Corporate Governance Policy – Copastur

 

1. INTRODUCTION

The Corporate Governance of Copastur Viagens e Turismo and G8 Special Travel Services seeks to promote the sustainability and longevity of the organization, based on transparent, responsible, and ethical relationships with all stakeholders. This policy institutionalizes practices that ensure balanced decision making, compliance with legal obligations, and the generation of sustainable value for stakeholders.

2. DEFINITIONS AND CONCEPTS

Corporate Governance

System by which Copastur and G8 are directed, monitored, and encouraged, involving practices and relationships among shareholders, managers, employees, and stakeholders, based on the principles of transparency, fairness, accountability, and corporate responsibility.

Corporate Responsibility

Copastur and G8’s commitment to conducting business ethically, considering the social, environmental, economic, and legal impacts of their activities.

Top Management

Represented by the President and CEO, with the highest authority to define strategies, approve policies, and ensure compliance with governance and compliance guidelines.

Senior Leadership

Comprises all professionals who report directly to the CEO, responsible for leading teams and implementing the organization’s strategic guidelines.

Middle Management

Composed of professionals who report to Senior Leadership and are responsible for the tactical execution of established guidelines.

Stakeholders

Individuals or organizations that impact or are impacted by Copastur and G8’s decisions or activities, such as employees, clients, suppliers, regulators, the community, among others.

3. PURPOSE

To establish Corporate Governance guidelines applicable to Copastur and G8, with the purpose of:

  • Transparency and stakeholder engagement;
  • Clarity of roles and responsibilities at strategic, tactical, and operational levels;
  • Promotion of sustainability, integrity, and legal compliance;
  • Structuring decision-making processes with delegation of authority and segregation of duties;
  • Ensuring accurate and timely communication;
  • Respect for stakeholders’ rights;
  • Strengthening of ethical culture and social and environmental responsibility.

4. SCOPE

This policy applies to Top Management, leadership, employees, committees, suppliers, partners, and third parties acting on behalf of or for the benefit of Copastur and G8.

5. PRINCIPLES OF GOVERNANCE

Copastur and G8 guide their actions by the following principles:

  • Transparency: Clear, accurate, and timely accountability regarding business conduct;
  • Fairness: Equal and fair treatment of stakeholders, respecting their rights and duties;
  • Corporate Responsibility: Commitment to sustainable development, including environmental, social, and governance (ESG) aspects;
  • Accountability: Governance agents’ responsibility for their decisions and conduct;
  • Ethics and Integrity: Conduct based on high ethical standards and zero tolerance for corruption;
  • Security and Privacy: Protection of personal data and confidentiality of corporate information.

 6. GOVERNANCE STRUCTURE

The governance structure of Copastur and G8 includes the following bodies and functions:

  • Top Management: Responsible for defining strategies, supervising results, and promoting organizational culture.
  • Corporate Committees (Sustainability, 5S, Health and Well-being, Ethics, Diversity & Inclusion, Approvals – People & Culture, Information Security & Data Privacy, among others): Technical advisory bodies that support decision-making, composed of representatives from key areas.
  • Senior Leadership: Responsible for implementing strategic objectives and ensuring execution of guidelines.
  • Middle Management: Responsible for the tactical execution of established guidelines.
  • Support Areas (People & Culture, Compliance, Legal, Information Security): Provide technical and regulatory support, ensuring compliance.

7. GENERAL GUIDELINES

  • Collegiate Decisions: Strategic matters must be analyzed in committees or formal meetings, ensuring plurality of views and risk mitigation.
  • Segregation of Duties: Critical activities must be separated to avoid conflicts of interest.
  • Risk Management: Corporate risks must be continuously identified, assessed, treated, and monitored. At Copastur and G8, risk management is guided by a corporate risk matrix that serves as a reference for analysis and prioritization, carried out in a decentralized manner by the areas. Tools such as SWOT and other specific analyses may be used depending on the nature and complexity of the risks involved.
  • Compliance: The Compliance area acts as the second line of defense, promoting adherence to laws and internal policies.

8. STAKEHOLDER RELATIONSHIP

Copastur and G8 respect and value their stakeholders. Relationship guidelines include:

  • Transparent, responsible, and timely communication.
  • Active listening and participation in multi-sector forums.
  • Commitment to the rights of personal data subjects, in accordance with LGPD.
  • Social and environmental responsibility in business decisions.

9. CORPORATE CODE OF ETHICS AND CONDUCT

Consolidates the values and standards of conduct of Copastur and is mandatory for all. Non-compliance may result in disciplinary measures, in accordance with internal regulations.

10. PILLARS OF THE COMPLIANCE PROGRAM

The Compliance Program of Copastur and G8 is structured on pillars recognized nationally and internationally, in accordance with current legislation, OECD guidelines, and best practices in corporate governance.

11. CORPORATE POLICIES

Policies are complementary normative instruments to the Corporate Code of Ethics and Conduct. They must be drafted with the support of the Compliance area, approved by leadership, and clearly communicated to all employees.

12. COMMITMENT OF TOP MANAGEMENT

Top Management sponsors the Governance and Compliance Program, defines priorities, approves policies, and monitors results, demonstrating commitment to ethics and business sustainability.

13. DISCIPLINARY MEASURES

Violation of internal policies subjects the offender to disciplinary sanctions, in accordance with Copastur’s Code of Ethics and applicable legislation, without prejudice to any applicable legal actions.

14. PRIVACY AND DATA PROTECTION (LGPD)

Copastur and G8 adopt solid governance practices in data protection. The Data Protection Officer (DPO), linked to Information Technology / Information Security, coordinates the privacy program in compliance with the LGPD.

15. PREVENTION AND FIGHT AGAINST CORRUPTION

The Anti-Corruption Policy of Copastur and G8 establishes guidelines to prevent, detect, and combat illicit acts. It applies to all employees, suppliers, and third parties acting on behalf of the company.

16. SOCIAL AND ENVIRONMENTAL

Copastur and G8 adopt actions to reduce environmental impacts, value the conscious use of resources, and encourage citizenship and respect for future generations. Sustainability is promoted as an institutional value.

17. ETHICS CHANNEL

Copastur and G8 maintain an ethics channel available to the internal public, ensuring confidentiality and impartial handling of reports. Responsible use of the channel reinforces an environment of trust and integrity.

18. CORPORATE EDUCATION AND TRAINING

Copastur and G8 promote continuous training on ethics, governance, compliance, and data protection, strengthening organizational culture and the effectiveness of controls.

19. FINAL PROVISIONS

This Policy will be reviewed every two years or whenever there are significant changes in the company’s structure, applicable legislation, or governance best practices. The current version will be made available through Copastur’s official channels.