Policies and Procedures

Policies and Procedures

OGMA is guided by values that shape its organizational culture and inspire actions based on ethics, transparency, and integrity. With regard to Ethics & Compliance, OGMA clearly defines the expected behaviors through internal policies and procedures, which are widely disseminated to ensure that all employees and stakeholders are aware of and observe them in their daily work.

Below is a list of our main Ethics & Compliance guidelines:

Code of Ethics and Conduct

Based on OGMA's values, our Code of Ethics and Conduct reflects our commitment to conducting business with ethics, transparency, integrity and social responsibility, valuing healthy relationships between our people and with all those we interact with, respecting the environment and contributing to the development of the community in which we operate. The Code also reinforces our adherence to corporate management and accounting good practices, providing clear guidance to ensure that our actions and decisions are made with responsibility, quality, honesty, trust, respect and loyalty, at all times.

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Our Anticorruption Policy reaffirms OGMA’s commitment to preventing corruption and to conducting business in accordance with the highest ethics, integrity, and transparency standards. This policy is the formalization of a set of internal guidelines intended to prevent, detect, and combat all forms of corruption, and applies to the entire company — all employees and third parties we interact with (customers, suppliers, business partners, etc.) — in every location where we operate.

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Preventing money laundering and terrorism financing is a growing concern in international legal systems. With this policy, OGMA establishes specific actions to identify, prevent, and combat such illicit practices. The policy applies to all employees and third parties interacting with the company, in every location where we operate.

Most countries control the export, re-export, or transfer of goods for reasons of national security, human rights, or geopolitical stability. As a global company, OGMA strictly complies with all applicable regulations. Our Export Control Policy ensures that all employees and partners are informed about and comply with such rules, in every location where they operate.

OGMA is committed to conducting business with integrity, transparency, and social responsibility. Our HELPLINE Policy defines how employees and third parties can responsibly and effectively report any situation that may involve misconduct or non-compliance with the applicable laws, the Code of Ethics and Conduct, or any part of the Ethics & Compliance Program. This policy establishes the principle of non-retaliation and the appropriate protection for all the people who report in good faith.

We operate in a transparent, safe and responsible manner — free from conflicts of interest and consistent with our values.
This procedure defines how to identify and manage situations where personal interests may conflict with OGMA’s interests. All individuals — including board members and third parties — must report potential or actual conflicts.
Employees and board members are aware that they must report any:

• Personal investments or transactions with any OGMA supplier, competitor or customer;
• Personal relationships with friends or relatives working in the company;
• Close personal relationship with public authorities;
• External interests that may affect objectivity or performance.

Verification of conflict of interest may also be required:

• Before hiring or promoting an employee;
• Upon designation of board members;
• Before internal transfers between departments.

Failure to report conflicts of interest may result in disciplinary action, or in the case of board members, dismissal by the General Assembly after consultation with the Compliance Department and Embraer Audit & Risk Committee (CARE).

We understand that offering and receiving gifts or hospitality is part of many business cultures. However, OGMA has clear procedures in place to provide guidance on the acceptability of such practices. In general, gifts or hospitality may be received or offered if:

• They are not intended to improperly influence decisions;
• They are not related to active contracts or regulatory decisions;
• They are of reasonable value and not offered excessively;
• They are never in cash or equivalent (e.g., gift cards).

As part of corporate social responsibility, OGMA may support scientific, cultural, educational, or social projects through donations or sponsorships. Donations must be transparent, without any expectation of return, and properly documented. Sponsorships are permitted when promoting the company’s brand, products, or social commitment. OGMA does not make political donations, nor allows third parties to do so on its behalf. These initiatives must never be used to gain undue advantage whatsoever and must comply with all applicable policies and laws.

Events are a strategic part of OGMA’s corporate and business activities. They help promote the brand, strengthen relationships, and consolidate market presence. Our Corporate Events Procedure ensures that all aspects — from planning to execution — are conducted to the highest quality, ethics, and integrity standards.

OGMA conducts its global business with ethics and integrity at the center of its operations. In order to maintain our standards — and ensure compliance with our Code of Ethics and other policies — we conduct due diligence on third parties, such as customers, suppliers, and partners. These assessments are conducted on a regular basis, at the start and throughout the business relationship.
Included herein are: Collecting information to assess third party’s reputation and risk profile;
Risk classification (low, moderate, high) according to OGMA’s Risk Evaluation Matrix;
In-depth analysis of higher-risk third parties — including ownership verification, questionnaires, and alignment with our policies. Every time a risk is identified, mitigation measures are established, and the business relationship may even be refused or terminated if risks cannot be properly managed. Additionally, OGMA prohibits the hiring of agents or sales representatives due to the high risk associated with such services.

Our strength lies in our people • Together, we continue to shape the future of aviation, aiming to fly higher, at all times • Our strength lies in our people • Together, we continue to shape the future of aviation, aiming to fly higher, at all times •

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©2025 Ogma All Rights Reserved

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©2025 Ogma All Rights Reserved