Code of Conduct and Ethics

Introduction                               

Real Marine & Offshore (RMO) considers it essential that all employees and contractors understand and comply with these rules of conduct and ethics. Therefore, RMO has adopted this Code of Conduct and Ethics as a guideline for professional activities, regardless of job title, responsibilities, or tasks, and expects the highest standards of honesty, respect, and personal integrity when dealing with clients, colleagues, competitors, technical partners, suppliers, government authorities, and, more broadly, the community.

All Employees and Contractors Must

• Act with honesty, integrity, and respect toward others.
• Understand the risks associated with their role and how to manage them.
• Seek guidance from leadership when uncertain about any situation.
• Report any suspected violation of this Code.
• Comply with the laws, rules, and procedures of RMO, as well as those of clients, suppliers, partners, and government entities.
• Treat colleagues with respect in the workplace.
• Recognize the value of diversity and not discriminate based on race, color, religion, age, sexual orientation, gender, marital status, disability, ethnicity, or nationality.
• Continuously contribute to reducing environmental impact and improving occupational health and safety outcomes by applying RMO’s control measures.
• Help prevent or minimize strategic and operational risks by implementing internal controls adopted by RMO.
• Work with transparency, ethics, and respect in all professional settings, both on and off the job.
• Act with integrity, seriousness, and honesty in interactions with suppliers, clients, authorities, and colleagues, maintaining discipline and respecting established hierarchies and authorities.
• Protect the company’s assets, image, and intellectual property—whether electronic, physical, or digital—as well as those of its clients.
• Not share, disseminate, or distribute any information, reports, ideas, or internal policies of the company or its clients with external audiences, market competitors, private entities, public authorities, or individuals or organizations that may benefit from such information.
• Safeguard the company’s image at all times, ensuring it is not associated with any illegal or improper actions, in accordance with applicable laws.
• Understand that no company or client information—whether commercial, financial, or intellectual property—may be taken or shared in the event of contract termination or cancellation.
• Refrain from engaging in any commercial transaction directly with clients or suppliers of the company, whether inside or outside the scope of their employment contract.

Senior Management and Leaders Must

• Ensure that all employees and technical consultants under their supervision are aware of and comply with the Code of Conduct and Ethics.
• Foster an excellent work environment and uphold RMO’s reputation among employees, consultants, clients, suppliers, partners, and government bodies.

RMO’s Interactions with Clients, Suppliers, Partners, and Government Entities

• Build transparent and trustworthy relationships.
• Prevent corrupt behavior and illegal practices.
• Continuously identify and avoid potential conflicts of interest.
• Commit to transparent communication during any investigations or audits by public entities, agencies, or officials.
• Promote the importance of sustainability and environmental preservation.
• Refrain from funding, supporting, or in any way sponsoring illegal acts.
• Reject all forms of fraud and corruption, including bribery, money laundering, or insider trading.
• Consult company management before accepting any prize or reward obtained in the workplace.
• Implement actions to ensure the respect of human rights.

Harassment Prevention and Secure Reporting Channels

RMO strictly opposes all forms of harassment—including moral, sexual, psychological, physical, or virtual—within the workplace or in any interaction arising from professional activities.

Commitment to a Respectful Work Environment

RMO is committed to maintaining a healthy, respectful, inclusive, and safe professional environment where all employees and contractors can carry out their duties with dignity. The following behaviors are unacceptable:

• Offensive, humiliating, or inappropriate verbal conduct.
• Jokes or comments with sexual or discriminatory content.
• Unwelcome physical contact.
• Threats, intimidation, or undue pressure related to performance, promotion, or dismissal.
• Repeated behaviors intended to emotionally destabilize a colleague or contractor.

Responsibilities of Employees and Leaders

All employees and contractors must:

• Uphold mutual respect and integrity in the workplace.
• Actively reject all forms of harassment or abusive behavior.
• Promptly report any inappropriate conduct they experience or witness.

Leaders and managers have the additional responsibility to:

• Promote a harassment-free environment within their teams.
• Handle all reports with seriousness, impartiality, and confidentiality.
• Forward reports to the appropriate internal channels, following company guidelines.

Confidential and Secure Reporting Channels

RMO provides formal, confidential, and secure reporting channels so that any employee or contractor can report, in good faith, situations involving harassment or inappropriate behavior:

• Reporting Channel: contact@rmo-eng.com.br
• HR and Legal Departments: available for support and assistance.

Reports may be submitted anonymously or with identification. The company guarantees that no form of retaliation will be tolerated against individuals who report misconduct responsibly.

Commitments to Human Rights and Social Responsibility

Prevention of Conditions Analogous to Slavery

RMO vehemently rejects any form of labor analogous to slavery, including exhausting work hours, degrading conditions, debt bondage, forced labor, or any restriction of movement by any means.

All employees, contractors, suppliers, and partners must:

• Ensure dignified working conditions.
• Fully comply with labor laws and health and safety regulations.
• Immediately report any suspected violations of workers’ fundamental rights.

Guarantee of Freedom of Association and Collective Bargaining

RMO recognizes and respects the right of employees to:

• Freely organize in unions or other forms of representation.
• Participate in collective bargaining to defend their professional interests.
• Not suffer retaliation or discrimination for exercising these rights.

The company maintains open and respectful channels of dialogue with union representatives, valuing the collective construction of solutions.

Eradication of Child Labor and Sexual Exploitation of Children and Adolescents

The use of child labor is strictly prohibited in any instance, except in cases permitted by law (such as young apprenticeships, with appropriate age and conditions).

Furthermore:

• RMO condemns any form of sexual exploitation of children and adolescents.
• It is committed to adopting preventive and educational measures to protect this vulnerable group.
• It reinforces the obligation to report immediately to the appropriate authorities in the event of any indication or suspicion.

Combating Moral or Sexual Harassment and All Forms of Discrimination

RMO reaffirms its stance against any form of harassment or discrimination by promoting actions such as:

• Regular training on ethical conduct and respect for differences.
• Periodic review of reporting channels to ensure accessibility and effectiveness.
• Psychological and legal support for victims who choose internal assistance.

Promotion of Diversity, Equity, and Inclusion (DE&I)

RMO values plurality and believes that diverse teams are more innovative and effective. Therefore, it is committed to:

• Promoting actions that ensure equal opportunities, respecting different backgrounds, identities, disabilities, and worldviews.
• Including criteria in recruitment processes that encourage representation of underrepresented groups.
• Fostering an environment that respects differences and challenges stigma or prejudice.

Consequences

All reports will be investigated thoroughly, and appropriate disciplinary measures will be applied in accordance with applicable legislation and RMO’s internal policies. These measures may include warnings, suspension, termination of employment or contract, and legal actions, depending on the severity of the case.

Revision

RMO will regularly review the Code of Conduct and Ethics to ensure that the company’s business is conducted with integrity, ethics, and appropriateness, safeguarding the company’s interests and maintaining a harmonious and ethical work environment for all employees and contractors. The first version of this Code will be sent, and a signature will be requested to confirm acknowledgment. Subsequent revisions will be sent for informational purposes only and will not require the signed return of the document by the recipient.