Ethics and Conduct

3. CONDUCT GUIDELINES

a) The following guidelines are mutual commitments established between the Company and its Employees, and aim to guide professional practices or clarify situations that may generate conflicts in Channel's internal and external relations.
b) The selected themes, which certainly do not exhaust all situations, were considered priorities for inclusion in the Company's Code of Ethics and Business Conduct, in order to contribute to its ethical and sustainable management.

3.1. Discriminatory actions
3.1.1. The following practices are not tolerated by any Channel employee:
a) Any conduct that can be characterized as discriminatory based on race, nationality, color, gender, sexual orientation, language, special needs, religious belief or political conviction, social origin, or any other condition;
b) Any conduct that can be characterized as moral or sexual harassment, offense, hostility, exposure to ridicule, intimidation, or humiliation;
c) To carry out any type of political propaganda or religious demonstration, on or off Channel premises, in the name of the Company.

3.2. Use of alcohol, drugs and weapons
a) Channel does not allow entry, possession, consumption, or remaining under the influence of alcoholic beverages or illicit drugs, on its premises or outside in the name of the Company.
b) The use of cigarettes or similar products, including electronic ones, is not recommended and is prohibited in the company's covered areas, in accordance with the law.
c) The carrying and storage of weapons is not permitted on Company premises, except for legally qualified professionals expressly authorized by management.

3.3. Relationships with business partners
3.3.1. All relationships with Channel's business partners, such as Clients, Suppliers and Service Providers, must be based on technical and transparent criteria, conducted ethically and respectfully, promoting a lasting and trusting relationship, and acting in accordance with corporate objectives.
3.3.2. Employees who have a family relationship or personal interest with any Channel business partner may not participate in any Company decision, nor use the prerogatives of their position or power of influence in conducting matters related to that partner.
3.3.3. The use of Channel's name to purchase goods, contract services, obtain loans, whether for personal use or for third parties, or to benefit from credit or special discounts granted to the Company, will be considered to be in conflict with Channel's interests.
3.3.4. Receiving benefits such as payments, gifts, loans, entertainment, travel, employment for relatives, and favors of any kind from individuals or legal entities that are current or potential business partners of the Company will be considered conflicting with Channel's interests.
3.3.5. Employees acting on behalf of Channel (“Internal Employees”) who have any type of relationship, including kinship, with persons commercially linked to Channel, whether Suppliers, Investors or Partners, must inform the Company, through Internal Audit, and declare such relationship, provided that such Internal Employees have the power of influence as a result of their activities at the Company.

3.4. Receiving/offering gifts
3.4.1. The practice of exchanging gifts, services, and presents should be conducted with caution and transparency, so as not to influence or appear to influence business decisions.
3.4.2. The receipt or offering, by an internal employee and persons related to them, of non-monetary gifts with a market value equivalent to up to 20% (twenty percent) of the current federal minimum wage, in each calendar year, will not be considered a conflict of interest.
3.4.2.1. Gifts, services, or presents exceeding this value must be returned or, if this is not possible, forwarded to the Human Resources Manager, who will determine their final destination.

3.5. Fraud, bribery and corruption
3.5.1. Channel has an Anti-Corruption and Anti-Bribery Policy and repudiates in all forms any attempt or suspicion of corruption, bribery, kickbacks, improper privileges or benefits, undue donations or payments, and influence peddling, and adopts the measures provided for in the Integrity Program (Compliance) and in the related internal policies of Channel, its clients and partners.
Do not tolerate any situation contrary to Gerdau's Code of Ethics and Conduct. Be responsible for all your actions and act guided by the principles and this Code of Ethics and Conduct. Act with integrity, honesty, and professionalism. Know and comply with the other Policies and Guidelines of Channel and its clients and partners. Report any doubts or situations that may represent or be interpreted as contrary to the law and/or the Code of Ethics and Conduct. ALWAYS DO THE RIGHT THING.

3.6. Relations with government authorities and agencies
3.6.1. The relationship with an authority or employee of the direct or indirect public administration is foreseen in the Company's Policy to Combat Corruption and Bribery, mentioned in item 3.5.

3.7. Relations with Shareholders and Investors
3.7.1. The Company's relationship with its shareholders and investors must be based on accurate, transparent, equitable, and timely communication of relevant information, enabling them to monitor the Company's activities and performance, in accordance with applicable legal procedures.
3.7.2. Relationships with shareholders and investors may only be conducted through the Investor Relations Director and/or the CEO and, in specific situations, by duly authorized Internal Employees, in accordance with the Company's policies, controls and procedures.

3.8. Media relations
3.8.1. The Company's relationship with media outlets must be conducted only by authorized internal employees, respecting the limits of the Company's Disclosure Policy, available on our website.
3.8.2. Information that may be of particular interest to shareholders may only be disclosed to the market by the Investor Relations Officer and/or the Chief Executive Officer.

3.9. Social responsibility
3.9.1. It is Channel's principle to act with social responsibility towards the communities in which it operates, and its employees must establish good relationships, respecting the interests of these communities and the country, contributing to their development.
3.9.2. Channel complies with labor laws in all countries and regions in which it operates, supporting fundamental human rights for all peoples.
3.9.3. Channel condemns all forms of child labor, slavery, as well as human trafficking and commercial exploitation, including the sexual exploitation of men, women and children, and is fully committed in all markets in which it operates to protecting individuals from all forms of abuse and exploitation.

3.10. Environment
3.10.1. Employees, in the performance of their duties, must be committed to preserving the environment and adopting actions that seek to improve the quality of human life.
3.10.2. All Channel's business dealings must be conducted in full compliance with environmental legislation, with a focus on improving its operational processes, within the concept of sustainable development.

3.11. Health and safety
3.11.1. Channel prioritizes occupational health and safety in its activities and work relationships. Employees must respect the health and safety policies and standards specific to each area and function, including respecting the rules and guidelines within the companies and partner organizations where we operate.
3.11.2. Internal employees who identify any situation that threatens their physical integrity, that of colleagues, or that of third parties in the workplace must immediately notify their manager and the Occupational Safety area, where applicable.

3.12. Freedom of association
3.12.1. Channel recognizes and respects the right to freedom of association, including in trade unions, associations, professional bodies, political parties or any other constituted entities, provided that it is exercised responsibly and ethically, within legal limits.

3.13. Use of assets
3.13.1. The Employee is responsible for the preservation and care in handling the resources and assets of the Company and partner companies, whether financial, material or intellectual, including furniture, equipment or infrastructure, and must ensure the cleanliness and organization of their workplace and the conservation of the materials and resources made available for the execution of their activities, avoiding waste and unnecessary expenses.
3.13.2. The assets may not be used to obtain personal advantages nor provided to third parties for any purpose, except as stipulated in contracts entered into in accordance with internal regulations.

3.14. Use of information/confidentiality
3.14.1. Consultants and/or collaborators must, in their actions within and outside the corporate environment, protect the intellectual property of the Company and its clients and partners, which includes its trademarks, patents, other intangible assets, technology, and other information. Therefore, they may not misuse or disclose to third parties any information considered confidential by the Company, including, but not limited to, administrative procedures, information about internal employees, suppliers and clients, including inactive ones, engineering projects, commercial and financial information, corporate acts, contracts, processes, and other information designated as "confidential," using them solely for the purpose of assisting Channel in the performance of its activities. Exceptionally, such information may be disclosed with the express authorization of the Board of Directors, in accordance with the Articles of Association.
3.14.2. Employees who possess information that is not publicly known (insider information) and that could influence the value of the Company's shares may not buy or sell such shares and must comply with the Company's Trading Policy.

3.15. Parallel activities
3.15.1. Channel consultants and collaborators are prohibited from engaging in professional activities outside of their employment contract with the Company, whether remunerated or not, in situations of conflict of interest, such as those that:
a) compete, directly or indirectly, with the activities or interests of Channel and its partners;
b) have any relationship with current or potential business partners;
d) hinder the efficient performance of their activities at Channel, clients and partners; and
(e) contravene the provisions of this Code.

3.16. Activities unrelated to the Company's interests and business.
3.16.1. Consultants and collaborators are prohibited from engaging in activities unrelated to the interests and business of Channel and its clients and business partners, whether remunerated or not, on its premises, such as:
a) sale, advertising and promotion of products, services and activities of a commercial, religious, political, or class nature, holding raffles and engaging in games of chance in general;
b) circulation of lists or sale of raffle tickets for fundraising for any purpose, except with the approval of the Human Resources Department Manager;
c) Posting or distributing posters and/or written communications unrelated to the Company's business, except with the approval of the Human Resources Department Manager;
d) the circulation of petitions for any purpose;
(e) using the Company's address for receiving personal mail.

3.17. Relatives/romantic relationships
3.17.1. Internal employees are prohibited from having family members work in a position of direct or indirect reporting to them in the same department.
3.17.2. For the purposes of this Code, the following are considered family members: spouse, partner, boyfriend/girlfriend, father, mother, stepfather, stepmother, son/daughter, stepson/stepdaughter, father-in-law/mother-in-law, son-in-law, daughter-in-law, brother/sister, brother-in-law/sister-in-law, grandfather/grandmother, grandson/granddaughter, uncle/aunt, nephew/niece, father-in-law/mother-in-law of brother/sister, cousin, among others.
3.17.3. Employees are prohibited from influencing or participating in recruitment and selection, promotion, evaluation, and transfer decisions involving a family member.

3.18. Potentially conflicting situations
3.18.1. Any and all personal situations, whether existing or intended to develop, that could potentially be characterized as a conflict of interest for Channel, its clients, and partners, must be disclosed to Channel by the Employee.
3.18.2. The Company, through Internal Audit, will give the matter the appropriate treatment.
3.18.3. In the event of a potential conflict of interest, the potentially conflicted employee may not be involved in handling the matter, noting that if they are an Administrator or a member of a Committee, they must refrain from deciding on the matter.