Code of

Conduct and Ethics

of Alpargatas

Presentation 2

Hello!

This code summarizes, in a simple way, our “way of

being”. Here, you will find our principles and the conduct

we expect from our employees, managers, and the

stakeholders with whom we interact around the world.

It is a great challenge to keep our entire team, thousands

of people, connected to our Code of Conduct and Ethics,

but it is through the conduct described here that we

preserve the reputation of our employees, our brands,

and Alpargatas.

A healthy and worthy environment contributes to our

people feeling welcomed, safe and, consequently,

engaged during the time they are with us.

Therefore, the guidelines you will receive below must be

well applied in our routine. Thus, we will contribute to a

more just and ethical society.

We invite you to read this code very carefully, and,

therefore, make a commitment to follow the guidelines

contained here.

Regards,

Beto Funari - CEO

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Contents

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6 ............................................................................................. Introduction

8 .................................................................................. Vision & Principles

10 ............................................................................. To whom it applies?

10 ......................................................... Commitment to our stakeholders

12 ................................................ What we expect from our stakeholders

16 ............................................................. Respect for corporation assets

18 ............................................................... Relationship with the Market

22 ............................................................................. Social Responsibility

26 ............................................................................... Press Relationship

27 .................................................................... Communication Channels

29 .............................................................................. Adherence to Code

30 ................................................................................................ Training

31. ............................................................... Congratulations and Contact

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INTRODUCTION

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Alpargatas’ Code of Conduct and Ethics was prepared by the

Executive Board, supported by the Audit Committee, and was

approved by the Board of Directors on 9/20/2019.

The guidelines contained in this code list numerous

standards that must guide the internal and external relations

of the corporation, expressing the commitment we expect

from our employees, stockholders, directors, officers,

suppliers, and interested parties.

This code is a guide to the corporation’s activities in relation to

the communities where it operates, in addition to serving as

individual and collective reference, ensuring that all the parties

connected to Alpargatas act in alignment with the corporation’s

principles and the local legislation.

It is very important to know and consult this document

whenever you are faced with a situation considered conflicting

during your work routine.

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VISION

To be a powerhouse global of hyper-

connected and desirable brands, digital,

innovative and sustainable.

PRINCIPLES

Responsibility and commitment to your individual role in

achieving the corporation’s goals and final result,

whether financial, product or service, always prioritizing

teamwork.

INSPIRED BY PEOPLE

Consumers are at the center of everything we believe and do. We anticipate their desires by creating trends and memorable brand experiences

FACE THE IMPOSSIBLE

We have the courage to innovate and take risks without the fear

of mistakes. We combine analysis and creativity. We make

simple, fast decisions and strive through continuous learning.

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MAKE IT HAPPEN

We achieve outstanding and sustainable results by acting as

protagonists. We recognize our people and the value of collaboration

and meritocracy.

OWNER’S HEART

We are a team of passionate people, brand ambassadors that stand up

for our company, tackle challenges with resilience and always lead by

example

.

GROW TOGETHER

We work together in a simple and straightforward way. We focus on

results while honoring the individuality that enriches inclusion and

diversity. We promote continuous learning and cultivate the right place

for your personal growth.

TAKE CARE OF TOMORROW

We act now with our eyes on the future by building sustainable

businesses that generate positive social, environmental and

economic impact. We value transparency, ethics and integrity.

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To whom

it APPLIES?

– To all employees who work at the corporation, regardless of

position and function, including directors and officers.

– To all service providers, suppliers, sub-suppliers, customers,

competitors, and other audiences that relate to the company.

SUBSIDIARIES

MUST FOLLOW

THE PRINCIPLES PROVIDED HEREIN.

COMMITMENT TO OUR STAKEHOLDERS

– We respect the individuality of each one and seek for transparent

relationships, based on basic principles of ethics and relationship.

– We aim at the well-being and human and professional development

of employees. Thus, in addition to respectable salaries and benefits,

we maintain education, safety and health at work programs.

– We value the development of our employees and recognize

people based on their results and achieved goals. We manage

employees with respect, transparency, and impartiality. 10

– We apply the concept of meritocracy in our short and long term

incentives. The individual goals are contracted, validated at different

levels of the organization, and, through the management system,

are systematically monitored.

– We are committed to equal job opportunities for all and non-

discriminatory practices, regardless of race, sex, religion or

nationality.

– We do not tolerate any favoring or discrimination against any

employee.

– We provide equal opportunities for access to work and

professional advancement through selection, admission and

promotion processes, always aiming to identify the most

appropriate and qualified people to the profile and needs of the

position.

– We value a work environment without abuse, privilege or preference.

We do not engage or promote relatives in cases of direct or indirect

subordination, interdependent or correlated functions, and activities

that may characterize conflicts of interest. Relatives mean: spouses,

consanguinity kinship relationships, by affinity, adoption in a straight

line of ancestry (parents, grandparents), descent (children,

grandchildren) or by collateral relationship (brothers, brothers-in-law,

cousins, nephews, sons-in-law, daughters-in-law, etc.). Common-law

partners and affective relationships (dating) are also classified into

this category.

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– We provide a safe, healthy, ethical, transparent work environment

and free from any prejudice or injustice, which encourages the open

space for creation, which is motivating, and which encourages

cooperation between teams.

– We guarantee employees the lowest risk possible in their

activities and strictly comply with the work safety rules

established by law, as well as internal procedures. The goal is to

offer the best health and safety conditions at work.

– We encourage an attitude of respect and collaboration among

employees. In this way, we ensure a positive internal environment

for business growth.

– We respect the confidentiality and privacy of our employees when

dealing with private matters, as long as they do not damage the

corporation’s image or interests.

– We respect legitimate individual rights and we do not tolerate - under any circumstances - any attempt at bullying, sexual harassment, disrespect or prejudice.

– We maintain institutional anticorruption policies and practices

(bribery, influence peddling, undue favoring, etc.), money

laundering, fraud and other illegal or criminal actions.

– We follow the ethical and self-regulatory guidelines of the

business associations to which we are linked.

WHAT WE EXPECT FROM OUR STAKEHOLDERS

– Situations in which personal interests may conflict, or appear to

conflict, with those of the corporation or its subsidiaries must be

avoided. 12

In general, conflict of interest is a situation in which the

employee’s position or his responsibilities within

Alpargatas present an opportunity to obtain personal gains

or benefits (other than remuneration for work), or

preferences for personal interests, placing them above the

employee’s duties and responsibilities towards the

corporation or its subsidiaries.

In these cases, the exemption of shares is compromised and puts

the reputation and integrity of Alpargatas, its managers and

employees at risk.

– Any attitude that conflicts with the corporation’s goals and business

will not be accepted.

– The relationship with colleagues, customers and business partners

must always be cordial, respecting characteristics and opinions.

– No provision of services (including within the framework of the

Brazilian Consolidated Labor Laws - CLT) to other companies or

entities during working hours will be allowed, and any exceptions

will be submitted for approval by the Board of Directors and/or the

Ethics Committee, as the case may be.

– The performance of external, professional and personal activities

is allowed, as long as they are carried out outside working hours,

which do not conflict with the group’s business, interests and

sector of activity, do not impair their performance in the functions

performed at the Corporation and do not use the Corporation’s

infrastructure or information.

– Any activity or work performed on behalf of Alpargatas in an

external environment that is not part of the routine duties of the

position, such as classes, lectures, presentations of brand

cases or presentation of materials containing corporation

information and know-how must be submitted for prior approval

by the manager or immediate superior, and as long as the

limits of confidentiality of corporation information are respected.

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– The corporation’s premises must only be used for activities related

to your personal development with prior authorization from your

manager or immediate superior.

– The use of drugs or carry weapons of any kind on the corporation’s premises is not allowed.

– The consumption of alcohol, in a moderate way, will be allowed on

the Corporation’s premises when there are authorized celebrations

and/or parties. Those responsible for the events at Alpargatas must

always reinforce, in all communications, that employees cannot

consume alcoholic beverages and, subsequently, drive.

– It is strictly forbidden to supply and/or provide services to Alpargatas

by a company owned, even if in a minority, by the employee or his

relative, as defined in the item “Commitment to our stakeholders” of

this Code of Conduct and Ethics, and, also, by a company of which

the employee or his relative are managers.

– The use of the office, function or position in order to guarantee any

favoring for you or for others is not allowed.

– The receipt of gifts is allowed as long as the Gifts and Amenities

Policy is fulfilled, which is available on the corporation’s website.

– Any expense must be submitted for approval in accordance with the

guidelines described in the policy in force.

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– The laws and regulations applicable to the company must be

complied with, as well as the internal policies and regulations,

always prioritizing a high standard of integrity.

– We must not disclose any non-public information about the

Corporation on social networks.

– Corporation property information, comments or rumors that involve

the name of Alpargatas, its managers and employees must not be

disclosed on internet portals or on social networks in general. We

must always ensure the security of non-public information and that

such information is made available only in authorized areas.

– The use of email, internet, telephones and other means of

communication must be carried out in a professional manner,

always with an appropriate, respectful language and without

defamatory words. The corporation’s electronic media must not be

used for games, chain messages, exchange or storage of content

in disagreement with Alpargatas’ ethical principles, such as:

obscene, pornographic, violent, discriminatory, racist, defamatory

content, which disrespect any individual or entity, and which are

contrary to Alpargatas’ rules and legislation in force.

– Non-public information must be protected so that its disclosure does

not affect Alpargatas, our stakeholders and society in general, as

well as the trust relationships established between us and these

stakeholders. Thus, it is not allowed to use non-public information for

private purposes, or to pass it on to third parties, either by

professional email or in any other way, without prior authorization,

even after leaving the corporation.

– The copyright and intellectual property of third parties must be

respected. Therefore, the use or sharing of unauthorized copies,

or illegally obtained, of materials, systems and software from

third parties is not allowed.

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Only the use of computer programs licensed by the

corporation is permitted.

RESPECT FOR CORPORATION ASSETS

Each employee of Alpargatas is responsible for the correct use and

custody of the organization’s goods and assets, which must not be

used for personal benefit, including: real properties, assets,

equipment, facilities, business plans, technical and market

information, computer programs, product models, correspondence,

reports and other documents, and objects that are part of Alpargatas’

equity.

The appropriation or misuse of any of these assets and their

copying, sale or distribution to third parties is serious infractions that

may result in labor and criminal penalties.

– Patents and inventions - The inventions developed by Alpargatas

employees in the exercise of their function for the corporation, as

well as patents and other rights resulting from these works, belong

to Alpargatas and must be incorporated into our assets, remaining

with us even after the dismissal of employee.

– Accounting and other records - The records must be prepared and

monitored in a true manner, both by those directly responsible and

by the managers, obeying the determinations of the legislation and

the current tax rules, based on correct and legitimate

documentation. The entries and records are available to managers,

the corporation’s control and audit areas.

– Privileged information - The professional who becomes aware

of information that is not public must keep it confidential, even

after the termination of his relationship with the corporation.

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* d i d e

The use of privileged information for personal or

third party benefit is a crime, subject to labor, civil

and criminal penalties.

Procedures to prevent the misuse of inside information are

governed by the Securities Trading Policy and the Disclosure Policy

for Alpargatas’ Material Event, which can be consulted on the

corporation’s website www.alpargatas.com.br. Procedures to

prevent the misuse of Inside Information includes, among others:

(I) Fixation of periods prohibiting the trading with securities issued

by the corporation (such as, for example, in the period from the

date of the notice until the day of the disclosure, including any

material event to the market);

(II) Obligation of confidentiality about information related to a material

event of the corporation and its subsidiaries;

(III) Under specific conditions, communication to the corporation

about ownership and trading with securities issued by the

corporation.

The use of inside information for benefits by employees,

directors or third parties with whom the corporation relates will

not be allowed, and it is prohibited to use it for external use or to

suggest investment to family, friends or any interested party to

obtain advantages in the stock market.

No personal activity or business of employees can be carried out

with the use of corporation information or in prejudice to its

functional responsibilities. *All information related, directly or indirectly, to the Corporation and its portfolio companies that may significantly influence: (i) the

price of the securities issued by the Corporation traded on the market; (ii) the decision of investors to buy, sell or maintain the

aforementioned securities, or even (iii) the decision of investors to exercise any rights inherent to the condition of holders of securities

issued by the Corporation and its portfolio companies or referenced to them pursuant to law, and which are not yet public knowledge.

INTERNET/

ELECTRONIC MAIL/

EQUIPMENT

Access to the internet and telephone, as well as the use of Alpargatas’ emails,

software, hardware, equipment and other assets must be used for the exercise

of professional activity. Although we understand the need to use these tools for

personal purposes, they must not be used excessively or in a way that interferes

or affects our work.

Corporate email and any equipment owned by Alpargatas (desktops,

notebooks, etc.) used on the corporate network may be monitored to

ensure that these resources are used appropriately and in accordance

with applicable regulations.

RELATIONSHIP WITH THE MARKET

– We strive to establish effective relationships with our stakeholders. For this purpose, we encourage dialogue and cooperation, welcome suggestions and criticisms to leverage our performance, and answer questions quickly.

– We conduct negotiation and engagement with third parties with fairness,

ethics, integrity and impartiality. We adopt technical, objective, transparent and fair selection and engagement criteria so as not to allow favoring of any kind, or to discredit the partnerships formed. Only then will we be able to have the necessary credibility for the development of the corporation’s business. We believe that the shared value is beneficial to all parties involved, providing long-lasting relationships.

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THE CONDUCT OF ALPARGATAS AND OUR EMPLOYEES IN

RELATIONSHIP WITH SERVICE PROVIDERS, SUPPLIERS,

CUSTOMERS, COMPETITORS AND OTHERS MUST BE

GUIDED BY THE FOLLOWING ACTIONS:

SERVICE AND QUALITY We provide the market with quality products and services that meet the

requirements of the legislation and standards related to the sector, seeking

customer and consumer satisfaction and exceeding their expectations. We

provide information about our products and services in a clear, correct and

complete manner in order to allow the best choice by the customer and the

consumer. We provide adequate service channels to listen carefully to

customers and consumers and resolve their pertinent requests, complaints

and suggestions promptly.

CONFIDENTIALITY We are committed to keeping the information reserved for our customers

confidential. We value customer and consumer privacy and use information

security and protection devices to ensure that they are used only for your own

benefit and with your knowledge.

TIED BUSINESS No customer must be forced to purchase a product or service in prejudice to

another. We reject the use of tools, such as tied sales and other ways of

imposition, or constraints on doing business.

PROCUREMENT & CONTRACTS Our relationship with suppliers and other partners must be guided by

honesty, an adequate cost-effective ratio, technical and financial reliability,

integrity in conducting negotiations, always respecting legislation, the

environment, international labor practices and commercial, social and

contractual rights.

We prepare contract models that may be understood by service providers,

suppliers and customers that demonstrate the rights and duties of the

parties.

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We encourage our suppliers and service providers to adopt sustainable

development practices, and we require the fulfillment the legal, labor,

environmental and safety standards, focused on preventing any illegal or

criminal acts (corruption, influence peddling, fraud, money laundering,

smuggling, among others), and any prison, slave, involuntary, forced or child

labor is strictly prohibited in order to comply with the Alpargatas Code of

Conduct and Ethics.

We require service provider corporations that their employees, while

providing services to Alpargatas, are guided to respect the guidelines of the

Alpargatas Code of Conduct and Ethics and all applicable legislation.

COMPETITORS In no event we denigrate the skills or other characteristics of our

competitors. We act according to the principles of free competition and

respect the reputation and opinions of our competitors.

We value intellectual property and do not use information from competitors

without their express authorization.

PROFESSIONAL, BUSINESS

ASSOCIATIONS AND ENTITIES We participate in business associations with a spirit of cooperation,

aiming at improving the sectors of the economy in which we operate, and

agreement of any kind or exchange of information that undermines free

competition is repudiated.

STOCKHOLDERS AND INVESTORS We are part of Bovespa’s Level 1 Corporate Governance, which attests

to our concern to provide more transparency, honesty and prudence in

the information provided to the market. We strictly follow the applicable

rules and regulations, in addition to providing correct and transparent

information about our performance and strategy to stockholders, market

professionals and potential investors.

TRANSPARENCY AND ACCOUNTABILITY We must not take opportunities or prospecting

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businesses that have been identified by the corporation to take personal

advantage of them.

We keep our stakeholders and society informed about Alpargatas’ purposes,

behaviors and results.

We provide timely and correct accounts. Our reports, statements,

announcements and statements reflect the reality of the organization with

clarity, simplicity and consistency. We guarantee the independence of our risk

management, compliance and audit processes. We do not use information

that circulates internally for private purposes.

RELATED PARTIES The Corporation’s and its subsidiaries’ organizational structure is established based on the major interests of the respective companies and never on the personal interests of stockholders, managers or third parties. We adopt corporate governance practices that mitigate conflicts of interest

between our managers and Alpargatas’ stockholders and investors.

Transactions with related parties of Alpargatas must reflect commutability

and transparency, guaranteeing stockholders, investors and other

interested parties that such transactions are guided by the provisions of

the best corporate governance practices.

Accordingly, we must follow and comply with the internal guidelines that

guide transactions between related parties, more specifically our Policy for

Transactions with Related Parties, approved by the Corporation’s Board of

Directors.

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So

cial

Responsibility

We always try to be in conformity with the communities in

which our units are located, respecting people, their

traditions, their principles and the environment.

We act to improve the socioeconomic conditions of the

communities, particularly those in which we operate.

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CHILD, FORCED AND SLAVE LABOR We do not admit child labor, prison, involuntary, forced or slave labor, and we

make sure that our suppliers do the same.

COMPLIANCE WITH LAWS Our philosophy is strict compliance with the legislation of the countries in

which we operate, and we expect the same behavior from our employees.

We internally promote the perception that laws, rules and regulations do

not exhaust the ethical implications of all situations. For this reason, we

encourage reflection on how our actions, from an ethical point of view,

influence our stakeholders, society, and the environment.

POLITICAL/PARTY ACTIVITIES We do not engage in political activities, and each employee who wishes to

participate in this process must do so individually, without involving the name

or resources of the corporation. Any political activity carried out by our

employees must take place outside the work environment and working hours.

WE KEEP OUR DECISIONS FREE FROM PARTY OR

IDEOLOGICAL PREFERENCES.

RELATIONSHIP WITH AUTHORITIES, PUBLIC

OFFICIALS AND POLITICAL PARTIES We understand that this type of approach must be based on professional

and correct actions.

Any form of pressure or request from public officials that does not meet

this definition must be refuted and communicated immediately to the

corporation’s management.

The relationship and interaction with any public officials and private entities

must be guided by the best market practices, respecting the rules that govern

government, the applicable legislation and regulation, as well as the

principles established in our Code of Conduct and Ethics.

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We are committed to interacting with public officials with ethics, morals,

honesty, professionalism, transparency, and in full compliance with the Anti-

corruption Laws.

Thus, we must reject and prevent any and all ways of corruption, favoring,

extortion or undue advantage.

Our procedures to prevent any action that could be characterized as

corruption are described in the Policy for Relations with Public Officials.

TRADE UNION ACTIVITIES We seek to maintain a respectful relationship with union entities and do not

discriminate against union professionals.

We respect the right to collective bargaining and free union association.

We comply with collective agreements and conventions, and follow labor

rights and duties.

ENVIRONMENT All of our activities are carried out in compliance with legislation and

environmental standards, seeking, in addition, to optimize the use of natural

resources and preserve nature and biodiversity.

We cooperate with the communities where we operate to develop

preservation actions and raise awareness about causes related to the

environment.

We adopt practices designed to mitigate the environmental impacts of

our business and operations.

EDUCATION & SOCIAL ACTION We seek to collaborate with the development of the communities in which

we operate through Alpargatas Institute, using our own or third-party

funds, with educational, social and cultural projects that serve children,

adolescents and young people. In addition, we support and carry out

professional training and learning programs for young people.

* It means Federal Law No. 12,846/13, as regulated by Federal Decree No. 8,420/2015 and,

24 as applicable, Law No. 8,429/1992 (Administrative Improbity Law) and Law No. 8,666/1993 (Bidding Law)

RELIGIOUS ENTITIES We seek to maintain a good relationship with entities of a religious nature,

respecting all creeds and beliefs, both of our employees and suppliers and the

communities where we operate.

Any donations for social works that are coordinated by entities of this

nature must be made by Alpargatas Institute. Any requests that are not

part of the scope of the Institute’s activities will be evaluated by the

corporation’s executive board.

SOCIAL ECONOMY ORGANIZATIONS Partnerships with civil society entities must aim at the preservation and

recovery of the environment and the social, economic and cultural

development of the communities reached by the actions resulting from these

partnerships.

By means of Alpargatas Institute, we make contributions (sponsorships,

donations, etc.) to Non-Governmental Organizations (NGOs), Civil Society

Organizations of Public Interest (OSCIPs), philanthropic entities, assistance

and other similar associations, to the compliance with applicable legislation,

and compliance with our corporate guidelines, provided that they are proven

to be legitimate, suitable and that the contribution in question is not made

aiming at ensuring any business or improper advantage (financial or not) for

the Corporation or third parties.

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PRESS RELATIONSHIP

We believe that print media (newspapers, magazines) and

electronics (radio, TV, internet in general) play an important role

as social information channels. In this way, whenever possible,

we will be open to meet to requests from journalists.

The information disclosed by the media has an influence on the

image of our corporation, and for this reason, we maintain a

centralized work to guarantee the integrity of the information.

Statements on behalf of Alpargatas may only be made by the

President and the Officers.

If necessary, these spokespersons will be in charge of delegating the

responsibility of serving the media to other officers. No statement can

be made without the consent of the corporation’s Executive Board. If

you are approached by an external communication vehicle, contact

your immediate superior, with the communication area or, also, with

the press office of the Corporation.

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COMMUNICATION

CHANNELS

Employees, managers and members of committees and commissions have an

obligation to report any violation, or even suspected violation, to the Alpargatas

Code of Conduct and Ethics and/or applicable laws, including if committed by

third parties that provide services to the Corporation.

In addition, we must inform our manager whenever we become aware of

any situation that is, or may be, a conflict of interest.

If you experience any difficulty in interpreting our Code of Conduct and

Ethics, or have any questions about how to act in a given circumstance,

do not hesitate to ask.

Consult your manager, immediate superior

or the Human Resources area. Maintaining an open communication channel is part of our principles. No one will

be punished or retaliated for information in good faith about suspected

inappropriate behavior or that is contrary to our principles.

The corporation has a specific channel for receiving complaints:

AlpaEscuta, which can be accessed by calling 0800 7707791 or via the

web at www.alpaescuta.com. AlpaEscuta is an independent and

impartial tool, operated by an internationally renowned service

provider, which will ensure the confidentiality of information and

complaints received. This channel is also open for receiving complaints

from third parties. Anonymous statements will also be received.

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Communications regarding complaints must be accompanied by as

much information as possible, such as:

(I) Objective and impartial description of the fact; (II) Where and when the violation happened or is happening; (III) Who are the people and organizations involved;

(IV) Documentation to assist in the assessment of the case

and forwarding any possible actions.

Complaints or accusations without consistent reasoning

will be disregarded.

Complaints may also be reported via e-mail:

comissaodeetica@alpargatas.com.br.

The Ethics Committee is subordinate to the President, and has the

following duties:

(I) Implement and disseminate the Code of Conduct and Ethics;

(II) Prepare and provide training on integrity and ethics and

dissemination and awareness campaigns, jointly with the Executive

Board and the Audit Committee;

(III) Review and update the Code of Conduct and Ethics from time to time;

(IV) Assess any violations of the Code of Conduct and Ethics, including those

reported through AlpaEscuta or by any other means;

(V) Propose, as the case may be, the appropriate penalties, except in

cases involving members of the committee itself, the Executive

Board or the Board of Directors, which will be analyzed by the

Corporation’s Board of Directors. 28

ADHERENCE TO

CODE

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All managers, members of committees and commissions and employees

when they join the Corporation declare their knowledge and agreement with

this Code of Conduct and Ethics. At the same time, managers, members of

committees and commissions and employees must disclose the existence of

any actual or potential conflicts of interest.

In addition, every year, each manager, member of the committees and

commissions and employee of the Corporation renews their commitment to

this Code of Conduct and Ethics. They must also repeat annually the

confirmation of any actual or potential conflicts of interest. Even though it has

already been reported and authorized, we must repeat the disclosure of

conflicts of interest throughout our stay in the Corporation.

The renewal of the commitment to this Code of Conduct and Ethics

is also necessary in the event of changes to the provisions

provided for herein.

In relation to our suppliers, service providers and business partners,

adherence to this Code of Conduct and Ethics is made by contract.

Training

The actions of education and communication on the guidelines

of this Code of Conduct and Ethics and the various policies

adopted by Alpargatas and which are part of its integrity

program, defining clear standards of conduct and in line with

the corporation’s principles help managers and employees:

– Deepen the knowledge of the integrity and ethics guidelines, as well as

their application to business and to the management of processes and

people;

– Be able to identify, prevent and resolve ethical dilemmas, conflicts of

interest, interpersonal conflicts and misconduct inherent in their daily

activities, and get to know the Alpargatas Complaint Channel.

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Alpargatas’ education and

communication practices

include:

Education Training actions for all managers, members of committees and

commissions and employees when they join the Corporation and whenever

the Code of Conduct and Ethics is changed, as a way to enable the entire

Corporation to practice the precepts of the standards of conduct

established.

Communication Awareness campaigns, communications on specific topics related to ethics

and disclosure of policies and guidelines.

Penalties

Non-compliance with the guidelines of this Code of Conduct and Ethics, as well as denunciations and accusations in bad faith, is subject to penalties established in the Corporation’s internal policies.

In the case of suppliers and/or third parties with whom

Alpargatas relates, illegal conduct or which violates this Code

of Conduct and Ethics is a breach of contract and is subject

to the termination of the respective contract.

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www.alpargatas.com.br

Alpargatas S/A – Av. das Nações Unidas, 14.261 Ala A – 9°, 10° - 11° andares – São Paulo – SP – Brasil

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