CODE OF CONDUCT AND ETHICS

1. PREAMBLE:

GM DOS REIS INDÚSTRIA E COMÉRCIO LTDA is a company dedicated to research, development and manufacture of products for orthopedic, spine and maxillofacial surgery.

We place high demands on ourselves to work in a way that guarantees social, economic and ecological sustainability in harmony with our corporate mission and principles for customer satisfaction, profitability and environmental protection. Furthermore, we see sustainability as a responsible attitude for building the future.

Demonstrating fair behavior, GMReis employees play a crucial role the company’s success; it is this attitude that forms the basis for joint innovation and long-term value creation. Our highest priority is the close collaboration of our employees, based on mutual trust.

The purpose of the Code of Conduct and Ethics is to set standards minimum ethical conduct of the company, aiming to guide the company’s activities within the law and in compliance with technical, moral and ethical standards.

Therefore, we expect our employees to accept responsibility and comply with the rules defined in this Code of Conduct when doing business representing the company GM DOS REIS INDÚSTRIA E COMÉRCIO LTDA.

2. STRUCTURAL CONDITIONS:

The principles of the GMReis Code of Conduct are applicable to all company employees, and determine a uniform business standard, defining the general framework and fundamental principles of the company’s activity.

2.1 LEGISLATION:

GMReis will follow the laws and regulations applicable in the country, and, in the situation where the legislation is omissive, it will apply its own cultural standards and values, so as not to leave any gap of understanding.

2.2 ELECTORAL DONATION:

GMReis opts for neutrality when it comes to political parties and candidates. Neither the name nor the company’s resources will be used to promote the interests of political parties or candidates.

2.3 ETHICAL STANDARDS:

GMReis is committed to ethical standards in conducting its business. Thus, the company does not admit the practice of corruption with public entities, which is why it cannot offer government officials, public officials, or any representatives of the public administration a reward or advantage for violating the applicable legislation.

2.4 CONFLICT OF INTERESTS:

GMReis policy regarding possible conflicts of interest is based on the principle that the employee should make decisions and act appropriately, without being influenced by private, family or friend issues that may, consciously or unconsciously, affect his judgment in relation to the activities in which he is personally involved, lead him to promote favors or to act against the interests of GM Reis.

2.5 RELATIONSHIP WITH COMPETITORS:

GMReis relations are conducted in an ethical, respectful and professional manner, and any unfair competition is prohibited or anti-competitive.

2.6 HUMAN RIGHTS:

Within the scope of GMReis, it supports and respects the international proclamation of protection of human rights, not committing to cases that may harm those rights.

2.6.1. Non-Discrimination:

GMReis remunerates and treats its employees in a non-discriminatory manner with respect to gender, race , religion, age, physical disabilities, sexual orientation, nationality, political opinion, union membership, ethnic or social origin.

2.6.2. Work:

No form of forced or child labor at GMReis will be tolerated.

2.6.3: Work Environment:

The working environment must be safe and healthy, guaranteeing the physical, mental and psychological integrity of all GMReis employees and business partners. Relationships between people should be based on dialogue and mutual respect at all levels. In addition, employees and collaborators must treat colleagues with courtesy and respect, always exercising constructive feedback, while maintaining a clean and organized work environment, thus promoting positive attitudes, aiming at maintaining an ethical posture that respects and disseminates the essential principles from GM Reis: Quality, Safety and Technological Innovation.

2.7 CONTINUING EDUCATION:

GM REIS provides its employees and customers, continuing technical education, with the aim of bringing safety and efficiency to the procedures carried out with its products, thus avoiding the abuse of procedural indications or even the unnecessary indication, both qualitatively and quantitatively.

2.8 RESPECT FOR THE ENVIRONMENT:

GMReis encourages its employees to comply with the legislation applicable to the environment, through simple measures that avoid the incorrect disposal of waste, as well as expanding the adoption of measures to reduce the consumption of electricity and drinking water, thus avoiding waste in favor of the environment.

2.9 OF THE PRODUCT:

All GMReis manufacturing products are developed and manufactured within internationally established quality standards, as well as obey the regulations and are certified by ANVISA, enjoying excellence, safety and efficiency for their use.

2.10 CONFIDENTIALITY:

All information acquired due to the link with GMReis must be treated confidentially, not thus, they should be passed on to third parties without prior authorization from a senior professional.

2.11 COMMUNICATION CHANNEL:

Any attitude practiced by a professional linked to GMReis contrary to this Code of Ethics and Conduct should be immediately reported to the company through the channel: [email protected]

Kind regards,

Geraldo Marins dos Reis Junior

CEO