Social Responsibility Policy

1. TERM

This Policy was instituted on 03/27/25 replacing POL012 – Social Incentive Policy, which will be discontinued as of this date. The review of its content may occur every twenty-four (24) months or whenever necessary.

2. PURPOSES

Reaffirm the commitment of ZMAX BLUE SHIP S.A – ZMAX GROUP to Corporate Social Responsibility, establishing principles and guidelines for the organization’s social and environmental performance, in order to contribute to the sustainability of business and society.

Establish the guidelines for the organization’s Social Investment, whether through incentivized or direct sponsorships, in order to ensure that such projects and initiatives are carried out legally, transparently and with integrity.

This document is aligned with the Sustainability Policy (POL011), the Code of Conduct and Ethics (COD001) and other regulations of ZMAX BLUE SHIP S.A – ZMAX GROUP on the subject.

3. SCOPE

The Social Responsibility Policy applies to the entire organization, permeating the activities, operations and services of ZMAX BLUE SHIP S.A – ZMAX GROUP, as well as the relations with its stakeholders.

4. REFERENCES

  • COD 001 – Code of Conduct and Ethics
  • POL011 – Sustainability Policy
  • POL009 – Anti-Corruption Policy
  • POL010 – Related Party Transactions Policy
  • POL001 – Integrated Management System Policy
  • Tax Incentive Laws
  • UN Global Compact
  • Sustainable Development Goals
  • ABNT PR 2030

5. DEFINITIONS

5.1. ABNT PR 2030

Environmental, Social and Governance (ESG) Recommended Practice – concepts, guidelines and evaluation and guidance model for organizations – offers guidance material on ESG, addressing the conceptualization and guidelines for incorporating it in different organizations, providing an evaluation and guidance model to be applied to the proposed ESG criteria.

5.2. UN GLOBAL COMPACT

Launched in 2000 by the then Secretary-General of the United Nations, Kofi Annan, the Global Compact is a call for companies around the world to align their operations and strategies with the Ten Universal Principles in the areas of Human Rights, Labor, Environment and Anti-Corruption, developing actions that contribute to facing the main challenges of society.

It is a voluntary initiative that provides guidelines for the promotion of sustainable growth and citizenship, through committed and innovative corporate leadership. The members of the Global Compact also assume the responsibility of contributing to the achievement of the 17 Sustainable Development Goals (SDGs).

5.3. SUSTAINABLE DEVELOPMENT GOALS

In 2015, the United Nations (UN) proposed to member countries a new sustainable development agenda, the so-called 2030 Agenda, composed of the 17 Sustainable Development Goals (SDGs).

This is a joint effort of countries, companies, institutions and civil society that seek to ensure the defense of human rights, the fight against poverty, the fight against inequality and injustice, the achievement of gender equality, actions against climate change, among other important social and environmental challenges.

5.4. HUMAN RIGHTS

According to the United Nations (UN), human rights refer to all basic rights and freedoms, considered fundamental to human dignity. They must be guaranteed to all citizens, without any type of discrimination, such as color, religion, nationality, gender, sexual orientation and politics.

5.5. TAX INCENTIVE LAWS

Tax incentive laws have existed since 1991 in Brazil and allow individuals and companies to allocate part of their taxes to support the realization of social, environmental, cultural, sports and health projects. These are instruments used by the government to stimulate the development and realization of projects through tax waivers. In this sense, the government makes part of the resources it would receive available to encourage the execution of these initiatives for the benefit of society. The investor, in turn, supports causes that align with their value proposition and can enhance their impact on society.

5.6. SOCIAL INVESTMENT

It is the mobilization and transfer of private resources, which are carried out systematically to institutions, projects and/or actions of public interest.

5.7. INCENTIVIZED SPONSORSHIP

Financial contribution to third-party projects or initiatives that offer as a counterpart a tax benefit due to specific legislation of a public entity (federal, state or municipal).

5.8. SUPPORTED INSTITUTIONS

They are institutions responsible for the execution of social projects supported by the organization, either through incentivized or direct sponsorship.

5.9. PARTNER INSTITUTIONS

They are institutions responsible for intermediating the relationship between the proponents and the sponsoring companies.

5.10. APPLICANTS

They are people or institutions that present projects suitable for financing with government resources.

5.11. PROJECT DILIGENCE

It is a process to identify and prevent the risks and impacts of business activity. In a context of support for social projects, due diligence is carried out so that it is possible to guarantee the suitability of the organizations that will be supported.

6. RESPONSIBILITIES

All employees and partners are responsible for the knowledge and compliance with the guidelines established herein.

The governance of the Social Responsibility theme is composed of the instances defined below:

6.1. ESG VICE PRESIDENCY

  • Reporting directly to the Chairman, it plays a representative role for the ESG pillars, being the main area for ensuring that Corporate Social Responsibility is contemplated in the Group’s strategic decisions, permeating the activities, operations and services carried out by the organization. 
  • It guides the analysis of the actual and potential impacts of Corporate Social Responsibility, driving the implementation of Social Investment, with the objective of disseminating and supporting commitments among stakeholders.
  • It manages the applicable legislation at the federal, state and municipal levels related to Corporate Social Responsibility.
  • It manages the entire process that permeates the support of socio-environmental projects and initiatives carried out by the organization, ensuring that they are executed with legality, transparency and integrity.

6.2. PRESIDENCY/CHAIRMAN

  • It validates the organization’s socio-environmental projects and initiatives, ensuring that Corporate Social Responsibility is included in the Group’s strategic decisions.

6.3. PARTNER INSTITUTIONS

  • It monitors all phases of execution of social projects supported by the organization through tax incentive laws.
  • Reports to the supporter/sponsor company all phases of execution of social projects, from the initial pre-production alignments, through the definition of schedule, alignment of counterparts, execution of actions and accountability.

6.4. APPLICANTS

  • It carries out the execution of social projects supported by the organization through tax incentive laws.

7. GUIDELINES

7.1. PREMISES

The Social Responsibility Policy of ZMAX BLUE SHIP S.A – ZMAX GROUP aims to establish the guidelines for the application of its Social Investment, adding value to the brand, consolidating the institutional image, expanding relationship ties, strengthening strategic positioning, contributing to local development and the quality of life of the communities where it operates.

7.2. GENERAL GUIDELINES

The main guidelines of Corporate Social Responsibility at ZMAX BLUE SHIP S.A – ZMAX GROUP are:

  • Ensure compliance with the ESG agenda, guiding the Group’s performance and growth strategy towards economic, social, environmental and governance development, taking into account the impacts and externalities associated with its operations, based on the guidelines set out in the Sustainability Policy – POL011.
  • Fully comply with national legislation and, where relevant, international standards, with regard to Social Responsibility in order to contribute to the sustainability of business and society.
  • Exercise Social Responsibility in the regions where the Group operates, in line with the Sustainable Development Goals, the 2030 Agenda and the 10 Universal Principles of the UN Global Compact.
  • Respect, raise awareness and prevent the violation of Human Rights in direct activities and partnerships, combating discrimination in all its forms.
  • Establish actions to prevent and combat the use of child labor or conditions analogous to slavery within the organization and in the supply chain.
  • Reinforce the commitment to the promotion of diversity, equity and inclusion, establishing guidelines that direct a favorable environment for the expression and recognition of respect for equal opportunities, non-discrimination and differences.
  • Establish actions to prevent and combat the occurrence of discriminatory practices, moral harassment and sexual violence within the organization and in the supply chain.
  • Carry out socio-environmental projects and initiatives through partners aimed at promoting sustainable development.
  • Map in advance the adverse social impacts generated by our activities, aiming to avoid, prevent and reduce such effects. At the same time, strengthen the positive impacts of our operations through social programs and initiatives in collaboration with public, private and civil society institutions. This implies promoting constant, proactive, and transparent engagement with stakeholders.

The main guidelines of Social Investment in ZMAX BLUE SHIP S.A – ZMAX GROUP are:

  • Carry out incentivized and/or direct sponsorships in accordance with the applicable legislation, rules provided for in this Policy, Code of Conduct and Ethics, Sustainability Policy and other regulations of the Group on the subject.
  • The supported or proponent institutions and their respective projects will be subjected to a due diligence process, and must be duly regularized, be proven legitimate and suitable, and be in accordance with the Group’s ESG premises, strengthening the ethical and integrity standards established by the organization.
  • ZMAX BLUE SHIP S.A – ZMAX GROUP may carry out incentivized or direct sponsorships focused on its business areas or on expanding the relationship with its stakeholders, based on the Sustainable Development Goals (SDGs) of the UN Global Compact, in particular the 8 SDGs prioritized in our ESG strategy, which are SDG 4 – Quality Education, SDG 6 – Drinking Water and Sanitation, SDG 7 – Affordable and Clean Energy, SDG 10 0 Reduction of Inequalities, SDG 12 – Responsible Consumption and Production, SDG 13 – Action against Global Climate Change, SDG 14 – Life on Water and SDG 15 – Life on Land.
  • Institutions or proponents that perform the activities below will be ineligible:
    • Put at risk or damage the image of the organization or any of its members.
    • Cause, or may cause, a negative impact on health and the environment.
    • Violate current law or legal standard, such as: exploitation of child, degrading or slave labor; violation of human rights and those of third parties, including intellectual property; discrimination of race, creed, sexual orientation or prejudice of any kind; use of names, symbols or images that characterize personal promotion of authorities or public servants, as well as activities that unduly benefit public or private entities.
    • Have among their leaders, employees of the organization.
    • Have a political bias.
    • For people and/or entities that have repeated negative exposure in the media and various media.

8. GENERAL DIRECTIONS

8.1. APPROVAL LEVELS

All Social Responsibility projects or initiatives must be forwarded to the ESG area, which will analyze the applicability in accordance with the guidelines established in this document.

Based on this preliminary analysis, the nominated projects and initiatives will be evaluated and approved by the Chairman of the ZMAX BLUE SHIP Group.

9. FINAL PROVISIONS

The above provisions apply immediately to all ZMAX BLUE SHIP S.A – ZMAX GROUP, as of the publication of this Policy.

10. REVISION HISTORY

Rev

00

Date

03/27/2025

Description of Revisions

Initial Issuance

Elaboration

Ellen Monteiro
Sustainability and Social
Responsibility Analyst

Revision

Carolina Araújo
QHSE and
ESG Manager

Approval

Patricia Bueno
ESG
Vice President

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