Anti-Corruption Policy

Public Administration: should be understood in its broadest sense, encompassing all bodies of the Executive, Legislative, and Judicial Branches, autonomous government agencies, public companies, mixed-capital companies, and public foundations, whether national or foreign, including, for example, ANTAQ, INEA, the Navy, Labor Courts; (ii) companies owned or controlled by the government, including, for example, BNDES, Caixa Econômica Federal, Petrobras; (iii) international public organizations, such as Maritime and Customs Authorities of other countries or development and financing bodies. For the purposes of this policy, private companies providing public services under concession, authorization, or permission, international public organizations, and political parties are included in the concept of Public Administration. When in doubt, adopt the broadest and most conservative definition, or consult the Compliance department.

Public Official: means anyone who performs public functions, even temporarily or without remuneration, by election, appointment, designation, contracting, or any other form of investiture or engagement, mandate, position, employment, or function within direct, indirect, or foundational administration entities of any of the branches of the federal government, states, federal district, municipalities, including autonomous agencies, state-owned enterprises, mixed-capital companies, international organizations, candidates for political office at any level, members of political parties, and members of the Executive, Judicial, or Legislative Branches. Also, any individual working for a service provider company contracted or partnered to carry out activities typical of Public Administration. Examples of Public Officials include: police officers, firefighters, tax inspectors, municipal inspectors, sanitary surveillance agents, finance and urban planning secretariat employees, traffic authority employees, court officers, judicial servants, and members of the Public Prosecutor’s Office, among others. The definitions of public official set forth in Articles 327 and 337-D of the Brazilian Penal Code are additionally adopted as a reference.

For the purposes of this policy and in accordance with the Anti-Corruption Law, the delivery, offer, or promise of an Undue Advantage, as defined below, to relatives of a Public Official, such as parents, children, spouse, domestic partner, stepchildren, siblings, and nephews/nieces, or even to persons close to the Public Official, is equivalent to offering an Undue Advantage to the Public Official themselves.

Anti-Corruption Laws: a set of laws and regulations applicable to combating and repressing corruption in Brazil, in particular the Brazilian Penal Code, the Improbity Law (Law 8.429/1992), and Law 12.846, of August 1, 2013, which provides for the administrative and civil liability of legal entities for the practice of harmful acts against national or foreign public administration, and other provisions.

Employees: means directors and employees of Delta Offshore.

Conflict of Interest: means any situation representing a conflict between an Employee’s personal interests and Delta Offshore’s interests that could, in a concrete or apparent manner, improperly compromise or influence the performance of that Employee’s duties, to the detriment of Delta Offshore’s interests.

Anti-Corruption Due Diligence: Investigations and measures to assess the reputation, financial standing, history of ethical conduct, and experience of a potential partner, which will vary according to the potential risk presented by the service provider based on their activity.

Close Associates: means partners, business associates, close friends, dependents or financial guarantors, spouses, former spouses, domestic partners, former domestic partners, relatives by blood or affinity, in direct or collateral line, up to the third degree (e.g., father, mother, children, grandparents, grandchildren, nephews/nieces, cousins, aunts/uncles), and their respective spouses.

Third Parties: means representatives, suppliers, service providers, and third parties working on behalf of Delta Offshore.

Undue Advantage: means any benefit, even if non-economic, including gifts, presents, entertainment, airline tickets, accommodation, donations, sponsorships, cash amounts or equivalents (cryptocurrencies, vouchers, loyalty miles), offered, promised, or delivered to a Public Official, directly or indirectly. If offered with the aim of unduly influencing or improperly rewarding any act, decision, or omission by a Public Official, in addition to constituting a violation of this Policy, the act may constitute the crime set forth in Article 333 of the Penal Code.

Corruption: in this Policy, the term is used in a broad sense, including the crimes of active or passive Corruption proper¹, the act or attempt to use a position of power to, through abuse or deviation, obtain an advantage for oneself or for others one represents or wishes to benefit, as well as the other harmful acts listed in Article 5 of Law 12.846/2013.

Bribe: offering, giving, requesting, or receiving money, a gift, or other advantage as an inducement to perform any action, omission, influence, undue advantage, or illegal act, or a breach of trust in the performance of one’s duties. Forms of bribery may include the offering of any advantage, including but not limited to, favors, employment, internships, conveniences, donations, or favorable opportunities provided directly or indirectly to persons who may benefit Delta Offshore’s business interests.

¹Articles 333 and 311 of the Brazilian Penal Code.