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1. LETTER FROM THE CEO

Dear employee,

This code of ethics lays down the guidelines governing our conduct and should be regarded as a reference for all your professional decisions, from the routine to the most important. It applies to each and every employee, no matter their position in the Company.

As an organization, Amilpar inserts itself in the society in a straight and respectful manner, and behaves as such in all its relationships with clients, shareholders, business partners, competitors and, above all, its neighboring communities.

We are a socially responsible Company that is not only determined to achieve positive results but determined to do so in a responsible manner. Amilpar wishes to be perceived as the solid and reliable Company it is.

This code of ethics provides the guidelines for the behavior we consider to be ethically correct. These practices are coherent with our corporate policy, business strategy and conduct.

Use this document as a working tool: consult it, share it, be inspired by it.

And please bear in mind that our Company’s reputation, credibility and success is based on your character and your conduct.

Thank you,

Edson Bueno
CEO – Chief Executive Officer

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2. INTRODUCTION

Amilpar’s success depends, above all, on its employees and their professional relations with clients, suppliers, competitors, shareholders and society as a whole, based on the highest ethical standards.

We have therefore drawn up the Amilpar Code of Ethics in order to describe and reinforce the values adopted by the Company, values that should be incorporated into the day-to-day conduct of every employee.

This Code of Ethics will guide you in the performance of your corporate activities, in addition to officially enshrining the Company’s expectations regarding the conduct of each employee in every situation.

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3. OUR VISION

To be the leader in the private healthcare market, maintaining our commitment to excellence and transparency. Our objective is to create constructive relationships with clients, employees, suppliers, shareholders and the society as a whole, in the belief that ethical conduct ensures the sustainability of positive results.

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4. OUR MISSION

Promote health in a comprehensive manner, providing a large share of the population with access to high-quality medical services, as well as information and activities that contribute to improve their quality of life.

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5. CORPORATE VALUES - BELIEF SYSTEM

Health is the result of taking care of people and the focus of all our activities. We therefore strive ceaselessly to promote health, welfare and the quality of life:

• The pursuit and dissemination of knowledge are the pillars of our Company and our permanent goals;
  
• We maintain ethical and respectful relations with clients, shareholders, colleagues, competitors and surrounding communities;
  
• We are a socially responsible Company that values both positive results and the way they are achieved;
  
• Our activities and future projections are underpinned by good corporate governance practices;
  
• Friendship is a highly important aspect of our relationships, but professional conduct is above any type of favoritism;
  
• We are a medical group that believes in being ahead of our time. Quality, technology, truth, reliability, carefulness and transparency are an integral part of our DNA.

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6. PERSONAL AND PROFESSIONAL INTEGRITY

Prejudice

All employees are entitled to fair treatment from their superiors, subordinates and peers. Our priority is the respect for people. Amilpar does not accept discrimination or harassment under any circumstances. Prejudice based on religion, ethnic background, nationality, gender, age, mental or physical disability, sexual orientation or any other characteristic is strictly forbidden.

Violence in the workplace

We must preserve the physical and moral integrity of our employees. Amilpar expressly forbids any attitude leading to physical violence or offensive verbal aggression.
We have a healthy working environment based on mutual respect and the exchange of ideas and values.

Use of illicit substances

The use of alcohol and drugs (except under proven medical prescription) is forbidden in the workplace or at external events in which employees are representing the Company. The use of these substances constitutes a crime, may substantially jeopardize health and performance and put other employees and partners at risk, in addition to disturbing the workplace and causing embarrassment.

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7. CONFLICT OF INTERESTS

Commercial, financial and personal relationships

• Employees must not undertake any activity that conflicts with Amilpar‘s interests. Employees finding themselves in such a situation should withdraw from the negotiations and inform their immediate superiors at once.
  
• Employees must not use Amilpar’s information and resources for their own benefit.
  
• Employees must not benefit from their position in the Company to obtain commercial or financial advantage.
  
• All commercial transactions should be conducted solely in accordance with the Company’s pre-established interests.
  
• Employees must not use Amilpar’s name for their own benefit.
  
• In cases of direct or indirect recruiting processes involving family members of Company employees, said employees must previously inform their superiors and the HR department, given that hiring procedures must be fair and impartial for all.
  
• Employees who have relatives in the Company must not, under any circumstances, work in the same area as said relatives.
  
• Employees should avoid private commercial relationships with the Company‘s clients and suppliers, thereby preserving their impartiality.
  
• Employees must not have any type of personal, commercial or financial interest with regard to any supplier, competitor or client.
  
• Employees must not obtain any type of favor in the choice of suppliers.

Inappropriate use of Company’s assets

• Employees must not profit from opportunities for financial gain through use of the Company’s assets or information, or from their position in the Company.
  
• All employees must take care of the Company’s assets in order to avoid their inappropriate use, loss, damage, theft, etc.

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8. INFORMATION SECURITY

All employees must use the given passwords/accounts in an appropriate manner to access IT systems and equipment. The following practices are strictly forbidden:

• Installing or uninstalling IT/information systems;
  
• Making inappropriate use of the Company’s equipment and database;
  
• Using e-mail for purposes other than those in the Company‘s interest;
  
• Exchanging discriminatory or obscene messages, texts or images;
  
• Disclosing or sharing information available on the Company’s network to or with third parties;
  
• Using unofficial copies of software or programs. If the originals are not available in the Company, they should be requested and their purchase authorized by the responsible area (Ditop);
  
• Downloading files from the Internet for the employees’ own benefit;
  
• Forwarding messages with illicit content to third parties internally or externally;
  
• Register itself in personal or illicit websites, as well as websites of dubious origin, with the Company’s e-mail;
  
• Lending restricted-access passwords to other employees or third parties.

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9. CORPORATE GOODS AND SERVICES

Employees should make use of the Company’s goods and services in an appropriate manner, given that their sole purpose is to execute the Company’s tasks. The direct or indirect use of these resources for the employees’ own benefit is expressly forbidden. Employees must not:

• Make inappropriate use of resources that are for the exclusive benefit of the Company, including printed material, copies, courier services, car rentals and messengers, among other;
  
• Make inappropriate and unnecessary use of the Company’s healthcare plan or lend their (personal and non-transferable) health plan cards to third parties;
  
• Make personal long-distance telephone calls, except with prior authorization of the immediate superior;
  
• Use working tools for purposes other than those of the Company, including cars from the administrative area, taxi services with reimbursement, parking spaces for the exclusive use of registered employees, and mobile phones, except with prior authorization of the immediate superior.

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10. INAPPROPRIATE PROFESSIONAL CONDUCT

Commercial bribery

• Amilpar expressly forbids bribery under any and all circumstances.
  
• We must not accept or offer gifts, favors or money, either directly or indirectly, in order to persuade, affect or benefit third parties.
  
• Expenses with clients, including meals, transport, tickets, etc., must be previously authorized by the immediate superior. Such expenses should be considered as the normal courtesy associated with business relations.
  
• The Company recommends the non-acceptance of presents. Employees should report such gifts to their superiors for donation or forwarding to the Audit department, if appropriate. The destination of such donations should be totally transparent.
  
• Favors including trips, accommodation and air tickets must not be accepted, since they can be perceived as a form of personal inducement or the currying of favors.

Undue payments to government agencies

• All employees must abide by the law, comply with their duties and maintain good relations with public agencies.
  
• Amilpar expressly forbids any type of corruption. The reception and offer of any kind of inducement is strictly prohibited.
  
• The payment of bribes to employees of public agencies, or related parties, for the purpose of gaining an advantage for the Company, is expressly forbidden.
  
• Direct or indirect payments or gifts to any public agency or employee are strictly prohibited.
  
• The Company‘s assets or objects of value may not be directly or indirectly promised, provided, paid or transferred to any public agency or employee.

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11. CONFIDENTIAL INFORMATION

• Employees must take all necessary measures to protect the Company’s confidential information, including all unpublished information.
  
• Information related to sales, salaries, marketing, new acquisitions, strategies, new products, important contracts and financial activities are strictly confidential.
  
• The disclosure of strategic information is the sole responsibility of senior management.
  
• Employees’ personal registration details must be protected unless their disclosure is authorized by the employee in question or required by law.
  
• Employees may not use information belonging to the Company for personal purposes even if it has been prepared in the workplace by the employee itself.

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12. RELATIONSHIP WITH CUSTOMERS

We deal with life’s most precious gift – our customers‘ health. We must therefore be transparent and sympathetic at all times in order to maintain good relations and thus acquire new clients. We cannot emphasize enough that:

• Clients are our guests and must be treated with respect and cordiality at all times;
  
• No untrue statement shall be accepted in negotiations with clients. We shall maintain absolute honesty in regard to our products and services.

We must not allow our opinions or interests to conflict with those of our clients. We must be impartial in all our professional relationships.

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13. RELATIONSHIP WITH SUPPLIERS

• Supplier selection criteria must be fair and impartial.
  
• At least three suppliers must be evaluated for each solicitation.
  
• Employees’ behavior must be impartial regarding discounts or commercial inducements.
  
• Employees may not offer advantages to third parties.
  
• Habitual entertainment expenses during negotiations with third parties must be documented.
  
• Gifts from suppliers are acceptable if they bear the supplier’s logo.

“Exchanges of favors” are expressly forbidden. Employees may not receive favors, directly or indirectly, from suppliers/partners or vice versa.

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14. RELATIONSHIP WITH COMPETITORS

• Any and all violations of confidentiality related to products, services and business strategies are expressly forbidden.
  
• Comments on our competitors, as well as rumors or false information concerning them, are prohibited.
  
• Our strategies, costs, projects and differentials must not be discussed with our competitors.

Competitors shall be treated fairly, given that we expect the same treatment from them.

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15. RELATIONSHIP WITH SHAREHOLDERS

• Amilpar is concerned with the financial solidity of its shareholders‘ investments, given that it prioritizes integrity and compliance with the law.
  
• We comply with and value the best corporate governance practices, maintaining transparent relations with shareholders, market analysts, regulatory bodies, and national and international capital market entities.
  
• Amilpar is committed to the timely market disclosure of clear, accurate and complete information.

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16. RELATIONSHIP WITH THE MEDIA

• Only authorized people can speak on behalf of the Company.
  
• Any statements should be made by or with the support of the Media Relations department.

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17. ACCURACY OF THE COMPANY’S BOOKS AND RECORDS

• Is necessary to guarantee that documents are kept for the period required by law.
  
• We must ensure that documents under administrative and judicial investigation are not violated.
  
• No employee shall destroy, alter, falsify or create documents to conceal possible irregularities.
  
• Only authorized personnel shall have access to confidential documents.

We must ensure that documents are permanently updated and managed in compliance with the current legislation.

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18. SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

• We are strongly committed to social responsibility.
  
• Employees interested in participating as a volunteer in the Company‘s social projects should sign the Instrument of Volunteer Work, available at the HR department, and receive the proper training.
  
• Service providers whose conduct is inappropriate, including the use of forced or child labor, cannot be partners of the Company under any circumstances. If said conduct is verified, they shall be removed from the Company‘s list of suppliers.
  
• We value and encourage the development and sharing of knowledge.
  
• We are committed to offering high-tech medical services with a human approach.

We actively encourage corporate citizenship.

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19. FINAL CONSIDERATIONS

It is vital that every employee knows and acts in accordance with the rules defined in the Code of Ethics of Amilpar.
It is incumbent on all employees to comply with the rules herein, as well as to apply them in the execution of their daily duties.
If employees fail to comply with these rules, Amilpar may, at its discretion, apply the relevant disciplinary measures.

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