ethics

Acting ethically means adopting moral principles and values ​​that guide our conduct in a fair and responsible manner. To this end, PLAN CONSULTING MARKETING LTDA ensures that:

1. Our decisions and actions are made based on ethical criteria, respecting people's rights and promoting collective well-being.

2. We respect the principles of public administration, especially those of legality, impartiality, morality, publicity and efficiency (Art. 37 of the Federal Constitution).

3. We combat illicit practices, such as corruption, fraud, harassment, discrimination and any form of unethical behavior, both internally and in our interactions with partners and clients.

Integrity in Relationships

Integrity reflects our commitment to maintaining coherence between our values ​​and our actions, ensuring that our behaviors are transparent and trustworthy. PLAN CONSULTING MARKETING LTDA bases its relationships with:

Employees: Valuing respect, diversity, equal opportunities and safety in the workplace.

Clients: Providing quality services, with transparency and commitment to the expected results, always respecting the applicable laws and regulations.

Partners and Suppliers: Establishing business relationships based on ethics, equity and compliance, with a careful assessment of integrity.

Society: Promoting actions that contribute to strengthening public management and health, for the benefit of the community.

Ethical Conduct Guidelines

1. Transparency and Honesty:

All data, information and results presented by the company are accurate, clear and reflect reality, without distortions or omissions.

We promote open and accessible communication with all stakeholders, ensuring that our actions are understood and monitored by whoever is necessary.

2. Respect and Inclusion:

We treat all people with dignity, respect and equity, promoting an inclusive work environment free from discrimination of any kind.

We reaffirm our commitment to diversity and the appreciation of different perspectives and experiences.

3. Confidentiality:

We guarantee the confidentiality of all sensitive information from clients, partners and projects, using this information responsibly and in compliance with current legislation, such as the LGPD.

4. Social Responsibility:

We seek to contribute to the well-being of society and to promote improvements in the public health system and public management, aligning our projects with social needs.

5. Ethical Decision Making:

We always evaluate the ethical impact of our decisions, considering how our actions can affect our employees, customers, partners and society in general.

Culture of Ethics and Integrity

To ensure that ethics and integrity are values ​​experienced daily by everyone, PLAN CONSULTING MARKETING LTDA adopts the following practices:

1. Training and Awareness:

We offer regular training to our employees to reinforce the importance of ethical conduct and integrity in our activities.

We publish internal materials and communications that encourage reflection on ethics in the corporate environment.

2. Leadership by Example:

The company's leadership acts as a model of ethical conduct, encouraging positive behavior and guiding decisions that are aligned with our values.

3. Valuing Integrity:

We recognize and reward attitudes that demonstrate commitment to ethics and integrity, reinforcing their importance in the organizational culture.

4. Open Dialogue Channel:

We encourage open communication between employees and senior management, creating an environment in which doubts, concerns and suggestions can be shared without fear.

Management of Ethical Dilemmas

We recognize that situations of ethical conflict may arise in everyday life. To deal with these dilemmas, the company advises employees to:

1. Reflect on the company's values ​​and applicable legislation.

2. Consult their immediate superiors or the compliance department in case of doubts.

3. Use the ethics and reporting channel to report any situation that represents a violation of this policy.

Consequences of Ethical Violations

Violations of ethics and integrity principles will be treated seriously and may result in:

1. Warnings or disciplinary sanctions, including termination of employment in serious cases.

2. Reporting to the competent authorities, in accordance with applicable legislation.

3. Implementation of corrective and preventive measures to prevent further occurrences.

Ongoing Commitment

PLAN CONSULTING MARKETING LTDA believes that ethics and integrity are essential pillars for sustainable success and for building a solid and reliable reputation. Therefore, we are committed to constantly improving our practices and promoting an organizational environment that inspires trust, respect and responsibility.

II. LEGAL COMPLIANCE

We fully comply with applicable national and international laws, such as the Anti-Corruption Law (12.846/2013), the General Data Protection Law (13.709/2018) and other specific regulations for the health and public management sectors.

III. TRANSPARENCY

We ensure clarity and accessibility in the information shared with clients, regulatory bodies, partners and stakeholders.
We regularly and reliably report on the use of resources and results obtained.

IV. IMPARTIALITY AND EQUITY

Our services are offered in an impartial and fair manner, respecting the principles of public administration and the specific needs of each client or partner.

V. SOCIAL RESPONSIBILITY AND SUSTAINABILITY

We work to strengthen public health and management policies, always seeking solutions that promote positive social impact and efficient use of public resources.

Compliance Guidelines

1. Prevention of Corruption and Bribery

PLAN CONSULTING MARKETING LTDA adopts a zero-tolerance stance towards any form of corruption, bribery or illegal practices that may compromise the integrity of our operations and the trust placed in our services. This commitment is based on national and international legislation, such as the Brazilian Anti-Corruption Law (Law 12.846/2013) and the United Nations Convention against Corruption, and reflects our purpose of acting ethically and responsibly in all interactions, whether public or private.

Definitions and Examples of Prohibited Practices

1. Corruption: Act of offering, promising, giving or receiving any undue advantage with the aim of influencing decisions or obtaining illegal benefits.

Examples: Bribing authorities to obtain public contracts or speed up administrative processes.

2. Bribery: Offering or accepting any monetary value, benefit or gift to obtain an undue advantage

Examples: Payment of "facilitation fees" to government officials to expedite permits or approvals.

3. Fraud: Manipulation of information, documents or processes with the aim of deceiving and obtaining illicit gain.

Examples: Changing data in public tenders or contracts.

Prevention Guidelines and Practices

PLAN CONSULTING MARKETING LTDA adopts the following guidelines to prevent acts of corruption and bribery:

1. Prohibition of Improper Payments:

It is strictly prohibited to make, authorize or accept any form of payment, gift or benefit that could be interpreted as an attempt to influence or obtain undue advantage.

2. Gift and Entertainment Control:

Gifts, hospitality and entertainment expenses may only be offered or accepted if they are modest, legitimate and in accordance with this policy and applicable laws.

High-value gifts or benefits that could be construed as attempted bribery are strictly prohibited.

3. Transparency in Contracting:

All contracts, partnerships and financial transactions must be clearly documented, detailing the agreed conditions and the purpose of the considerations involved.

4. Due Diligence of Partners and Suppliers:

Before establishing any business relationship, the company carries out a thorough integrity analysis (due diligence) to assess the history of partners, suppliers and third parties.

Priority is given to suppliers and partners who share the same ethical values ​​and commitments to legal compliance.

5. Continuous Training:

All employees receive regular training on preventing corruption and bribery, including practical guidance on how to identify, avoid and report potential cases.

6. Monitoring and Auditing:

A empresa realiza auditorias internas periódicas para monitorar a conformidade com esta política, identificar riscos e implementar melhorias nos controles internos.

Whistleblower Channel and Protection

We provide a secure, anonymous Whistleblower Channel that is accessible to all employees, partners and third parties, through which it is possible to report suspicions of corruption, bribery or other irregularities.

We guarantee full protection to the whistleblower, avoiding retaliation or losses resulting from reports made in good faith.

Sanctions and Consequences

Any involvement in corrupt or bribery practices will be treated with the utmost rigor, and may result in:

• Administrative sanctions, including dismissal for just cause or termination of contracts;

• Notification to the competent authorities and application of penalties provided for by law;

Legal proceedings and lawsuits, when applicable.

Leadership Commitment

The senior management of PLAN CONSULTING MARKETING LTDA leads by example, demonstrating unconditional commitment to this policy and promoting an organizational culture based on ethics and integrity. Combating corruption and bribery is a collective responsibility that involves all levels of the organization.

2. Conflict of Interest Management

We monitor potential conflicts of interest and implement measures to prevent personal or institutional situations from undermining the impartiality of decisions and recommendations.

3. Data Protection and Confidential Information

We ensure the security of sensitive information of customers, partners and stakeholders, implementing policies and tools to meet LGPD requirements.

4. Training and Qualification

We offer ongoing training programs on ethics, compliance and good practices in the healthcare and public management sectors for our employees.

5. Whistleblower Channel and Whistleblower Protection

We provide a secure, anonymous and accessible whistleblower channel so that employees, partners and third parties can report irregularities or ethical deviations without risk of retaliation.

6. Auditing and Monitoring

We conduct periodic audits and continually evaluate our internal processes to ensure compliance and identify areas for improvement.

7. Relationship with the Public Sector

All interactions with public bodies, their representatives and managers are guided by transparency, ethics and technical rigor, always respecting the principles of legality and morality.

VI - COMMITMENT TO HEALTH AND PUBLIC MANAGEMENT

PLAN CONSULTING MARKETING LTDA understands that the health sector and public management are fundamental pillars for the country's development. Thus, our activities seek to add value through innovative solutions, robust studies and consultancies that promote efficiency, equity and positive social impact.

Responsibilities of Employees and Partners

All employees and partners have the duty to:

1. Comply with applicable laws and regulations;

2. Immediately report any suspected violation of laws or this policy;

3. Actively participate in the company's compliance training and initiatives;

4. Promote an ethical and collaborative environment in its activities.

Consequences of Non-Compliance

Violations of the guidelines of this policy or of current legislation may result in disciplinary measures, which range from formal warnings to dismissal or termination of contracts, without prejudice to applicable legal sanctions.

Review and Update

This policy will be reviewed periodically to ensure its effectiveness and alignment with regulatory changes and best market practices.

PLAN CONSULTING MARKETING LTDA reaffirms its commitment to being an ethical and technical reference in the sector, acting responsibly and promoting solutions that generate a positive impact on society.

Brasilia, DF, January 1, 2025

GEOVANA DANTAS CORRÊA

DIRECTOR