Companhia Brasileira de Distribuiçao Netherlands B : Marketing Policy

GPA Marketing Policy

1. Purpose

GPA's Marketing Policy ("Policy") presents guidelines (general and specific) on GPA's commercial advertising and marketing actions, including all business units and related companies/institutions, as well as suppliers, service providers, customers, social institutions and partners, among other stakeholders.

The purpose of this Policy is to ensure compliance with applicable regulation and good practices in marketing, sales and advertising activities, ensuring that the communication of products and services is done in a responsible, ethical and transparent manner, respecting all the precepts of sustainability, diversity and consumer rights, in line with the guidelines of all other GPA Policies.

2. Scope

This document applies to all GPA employees, areas, brands, business units and related companies/institutions, in addition to suppliers, service providers, customers, social institutions and partners of the company.

3. Terms and Conditions

Marketing: is the set of strategies and actions for promotion, dissemination and sales of our products and services with the objective of strengthening our brands, conquering new customers and retaining customers who already buy our products and services.

Commercial promotion: these are non-routine actions with a specific objective. It is the offer of valuable experiences and actions that strengthen our brands, such as promotional coupons, special promotions, gifts, etc.

Advertising: is the marketing strategy that involves the purchase of a space in a media vehicle to promote a product, service or brand, in order to reach our target audience and encourage them to buy our products and services.

It can be qualified as a "commercial advertisement".

Communication: A process involves the exchange of information between two or more interlocutors through mutually understandable signs and semiotic rules.

Exclusive Brands: are the product brands that are part of the GPA Group. They are Qualitá, Taeq, Casíno, Cheftime, Pra Valer, Club des Sommeliers, Fábrica 1959, Nous and Finlandek. Exclusive Brands are developed with strict quality control and following market trends and needs.

Interested Parties or Stakeholders: also known as strategic audiences, they are all relevant audiences with interests relevant to GPA, or individuals or entities that assume some type of risk, direct or indirect, in relation to society. Among others, the following stand out: shareholders, employees, community, customers, suppliers, creditors, governments and non-governmental organizations.

Diversity: is the set of characteristics, cultural, biological, social, economic, among others, that make each individual a unique being. In the business context, it is related to the representation of different groups that make up society in the workforce.

4. General Guidelines

Marketing actions are part of our relationship and engagement strategy with our stakeholders, seeking to satisfy their needs, through quality products and services that match the announced characteristics, as well as expectations, in a transparent, respectful and consistent manner. These actions must express the offers and/or messages clearly and guarantee the fulfillment of what is agreed.

Through these actions, we seek to raise awareness of our stakeholders through our communication channels, promoting more sustainable practices and attitudes with less environmental impact.

This Policy must comply with all of GPA's Corporate Policies, Procedures and Regulations. Likewise, ensure strict compliance with current legislation regarding the

distribution of advertising material, promotional actions and visual communication of all products and services, meeting the specifications and standards defined by the regulatory bodies in the Country (at the federal, state and municipal levels) in order to ensure that, in the event of any infraction, it is immediately corrected.

4.1 Relationship and Respect with the Consumer

Any and all marketing actions, campaigns and/or advertising in the media, and/or in all sales channels, whether internet, television media, sales platforms and/or physical points, must be respectful, clear, objective and transparent and must be in line with the Consumer Defense Code, GPA Code of Ethics, Human Rights, Inclusion and Diversity Policy, among other rules that deal with the subject, especially those mentioned in the references below.

Our marketing, promotion and sales practices are regularly evaluated by GPA's specialized professionals, always seeking to improve our practices and policies. GPA is responsible for establishing mechanisms that ensure compliance with legislation and internal policies related to the sale of products and services, as well as product labeling and consumer information, seeking to constantly encourage conscious consumption, sustainability, health and well-being in our brands and businesses.

In addition, regardless of the channels in which communications are being disseminated/broadcasted, we make available to all our stakeholders relationships and customer service channels (Customer Home) and for situations of violations of our policies and our Code of Ethics (Ombudsman Channel).

We are committed to the confidentiality of the personal information of our customers, employees and other stakeholders, subject to the terms and conditions of our Privacy Policy.

4.2 Impartiality of Communication

Any and all commercial or institutional communication must be impartial and must ensure that GPA's values and principles are observed and complied with. Disrespectful, prejudiced or discriminatory forms are not tolerated and accepted. Communications are committed to being inclusive, representative and ensuring respect for all people, in accordance with our Policies on Human Rights, Inclusion and Diversity, Relationship with Stakeholders, as well as Corporate Communication.

4.3 Diversity and Inclusion

In order for everyone to be respected in communication, advertising, and other promotional materials for GPA's products and its exclusive brands, it is the responsibility of everyone involved with communication actions (internal and external) to ensure the production, validation and dissemination of content free from discrimination, without stereotypes and that comply with the principles: accessibility, representativeness, clear and without barriers language; and sustainable consumption.

Find out more by consulting our Diversity, Inclusion and Human Rights Policy and our Inclusive Communication Guide.

4.4 Conscious consumption

One of the pillars of GPA's sustainability strategy is the promotion of supply and conscientious consumption. As a link between thousands of suppliers and millions of customers, we are aware of our responsibility to co-build healthier and more sustainable products and services with our chain and encourage our consumers to choose these products.

Communication is essential as a channel of information and awareness of consumers on conscious consumption, according to Instituto Akatu1, "consumption with better impact, without excess or waste, making choices that contribute to the sustainability of the planet, so that there is enough for everyone forever".

5. Specific Guidelines

5.1 Internal Engagement & Awareness

We understand that the implementation and adherence to this Policy depends on the engagement of internal teams, from the leadership to the operational areas. Thus, the Group's employees involved in the Communication and Marketing process are frequently trained and updated on respect for consumers, inclusive communication, fighting stereotypes, and other good practices with regard to the

1 https://akatu.org.br/

promotion, sales and communication of our products and services from the perspective of sustainable consumption.

5.2 Relationship with Suppliers

All suppliers must follow the laws and regulations, know the values and respect the ethical principles settled in our Code of Ethics, establishing business relationships in an integral and exemplary manner, following the standards established in the Ethics Letter for Suppliers.

5.2.1 Hiring Suppliers

The hiring of communication vehicles, event and/or advertising agencies, promotional actions, among others, must always occur through technical, legal and ethical conduct criteria that attest to the qualification for the action and respect for the Letter of Ethics for Suppliers.

5.3 Provision of Communication and Marketing Materials

It is the responsibility of the Communication and Marketing Department to oversee GPA's communication strategy, brands, products and services. When necessary and in line with the communication proposal, it must make publicity material and institutional campaigns available in all stores and/or other vehicles and media. For this, it is necessary to prepare and make available guidance guides, for all teams involved, containing the amount to be disclosed, disposition guidelines, time and spaces, among other points considered important to ensure the best operation and communication to the consumer.

The production of any material by any area, store or team is prohibited without the proper formal consent of the Communication and Marketing teams. Likewise, the use or mention of the GPA brand(s) and/or any product in electronic, printed, or internet parts is prohibited without the authorization of the aforementioned departments.