Alpargatas S A : 12/22/2022 - Sponsorship Policy

SPONSORSHIP POLICY

1. OBJECTIVE
   This Policy establishes the rules to guide the decision process of Alpargatas S.A. ("Alpargatas" or "Company") when choosing partners to receive institutional support in the form of a Sponsorship. This Policy also describes what is expected of employees, company executives, partners, Sponsored Parties, and third parties who act on behalf of the Company.
2. SCOPE

GLOBAL

3. DEFINITIONS

Sponsorship: The financial support granted to projects conducted by third parties in order to promote cultural, sports, and social initiatives while, in return, raising awareness about the Company's operations. Sponsorship seeks to strengthen the Company's position, add value to the brand, boost sales, or foster brand awareness and a closer relationship with the Company's target audiences.

Sponsored Party: Individual or legal entity whose Project has been approved and who has been granted the Sponsorship.

Project: Detailed description of all the actions to be undertaken, including their start and end dates. To be awarded a Sponsorship, the Project must comply with Alpargatas' requirements and guidelines, as well as the terms and conditions herein described.

Applicant: Individual or legal entity who submits a Project for approval to receive a Sponsorship.

Area Assigned to a Project: refers to the Alpargatas' department that receives the Project submitted by an Applicant and carries out all the appropriate steps to approve and manage it.

Public Official: every natural person who exercises, even if temporarily, with or without remuneration, by election, appointment, designation, hiring or any other way of incumbency or relationship, a term of office, position, job, or function in governmental agencies and companies that are part of the direct and indirect government, including regulatory agencies, legislative, executive, or judicial authorities, in any country.

4. GUIDELINES

Alpargatas sponsors different entities and Projects in an effort to promote and strengthen its brand, as well as to improve communication with customers, suppliers, and the broader society. With this Policy, the Company intends to ensure high standards of transparency, integrity, and legality when granting Sponsorships.

1. ALPARGATAS' REQUIREMENTS TO SPONSOR PROJECTS

Alpargatas shall only sponsor Projects that fulfill one or more of the criteria below:

1. Can potentially generate positive publicity for Alpargatas, its brands, and its image through actions that boost brand recognition and/or add new dimensions to the brand;
2. Can improve, strengthen, and establish new relationships with strategic audiences;
3. Promote health, wellness, and quality of life;
4. Help develop the people, education, culture, and self-esteem of the targeted community;
5. Promote gender equality and ethnic and cultural diversity;

Internal Use Only

SPONSORSHIP POLICY

1. Champion the collective interests of the targeted community.

The Company shall only grant Sponsorships to Applicants and Sponsored Parties who have proved to be legit and reputable.

1. PROJECT PRE-SELECTION

Project selection shall prioritize Applicants and Sponsored Parties that are ethical and whose reputation in the market is compatible with that of Alpargatas, in order to protect and improve the Company's own reputation, corporate image, and social benefit.

The Area Assigned to a Project must share the information sent by Applicants and Sponsored Parties with the Compliance team, which will run a Background Check before the Project can be chosen. All Applicants and Sponsored Parties shall go through the approval process conducted by the Compliance team to ensure that no Sponsorship is used for illegal or illicit activities.

Before any decision is made about a Sponsorship, the Compliance team must also be requested to run a veracity check that states that the Project is genuine, and to guarantee that the Sponsorship does not violate any of the terms in this Policy and in Alpargatas' Code of Conduct and Ethics.

Whenever a Sponsorship is associated with a Project that meets the criteria of the Brazilian Rouanet Law (or any equivalent legislation that succeeds it) or any other tax incentive legislation, the Project shall only be selected after approval by the Commission on Cultural and Sports Incentives, whose members must include a representative of the Legal Tax team, a representative of the Tax area, a representative of the Communications area, a representative of the Sustainability area, and a representative of the BMU assigned to that Project. This Commission shall meet whenever there is fiscal room to allocate funds to Projects eligible for such incentives.

At the beginning of each year, the Strategy Committee must receive a report with all the Sponsorships associated with Projects eligible for fiscal incentives, such as the Brazilian Rouanet Law (or any equivalent legislation that succeeds it), or any other tax incentive legislation, approved in the previous year. Alpargatas' Tax area shall be responsible for sharing the summary of these allocations with the Company's CEO at the beginning of each year.

1. PROJECT REVIEW AND APPROVAL

After the pre-selection process, the Area Assigned to the Project shall confirm whether the Project proposals meet all the requirements herein described, including the description of specific objectives and goals. After this step, all proposals, regardless of their value and nature, shall be submitted for prior approval, as established in the Approval Policy.

Sponsorship agreements with terms longer than 1 (one) year and outstanding payments must also renew their annual approval process. If any non-compliance or new risk is identified, the Project will be sent for renewed appreciation and approval, as established in this Policy and in the Approval Policy.

1. BANNED SPONSORSHIPS

Alpargatas shall not sponsor Projects that are:

1. Not aligned with the Company's values;
2. Considered offensive and/or vulgar;
3. Political or religious in nature;
4. Developed by or associated with Public Officials, government agencies or entities, or any relatives of Public Officials by consanguinity or affinity up to the second degree;

Internal Use Only

SPONSORSHIP POLICY

1. Developed by individuals who may potentially influence decisions that impact the Company's interests as a way to unfairly facilitate business, omit actions, or secure undue advantages to the Company, such as in the case of authorizations, licenses, permits, and certificates;
2. Encourage the use of drugs and/or violence;
3. Associated with gambling or speculation;
4. Involve child labor, poor working conditions, or modern slavery;
5. Potentially harm the minorities rights;
6. Physically abuse animals;
7. Go against legal, regulatory, and constitutional dispositions;
8. Submitted by Applicants rejected by the Compliance team;
9. Submitted by Applicants already responsible for other projects whose accountability reports are past due or contain pending issues with a Culture Department; or
10. Submitted by Applicants who have outstanding debts with the Company or who are in an irregular situation.

e. RULES FOR TICKET GIFTING AND INVITATIONS

Tickets and invitations to events sponsored by the Company shall only be extended to others provided all ethical principles described in Alpargatas' various internal policies are observed, notably those described in the Company's Code of Conduct and Ethics and Anti-corruptionPolicy. It must also respect the good faith of the parties involved, as well as the following rules:

1. The area that offers the ticket/extends the invitation must feel comfortable in publicly justifying the attendance of said guest in the event;
2. Tickets and invitations shall not be offered to the same guest in an unreasonable frequency that may raise suspicions of an exchange of undue advantages;
3. Tickets and invitations shall only be offered in the absence of any relevant ongoing negotiations that impact the Company's interests and in which the guest has decision-making powers, or direct or indirect influence;
4. Tickets and invitations to events sponsored by the Company shall not be offered to Public Officials or their direct relatives by consanguinity or affinity up to the second degree unless the event is merely institutional or protocol, tickets are not for sale, and the invitation has been approved by the Ethics & Compliance Committee.

1. AGREEMENTS AND DOCUMENT ARCHIVES

All Sponsorships require Alpargatas and the Sponsored Party to sign an agreement that describes the rights and obligations of both parties, as well as payment conditions. The agreement must follow the Company's standards and contain all the minimum requirements listed by Alpargatas' Legal Department.

All the documentation and proof of Sponsorship connected to this process, such as review, approval, accountability reports (including the Project Execution Report), and signed agreement must be archived by the Area Assigned to the Project, even if it does not involve financial resources.

1. PAYMENTS AND ACCOUNTABILITY

After all the relevant documentation is produced and the Project is approved, the budgeted financial resources shall be transferred by Alpargatas to the Sponsored Party in a previously established bank account linked to the selected Project.

Accountability involves producing proof that the budgeted and approved resources have been employed as expected.

Internal Use Only

SPONSORSHIP POLICY

The Area Assigned to the Project shall be responsible for requesting and archiving the Project Execution Report and all additional documentation that serves as proof that the Projected has been physically executed and that the funds have been used as expected and planned.

Examples of documentation that may be used as proof that the Project has been physically executed are: audiovisual materials, descriptive reports, statements, attendance lists, publications in the media/press, promotion material about the event, or any other type of material that makes it possible to verify that the actions proposed by the Sponsored Party have been executed.

The Area Assigned to the Project shall also be responsible for producing an Image Report listing the tangible and intangible benefits derived from the Sponsorship.

When the Sponsorship is associated with a Project that is eligible for tax incentives, such as the Brazilian Rouanet Law and other tax incentive legislation (or any equivalent legislation that succeeds it), all the documentation pertaining to the transfer of funds must be shared with the Tax area and included in the corporate income tax calculations.

1. RESULTS AND RESULTS COMMUNICATION

The Area Assigned to the Project shall produce an Annual Report, with data up to the last business day of that year, with information on all the Sponsorship under its management that year. The report must be sent to their respective Deapartment and contain the following information:

1. Sponsorship Planned Schedule
2. Project Objectives and Returns;
3. Sponsored Amount;
4. Achieved Goals;
5. Length of Partnership;
6. Image Results (press), if any; and
7. Project Location and Scope.

1. GENERAL GUIDELINES

Sponsorships shall also respect the following guidelines:

1. The funds associated with a Sponsored event must be employed solely in activities intrinsically linked to its execution;
2. Events associated with Projects sponsored by the Company must be closely reviewed by the Area Assigned to the Project to ensure that the funds are being correctly employed;
3. In the case a Project is not approved for Sponsorship, the Area Assigned to the Project must inform the Applicants of this decision.

5. COMPLIANCE HELPLINE

Any suspicions or evidence of violation of Code of Conduct and Ethics, of this or any other Policy may also be reported directly to the specific channel for receiving complaints, accessing the website at www.compliancehelpline.com.br/alpargatas. Globally, any suspicions or evidences may be reported in English or Spanish, through the website at www.compliancehelplinealpargatas.com.

Compliance Helpline is an independent and impartial tool operated by an internationally renowned service provider. The whistleblowing can be made anonymously, being ensured, even for the identified denunciations, the most absolute confidentiality of the report and people involved. This helpline is also open to receive complaints from third parties.

Internal Use Only

SPONSORSHIP POLICY

Any communication related to complaints should include as much information as possible, such as: (i) objective and impartial description of the fact; (ii) when and where the violation occurred or is occurring;

1. the people and organizations involved; and (iv) any documents that help the analysis of the case and the development of any actions. Any and all information or evidence is important to ensure the accuracy of the investigation of the report.

Complaints may also be reported via email to [e-mail].

6. SANCTIONS

Any noncompliance with the legal and regulatory provisions stated herein shall subject the offending party to the disciplinary measures established in the internal policies, without prejudice to administrative, civil and even criminal sanctions, among other applicable measures.

Any violation of this Policy or the relevant legislation by third parties may trigger an immediate contract termination and all the penalties resulting from the termination without prejudice to an action for damages and other appropriate legal measures.

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Internal Use Only