Protecting OGMA — and its People

The Ethics & Compliance Department plays a central role in protecting OGMA’s reputation and long-term sustainability. Through a proactive approach, we work to prevent corruption, fraud, money laundering, and other forms of misconduct — safeguarding not only the company but also its people.

Governance & Compliance at OGMA

OGMA conducts its business with integrity, transparency, and in strict observance of the best national and international corporate governance practices. Our Ethics & Compliance governance structure is designed to promote ethical leadership at all levels of the organization:

• Board of Directors: Provides strategic support to the Ethics & Compliance Program, including supervision of the Corruption Risk Prevention Plan.
• Chief Executive Officer (CEO): Ensures the implementation and continuous improvement of the program, promotes integration of ethical standards into operations, and sets the “tone at the top.”
• Compliance Department: Conducts ethics and integrity initiatives across the Company. Responsibilities include:
• • Preparing and implementing policies and procedures;
  • Promoting ethical awareness through training and communication;
  • Monitoring risks and supervising internal investigations;
  • Providing support to business units and coordinating the work of Compliance Ambassadors;

• Compliance Ambassadors: Acting as ethical role models within each business area, they ensure that decisions are aligned with OGMA’s values and policies.
• Directors & Heads of Department: Act as key promoters of Ethics & Compliance in daily operations, leading by example and reinforcing OGMA’s values in every interaction.
• Embraer Audit & Risk Committee (CARE): Supervises Ethics & Compliance across Embraer and its subsidiaries, including OGMA, in accordance with corporate governance models.
• Internal Audit Department: Conducts audits on program implementation and verifies compliance with anti-corruption laws and other relevant regulations. This department also conducts specific investigations as necessary.

The Ethics & Compliance Program in Action

OGMA’s Ethics & Compliance Program is more than just a framework — it is a commitment to responsible and transparent business practices. This Program was designed to prevent, detect, and respond to risks that conflict with our values, including corruption and internal misconduct.

Fully aligned with the General Regime for the Prevention of Corruption, our Program also follows international standards and guidelines. A strong support from OGMA Management ensures its continuous improvement and integration across all operations.

Strategic planning begins with a comprehensive risk assessment, which guides the implementation of actions across all pillars in the program— from training to controls and third party due diligence.

The Foundation: Our Code of Ethics and Conduct

At the heart of our program is OGMA Code of Ethics and Conduct, which expresses our values and establishes our commitment to:

• Ethical and responsible business practices
• Fair and respectful relationships with stakeholders
• Environmental sustainability
• Positive contributions to the communities where we operate

The Code is complemented by a wide range of internal policies, procedures, and controls, which are reinforced through continuous training and communication — ensuring that everyone understands their role in upholding OGMA’s ethical standards.

Training, Awareness, and Third Party Integrity

Awareness raising and training are central pillars of our program. Through regular training activities and clear consistent communication, we provide employees and third parties with the ability to identify and manage ethical risks before they escalate.

With operations worldwide, we apply consistent due diligence procedures to third parties — including customers, suppliers, and partners — across all regions and business transactions. Such assessments are conducted both before establishing the business relationship and over time, continuously ensuring the alignment with our compliance standards.

HELPLINE: A Confidential Whistleblower Channel

As part of our Ethics & Compliance Program, we provide the HELPLINE — a secure and independent channel where anyone, inside or outside the company, can report concerns in a confidential and safe manner.

The HELPLINE is managed by a specialized external provider and is based on four essential principles:

Anonymous reporting, if the reporter intends to do so

Protection against retaliation

Strict confidentiality, regardless of anonymous reporting

Commitment to the truth of the matter

All reports are analyzed by a specialized OGMA team and communicated to senior management, on a regular basis, in accordance with our policies. The HELPLINE serves both as a protective measure and a driver for continuous improvement.

Continuous Improvement and Collective Responsibility

We review our Ethics & Compliance Program on a regular basis to ensure that it remains effective and relevant. Its strength lies in the commitment of every person at OGMA. Together, we build a workplace and culture where ethical conduct is not just an expectation — it is second nature.

By acting with integrity, we contribute to OGMA’s long-term success, to the trust of our partners, and to the well-being of the society in which we operate.