Code for Ethical Conduct

Approved by the Board of Directors on 10/18/2023.

Dear employees:

LOG-IN Group's Code for Ethical Conduct is a guide to good practice conduct of mandatory compliance and directed to all our employees, regardless of their hierarchical level and business unit, such as directors, officers, committee members, employees, outsourced workers, interns and young apprentices. It also applies, as applicable, to third parties that are present in our value chain, such as service providers, suppliers, commercial partners, grant and sponsorship beneficiaries and anyone who in any way acts on behalf of Log-In Group companies.

This Code also summarizes the behavior expected from our employees and third parties towards Log-In,

its employees, suppliers, service providers, clients, public agents, shareholders and the community in general.

Its effective practice aims to enable the improvement of our corporate governance and maintains the objective of building a culture of probity and honesty, cultivated through the constant exercise of the ethical principles established herein.

This Code reflects all our Values. Values that we really believe in and by means of which we can achieve our Mission and Vision and, consequently, also reach our goals.

Our Mission | To offer cabotage shipping and port handling services that generate profitable long-term relationships and contribute to

increasing Brazil's competitiveness.

Our Vision | To be the most admired and profitable company in logistics integrated to navigation, connecting Brazil and Mercosur by sea.

Focus on results | We are proud of our growth, which leads us to always focus on actions that generate value for the company.

Security | Without security, our business cannot aim for any other goal. We take care of people, the environment and the cargo we handle.

Customer at the core | Our growth can only be achieved by being relevant to the customer. In addition to showing availability and agility when serving you, we also immerse ourselves in the demands and challenges, therefore being the agent of change.

Owner attitude | We undertake responsibilities, calculate risks, seek solutions with agility and anticipate expectations and demands.

Simplicity | Our operation is complex by nature. Internally, we focus on what matters with transparency and comprehensiveness. Externally, we are objective, constructive and consultative. Our communication prioritizes the client's outlook and understanding.

Team Spirit | We keep a spirit of collaboration at all times. If necessary, we discuss constructively. Our teams make no distinction of race, belief, gender, or origin. They are skill-based.

Our Values are the foundation of our business and we are proud to say that, above all,

we are ethical people in our personal and professional lives.

It is crucial that everyone reads, understands and replicates this Code, since these precepts are the foundation for building an increasingly prosperous LOG-IN!

Get to know, practice and disseminate our values, and ALWAYS adopt an ethical conduct! I count on the commitment of each one of you.

Kind regards,

Marcio Arany

Rules of Conduct

Introduction

How to use this code?

Read the entire Code to learn more about the expectations and ethical standards of the LOG-IN group. Its principles should guide our behavior, our decisions, as well as all other policies and normative documents of the company and its subsidiaries.

Naturally, no document can anticipate and solve all possible situations that may arise. However, we encourage a culture of openness where employees can raise genuine concerns.

We encourage all our employees to express their views, defend their opinions, and report behavior and requests that contradict this Code and which may have a suspicious or questionable motivation. In order to ensure that it really happens, we offer free access, to all employees, to the Whistleblowing Channel, through which everyone can - and should - report allegations of misconduct, fraud, embezzlement, corruption, irregularities, and any other infractions of the norms herein provided.

Any contact made with the Whistleblowing Channel shall be treated confidentially and dealt with directly by the Ethics Committee.

In order to maintain the respect and trust of the market, the internal and external customer and society in general, we must ensure that each and every day our actions reflect our Values.

We value diversity and base our relationships on honesty and integrity, with no room for discrimination

or favoritism. We do not tolerate behaviors which are inconsistent with our Values, such as:

Abusive attitudes (gestures, words and/or physical aggression) or embarrassing behavior that violates the moral and physical integrity of any person, regardless of whether they are characterized by legislation as sexual or moral harassment, as well as intimidation or threats;

Prejudiced or discriminatory behavior regarding race, color, origin, gender, personal aesthetics, physical, mental or psychic conditions, nationality, religion, sex, age, marital status, sexual orientation, social position, opinion, political option or any other act that may characterize violation of Human Rights.

Any practices of corruption, bribery, fraud, anti-competitive acts, money laundering, financing of terrorism or related acts harmful to the public or private administration, whether national or foreign.

Ethical principles in our relationships

Posture expected from employees

We foster a pleasant and favorable environment for the dissemination of our Values. We value people who are committed and make things happen. We prioritize employee development aligned with the adoption of meritocracy for all levels.

We respect and comply with the labor and social security legislation, conventions and collective agreements; tax, anti-corruption (Act 12.846/2013), antitrust (Act 12.529/2011) and prevention of money laundering (Act 9.613/98). Under no circumstances do we use child labor (under 14 years of age) or labor that bears the characteristics of slave labor.

The behavior of our team is supposed to set an example, whether in our administrative or business activities, and our employees must:

  • To comply with any applicable laws, policies and regulations;
  • To know and act in accordance with the statutes, regulations, norms, policies and procedures applicable to our business and in our respective area of activity, such as this Code for Ethical Conduct;
  • To care for the assets that are made available for the performance of our activities, using them in a correct way and aiming at the regular performance of our functions, making sure that no damage, improper handling, loss or misplacement occurs;
  • To treat the confidential information properly and only disclose or share such information with other employees, customers, suppliers or third parties that need it for the performance of their activities at LOG-IN and if authorized by the manager, regardless of the means of transmission: printed, electronic or verbal;
  • Not to make use or disclose, directly or indirectly and at any time, to anyone, any confidential information, even after termination of your employment contract;
  • To be cautious when conducting meetings or making remarks in public places (airports, cafés, lifts, restaurants, etc.);
  • To send an e-mail to the Compliance area (compliance@loginlogistica. com.br) if in doubt about what "confidential information" is;
  • To behave responsibly, conscientiously and maturely when dealing with issues that may interfere with the performance of our duties and conduct;
  • Not to play games of chance or make use of alcoholic beverages or narcotic substances within the work environment;
  • Not to work under the influence of alcohol or narcotics;
  • To be aware of situations that may constitute a conflict of interest and follow the codes set forth in this document and other policies applicable to the topic;
  • To communicate, via the Whistleblowing Channel (intranet, https://canaldedenuncia.com.br/ grupologin/, 0800-450-4503), any kind of harassment, be it sexual, moral or economic, or situations that represent pressure, intimidation
    or threats in the relationship between employees, regardless of their positions, as well as any kind of intimidation or personal embarrassment by their superiors with the purpose of obtaining personal or professional advantage;
  • To suggest, whenever deemed convenient, constructive criticism and suggestions for improvement, with the aim of improving the quality of the work;
  • To present yourself properly dressed and at the time and place established in the Employment Agreement;
  • To watch over LOG-IN's image and values, maintain a compatible posture in personal life and in the work environment, acting in defense of the interests of customers, shareholders, suppliers, employees and the community;
  • To dedicate office hours exclusively to the performance of your professional activities. Should you need to resolve personal issues, speak to your manager directly.
  • Besides the aforementioned duties, it is incumbent upon us to remind you that (i) everything created, obtained or compiled by LOG-IN, or on its behalf, including customer

lists, directories, reference files and materials, computer software, data processing systems, databases, computer programs, any content and/or educational material, belong to LOG-IN; and (ii) when invention, development, concept, idea, process or work, written or not, that may or may not be patented or have its rights reserved, developed alone or in group during your period of employment at LOG-IN, that is directly or indirectly related to the company's business, belongs to LOG-IN.

Political and religious activity

We respect the freedom of religious and political choice of our employees, customers and suppliers.

We do not tolerate any conduct that coerces, threatens, or promises benefits to make someone vote or not vote for a candidate, or any other form of electoral harassment or vote-buying; Any such practices must be communicated to our Whistleblowing Channel (intranet, https://canaldedenuncia.com.br/ grupologin/, 0800-450-4503).

It is the duty of every employee:

  • To understand that LOG-IN has an impartial posture in relation to political and religious issues and does not campaign for political parties, candidates, professional councils, or religious campaigns using directly or indirectly any LOG-IN resources;
  • Not to wear religious or political candidates' patches or buttons within the work environment or when at LOG-IN service in external diligences;
  • Not to make or promote political campaigns and ideologies within LOG-IN, even if running for political office;
  • To respect religious and political diversity;
  • To refrain from preaching or practicing acts of religious conversion within the work environment or in external service by LOG-IN.

Conducts in interpersonal relationships and conflict of interests

We encourage practices that preserve the good relationship among directors, officers and employees, maintaining effective communication to ensure a greater commitment among everyone in the exercise of their functions, aiming at the achievement of goals and the professional development and growth of all.

Any situation that involves conflict of interest must be avoided, such as relationships or operations that, effectively or potentially, characterize a circumstance of such nature.

"Conflict of interests" is the situation generated by the confrontation of personal interests, where one has an interest in the outcome of a given action contrary to the interests of LOG-IN or of the Public Administration. We must be attentive to know how to deal with these situations in an ethical and straightforward manner. To this end, LOG-IN makes the Whistleblowing Channel available, to which

communications related to this topic may be directed.

The following is the conduct required of managers and employees:

  • Not to use your position or office at LOG-IN to obtain personal favors or benefits;
  • Not to maintain your own business or activities that conflict with LOG-IN's business;
  • Not to take advantage of privileged information for the sale or purchase of any securities issued by LOG-
    IN - LOGISTICA INTERMODAL S.A., directly or through third parties and observe the restrictions on trading such securities and other codes disclosed by the Company's communication channels;
  • To prioritize the interests of LOG-IN in any situation that could lead to a real or potential personal benefit for yourself or any of your relatives or dependents;
  • To declare yourself conflicted, not to participate in meetings and not to influence any decisions in the following situations:
    • Involvement in any activity that conflicts with LOG-IN's interests;
    • In the process of hiring suppliers and employees that are closely related to you;
    • In negotiations with companies owned by relatives up to the 3rd degree, for instance: parents, children, siblings, spouses, grandparents, cousins, uncles/aunts and nephews/ nieces.
      • To respect all stages of the hiring process for employees and suppliers, as there can be no favoritism regardless of the professional level of the employee who made the referral;
  • Not to maintain a direct or indirect leadership or subordination relationship, with employees with whom a family, affective or loving relationship is established;
  • Members of the Executive Board,

Councils, Committees or Executive Managers are not allowed to indicate (former) spouses, (former) partners or relatives in a direct, collateral or affinity line, up to the 3rd degree, for hiring employees, suppliers, donations, partnerships and sponsorships.

  • It is everyone's obligation to act with transparency and impartiality, immediately communicating any situation that may configure or suggest a conflict of interest to the manager, the board, the Ethics Committee, or the Whistleblowing Channel (intranet,https:// canaldedenuncia.com.br/ grupologin/, 0800-450-4503).

Conduct in Internal Labor Relationships

FOCUS ON SECURITY

We value a safe and healthy work environment, which provides for the good development of the employees' activities, as well as the professional improvement of the teams.

Professional relations among employees, at all hierarchical levels, must be based on absolute respect for safety standards.

It is the duty of every employee to act proactively in case they observes any unsafe situation for any people that are on LOG-IN premises, immediately communicating it to the manager, to the Board of Directors, to Compliance (compliance@loginlogistica.com.br), to Legal (juridica@loginlogistica.com.br), to the Health, Safety and Environment area (ssma@loginlogistica.com.br),

to the Ethics Committee or to the Whistleblowing Channel (https:// canaldedenuncia.com.br/grupologin/, 0800-450-4503), any non-conformity

and or safety risk situation.

All employees are responsible for the preservation of the LOG-IN asset, consisting of the facilities and equipment necessary for the performance of their activity and must use them in the correct manner, exclusively for work purposes and by duly authorized persons.

Conduct in Internal Labor Relationships

THE MARITIME

There are certain situations in the onboard routine that need to be explained in this Code so that there are no doubts as to their mandatory nature, such as:

Punctuality: This is crucial not only for the safe operation of the ship but also for commercial commitments and to avoid the need for extra work. As an example, it can be mentioned, the delay in the arrival of a crewmember who went ashore and returned to take up duty at their watch may be mentioned;

The use, possession, sale or being under the influence of any illicit substance of alcohol, drugs and/or restricted use medications (psychotropic) without a doctor's prescription as well as the knowledge of the health team is strictly forbidden for any of the crew members, as well as passengers or anyone else staying on board.

Individuals authorized for boarding (crew member, visitor, third party or passengers) must be with all the certifications and documentation required by the regulatory agencies, as well as those pre-established by LOG-IN`s internal policy.

It is strictly forbidden for unauthorized individuals to board the vessel. Any person, crewmember, visitor and/or passenger wishing to enter the ship may only do so with the permission of the Master or Duty Officer;

Possession of fire guns and sharp weapons is strictly forbidden on board, except when authorized by the Company Security Officer (CSO) and provided for in the Ship Security Plan in accordance with the ISPS Code;

Smoking in prohibited areas is strictly unauthorized and dangerous on any ship, especially on ships carrying dangerous cargo;

The duties, as well as the rights of all crewmembers, are assured in the pertinent legislation, as well as in their work agreements and job descriptions;

The conservation of cabins and other areas of the ship should always be on the maritime's mind since it is not only your work place, but also your place of rest and leisure. Misuse of your cabin, which must be kept clean and tidy at all times, shall not be tolerated;

The conviviality on board must be maintained at the highest standard; therefore the use of bad language, rowdiness, partying, as well as noise and loud voices in the passageways shall not be tolerated, because working hours vary and inevitably there shall always be someone at rest.

Any attitudes or actions that may impact negatively on the environment of good coexistence on board and/or put at risk the safety on board, as well as in the operations, must be reported to the DPA "Designated Person Ashore" (dpa@loginlogistica. com.br), to the manager, to the board, to Compliance (compliance@ loginlogistica. com.br), to the area of Health (saúde. frota@loginlogistica.com.br), Safety

and Environment (ssma@loginlogistica. com.br), to the Ethics Committee, to the Whistleblowing Channel (https:// canaldedenuncia.com.br/grupologin/, 0800-450-4503), or to the Personnel area.

Conduct in customer relations

Respect for our clients is one of our strongest pillars and is even recognized as a company differential by the market. All employees should always address customers in a cordial and respectful manner, seeking to effectively understand customer needs, developing solutions that create value for both and strengthen long-term relationships.

Preferential treatments to any customers for personal reasons and that are at odds with LOG-IN's service standards should be avoided.

Any attitudes or actions that may impact the guarantee of customer satisfaction must be communicated to the manager, to the board, to the Ombudsman (ouvidoria@ loginlogistica.com.br), to the Ethics Committee and/or to the Whistleblowing Channel (intranet, https://canaldedenuncia.com.br/ grupologin/, 0800-450-4503).

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Disclaimer

Log-In Logística Intermodal SA published this content on 09 November 2023 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 14 November 2023 17:57:33 UTC.