Companhia Brasileira de Distribuiçao Netherlands B : Ethics Charter for Suppliers

ETHICS CHARTER FOR SUPPLIERS

This Ethics Charter for Suppliers (hereinafter referred to as the "Charter") sets forth the standards to be complied with, under any circumstances, within the supply chain, by all suppliers, service providers, and goods for use and consumption (hereinafter, "Suppliers") of Companhia Brasileira de Distribuição and its subsidiaries (hereinafter, "GPA"), in order to ensure that:

• Employees are treated with respect and dignity in an environment that provides safe and healthy working conditions, respecting all applicable laws and regulations;
• Appropriate mechanisms are set for the preventive management of risks connected to their corresponding operating industry;
• The culture of safety and health at work should be disseminated, establishing educational processes to promote such subjects;
• Processes of manufacturing or service provision are carried out in a way that respects the environment;
• Business relations performed by every Supplier shall be developed in an ethical and exemplary manner, within the strictest compliance with the law, regulations, and internal standards of GPA, as well as being free from any kind of undue favoring, active or passive corruption of Public Agents, extortion, or fraud of any kind.

1. GENERAL STANDARDS

Every Supplier of GPA undertakes to provide only products or services that comply with this Charter, with GPA's internal policies and standards, as well as with the laws and regulations applicable to the lawful performance of their activity, especially, but not limited to the standards mentioned in this Charter.

In this Charter, the word "Supplier" refers to individuals and/or companies that have direct business relations with GPA, the hiring or contracting of which must be formalized through an Agreement. Every hired Supplier automatically undertakes to transmit and enforce this Charter (as well as any exhibits or specific provisions that may be added hereto) to its partners and/or subcontracted or outsourced suppliers.

This Charter is meant to be the starting point of a process of continuous improvement that the Supplier undertakes to observe and work to improve practices.

GPA'S COMMITMENTS

GPA reaffirms its commitment to promote responsible business throughout its supply chain through the Code of Ethics of GPA, the Diversity, Inclusion and Human Rights Policy, and the signing of the United Nations Global Compact, since 2003.

1. 1.1 Whether within the scope of its business practices or in any other activity, the GPA Group is committed to:

   • Strictly comply with the laws and regulations applicable to its activities;
   • Avoid conflicts of interest; and
   • Not tolerate any form of corruption.

   1.2. GPA is committed to establishing fair relationships with Suppliers, regardless of their economic importance. GPA seeks, in compliance with the rules of free competition and free trade, to maintain a long-term business relationship with its Suppliers, considering its capacity and quality in the supply of products and services that meet GPA's needs.

2. GPA strives to keep a constructive and open dialogue with its Suppliers about their ability to comply with to this Charter and may, if necessary, support them to help them meet these expectations.
3. GPA undertakes, through its purchasing practices, to facilitate the application of the Charter by its business partners.
4. GPA is committed to respecting and protecting the environment and, year after year, undertakes to take actions to prevent and minimize the social and environmental impact of its activities. Its actions aim, above all, to reduce greenhouse gas (GHG) emissions, reduce waste generation and food waste, guarantee the sustainable use of natural resources and respect for biodiversity. In order to carry out these actions, GPA builds customer awareness, mobilizes its workforce, and helps its Suppliers respond to these challenges.

1. REQUIREMENTS

2.1 GENERAL STANDARDS

1. The Supplier must comply with the laws, principles, regulations, and standards in force applicable to its operations in all countries where it carries out its activities, in addition to making sure that its own employees, suppliers, and service providers are complying with them. The Supplier shall ensure that this commitment is respected by its suppliers and subcontractors.

2.1.2 The Supplier must refrain from offering GPA's employees and associates, as well as any public agent, any sum of money, gifts, loans, discounts, and other forms of undue advantage, and shall also comply with the guidelines set forth in GPA's Gift & Present

Policy, Anti-Corruption Policy, and Conflict of Interest Policy; the Supplier must also comply with all applicable laws, regulations, and standards (for more information, see our code of ethics currently in force (https://www.gpabr.com/en/ethics-and-compliance/). Any involvement or attempt of corruption or fraud by a Supplier will, if found and proven, be considered as grounds for removing the Supplier at issue from the selection of any competitive processes in which such Supplier could be taking part and/or the agreement with GPA will be immediately terminated for cause.

2.1.3. The Supplier cannot be involved in or support any form of corruption, fraud, or bribery, whether by offering or demanding fraudulent behavior, or by receiving objects of value and/or gifts, whether or not involving public or private agents, in order to obtain

undue advantage, influencing an act or decision, or unlawfully directing business. The Supplier, including its employees and outsourced associates and subcontractors, must fully understand and comply with anti-corruption, money laundering, anti-fraud, and anti-terrorist financing laws and standards, as well as GPA's internal regulations, policies, and procedures. The Supplier must also adopt mechanisms and best practices of compliance and internal controls in order to prevent acts of corruption, fraud, illegal practices, terrorist financing or money laundering by its suppliers and subcontractors.

1. Every Supplier that has a partnership with suppliers and subcontractors in Brazil must make use of the Register of Companies banned from doing business with the Federal Government, such as the so-called CEIS register (Register of Disreputable or Suspended Companies) and CEPIM register (Register of Banned Non-Profit Entities), and from the list of Penalties and Embargoes ("Dirty List") by IBAMA (Brazilian Institute for the Environment and Renewable Natural Resources) as an instrument of approval of its business partners.
2. The Supplier shall establish an effective internal management system to ensure
   that:
   - Every employment relationship is recognized, documented, and performed in compliance with the law, domestic usage or practices, and international labour standards, from recruitment until the end of the employment agreement, in particular for employees with a special status: young employees, immigrants, domestic migrants, autonomous workers, seasonal workers, home workers, piece rate workers, trainees and apprentices, temporary employees etc.;
   - Every business or management activity of the company is carried out transparently and duly registered into the company's records;
   - Disseminate the standards set forth in this Charter so that they are equally applied within the organization and its suppliers and subcontractors.
3. The Supplier undertakes to be fully transparent with GPA. Any attempt of dissimulating, making a false statement, falsify documents or misrepresent facts may lead GPA to suspend or interrupt its business relations with the Supplier temporarily, without prejudice to the measures to compensate for any losses and damages that might have been generated to GPA, Especially with regard to:
   - Information on the origin of raw materials, manufacturing processes and place of production, as well as their corresponding social, environmental, or ethical attributes for offering a product and/or service and considering raw material suppliers, outsourced factories and warehouses;
   - Documents, practices, and internal procedures that fall within the scope of social audits, if applicable, ordered by GPA;
   - Documents required within the context of GPA's Quality Policy, as determined and accepted by the Supplier at the time of its registration or the product specifications accepted during the corresponding business negotiation, whenever applicable.
4. The Supplier undertakes not to subcontract, in whole or in part, any workforce in disagreement with the laws currently in force, which had not been previously stated to the GPA Group and is unauthorized, for manufacturing its own-brand products for GPA or for providing services to GPA. When outsourcing is allowed, the Supplier will be responsible for ensuring the strict application of this Charter by means of external auditors or competent employees, taking responsibility for the products supplied to

GPA. Any non-disclosedsub-contracting may lead to immediate termination of the business relationship, without prejudice of the required measures to compensate for any losses and damages that might have been caused to GPA.

1. Every piece of information resulting from communications or connected to the business relationship between the Supplier and GPA shall be confidential. As such, it cannot, under any circumstances, be shared with third parties without the GPA's prior written consent.
2. The Supplier hereby states to be aware of and comply with antitrust laws in the countries where it operates, and that it does not practice any violation of the economic order, such as taking part in cartels or any other unfair practice that could bring the consequence of making it impossible or distorting free competition in the market, particularly those behaviors aimed at harming a competitor or restricting its access to the market by illegal means.

2.2. HUMAN RIGHTS, OCCUPATIONAL HEALTH AND SAFETY

2.2.1. PROHIBITION OF CHILD LABOR

The Supplier hereby undertakes to respect the minimum age for admitting people as set forth by the corresponding domestic laws for any type of job or work.

The Supplier cannot hire any young professional under the age of 18 for night work or in conditions likely to compromise their health, safety, and moral integrity and/or be harmful to their physical, mental, spiritual, moral, or social development in compliance with ILO Convention No. 182; in addition, the Supplier must comply with the UN Convention on the Rights of the Child (https://bvsms.saude.gov.br/bvs/publicacoes/convdir_crianca.pdfIN PORTUGUESE).

2.2.2. PROHIBITION OF FORCED LABOUR, SLAVE, OF SLAVE-LIKE WORK CONDITIONS

It is forbidden to resort to slave labor or slave-like work conditions like obligatory or unpaid jobs in all its forms, including prison work (as provided for by ILO Convention No. 29).

GPA prohibits the confiscation of employees' personal documents, surety deposits, or payment of hiring fees by employees as a requirement for them to be hired.

Suppliers shall respect the employees' right to terminate their employment agreements upon a lawful and reasonable prior notice of termination and their right to leave the workplace after the service has been completed.

2.2.3. ELIMINATION OF DISCRIMINATION AND ABUSIVE, HARSH TREATMENT

The Supplier hereby undertakes not to practice, encourage or even accept, as regards recruitment, hiring, training, working conditions, assignments, remuneration, payments, advantages, promotions, discipline, termination or retirement, any truculent practice that involves any use of violence, torture, which subject people to vexatious, embarrassing or humiliating situations, as well as to avoid any form of discrimination, whether based on sex, age,

gender, sexual orientation, religion, family situation, ethnicity, social context, illness, disability, pregnancy, national and ethnic origin, nationality, migrant status, gender identity and/or expression or any other identification marker, membership in an employee organization (including union), conviction and/or political, ideological affiliation, physical appearance or any other personal characteristic, in compliance with GPA's Diversity, Inclusion and Human Rights Policy.

The Supplier hereby states that it does not practice or even accept any kind of harassment or abuse, including moral, physical or sexual.

In addition, the Supplier undertakes to check its workforce on a regular basis, seeking to ensure an increase in the number of people from underrepresented groups such as women, black people, LGBTQIA+ people, people with disabilities, among others.

The Supplier hereby states that it creates written disciplinary procedures that are clearly explained to its employees. The Supplier does not apply any withholding on employee wages as a disciplinary sanction.

2.2.4. FREEDOM OF ASSOCIATION

Supplier's employees will be entitled to join the union of their professional class without being required any prior consent from their leaders. The Supplier shall not block, impede or interfere with such legitimate activities.

Where the law restricts or prohibits freedom of association and collective bargaining, the Supplier may not object to any other form of free and independent representation and bargaining according to ILO conventions.

2.2.5. NUMBER OF WORKING HOURS

The Supplier shall set a working day in compliance with the domestic legislation and ILO conventions, always applying the one that offers the best protection in terms of employee health, safety, and wellbeing. The Supplier respects the maximum weekly working hours of 48 hours, excluding overtime.

Overtime hours are performed voluntarily, and cannot be frequent or exceed the limit set by local laws (if there is no limit set by law, they cannot exceed twelve hours a week).

The Supplier shall respect the right of all employees to at least one day off after six consecutive work days, as well as to annual paid leave and the local and national public holidays specified in local laws.

2.2.6. WAGES AND BENEFITS

The Supplier shall pay its employees, including piece-rate workers, wages, overtime, benefits, and paid leave equal to or greater than the legal minimums and/or sector standards and/or those specified in collective bargaining agreements.