The ethical and transparent behavior of GOL's employees and stakeholders is given by the example constantly set by GOL's Senior Management, who are responsible not only for communication, but also in their attitudes.

GOL's Senior Management has the ability to incorporate the ethical values that represent the best governance practices into the attitudes of each stakeholder, through well-defined communications and values, on a daily basis.

The mission of the Corporate Risks, Compliance and Internal Controls Executive Board is to establish corporate policies and standards and to provide information that supports decision making and contributes effectively to value preservation through appropriate risk management and a robust system of internal controls. In other words, it is responsible for supporting and guiding the other areas of the company, especially those with a greater operational focus and higher risk.
GOL always conducts its business in accordance with the best corporate governance practices, taking into account the highest national and international standards.
Thus, we base our activities on the governance model of the three lines of defense, with areas involved in management, monitoring and support activities, through the integration of the areas of Corporate Risks, Compliance, Internal Controls and Privacy.

Rumo Certo is a dynamic program that is constantly evolving and improving and is based on the following pillars:

The GOL Way of Being and Acting is underpinned by upright and ethical behavior because we believe that ethics should permeate all of our relationships and activities. It is these attitudes and behaviors that bind us to the goal of Being First for All. In this sense, the company is committed to the anti-corruption legislation applicable to it and has adopted the Rumo Certo - Ethics and Compliance Program, which aims to promote a culture of integrity and to prevent, mitigate and respond to the risks of corruption and other internal actions that are contrary to our values.

RUMO CERTO - Ethics and Compliance operates in all areas of the company and its success depends on the commitment of all members, who must act in accordance with our values and contribute to the implementation of the necessary measures to ensure its effectiveness.

The Compliance Department is primarily responsible for managing RUMO CERTO - Ethics and Compliance. In this context, it also has the role of submitting issues related to ethics and conduct to the Ethics Committee for decision.

The Compliance Department is an independent department, made up of qualified professionals, dedicated exclusively to the coordination, development and improvement of the program, which is implemented and developed on a daily basis by all the company's departments. To ensure the necessary autonomy and independence, the Compliance function reports directly to the CEO and has direct access to the Statutory Audit Committee and the Board of Directors.

The Sustainability Policy has been created to present the company's ESG commitments and actions, always with a view to sustainable development. For more details on this topic, please visit the Sustainability page at this link: https://www.voegol.com.br/en-us/sobre-a-gol/sustentabilidade.

GOL, in its relations, is based on principles that sustain an organizational culture focused on valuing people, acting in compliance with our internal procedures and regulations and the permanent search for development. With regard to internal compliance guidelines, the company defines its expectations for action in clear and transparent internal policies and procedures and disseminates them to all those to whom they are directed.

The CIA is committed to maintaining high standards of Corporate Governance, and the Ethics Committee has the support of Senior Management to promote a culture of ethics and compliance with applicable legislation in its daily operations at all levels of the Company.

GOL has a comprehensive and transparent Code of Ethics that provides guidance on matters related to the ethics and values that govern the Company's activities. This Code applies to all members of the Company, both employees at all hierarchical levels and members of the Statutory Committees, the Fiscal Council, the Board of Directors and its shareholders, in the exercise of their functions or duties.

GOL expects these principles to be observed by all its business partners. Compliance with the Code demonstrates our commitment to professionalism and transparency in all of our professional activities.

 Code of Ethics download

GOL prioritizes relationships with third parties that conduct their activities in accordance with ethical principles similar to its own. Therefore, all third parties must comply with the Third-Party Code of Conduct during their relationship with the Company.

The purpose of these guidelines is to formalize GOL's firm commitment to ethical conduct and to make public its rejection of corruption in any form. A commitment to ethical conduct and compliance mechanisms to prevent and punish deviations is an essential factor for Third Parties to maintain partnerships with GOL.

 Third-Party Conduct Guidelines download

We oppose corruption in all its forms and seek to ensure the highest level of integrity and ethics in our activities. In order to clarify its commitments, concepts and major related risks, GOL has adopted an Anti-Corruption Policy, among others, as detailed below. In its Anti-Corruption Policy, the Company reiterates the prohibition of bribery and other acts harmful to public administration, such as damaging the competitive nature of a bidding process, obstructing or hindering investigations or inspections by public authorities, or using third parties to conceal their true interests in their relations with public entities.

As a Brazilian company listed in the United States, GOL is directly subject to the Brazilian Anti-Corruption Law (Law 12.846/13) and the U.S. Foreign Corrupt Practices Act (FCPA), the prohibited acts of which are described in the Anti-Corruption Policy.

GOL maintains the highest level of integrity and transparency in its relationships with public officials. Therefore, in order to guide our members in their relations with this type of professional, we have a Policy on Interactions with Public Agents.

In its interactions with public officials, GOL adopts a position of strict compliance with the law and reinforces the guidelines established in this policy.

The purpose of GOL's Policy on Gifts, Presents and Hospitality ("Courtesies") is to define the conditions under which courtesies may be offered/received in the course of GOL's business relationships, to explain concepts, to define limits, to draw attention to points of concern and to provide practical examples. Courtesies may be offered/received in the course of business relationships in accordance with GOL's internal policies and procedures and provided that they do not constitute or appear to constitute an improper advantage. In general, GOL members may receive gifts, entertainment or hospitality if these courtesies are:

• Do not appear or have the purpose of influencing the person receiving the courtesy, i.e., do not appear to be an exchange of favors;
   
• Are not excessive in value, such as more than 1/3 of the minimum wage;
   
• Not offered too frequently;
   
• Not in cash or another medium that can be easily converted to cash;
   
• Are not, or do not appear to be, inappropriate.

Sponsorships and donations are support provided by the Company to initiatives with which GOL identifies. In order to ensure that this support is provided in a transparent manner and achieves the objectives for which it is intended, this policy clearly defines the guidelines and precautions required when providing this type of support to third parties. We do not make contributions to political parties and we do not allow third parties to make contributions on behalf of and/or in the interest of GOL.

GOL conducts its activities in a transparent, safe and responsible manner, free from conflicts of interest and consistent with its values.

The Conflict-of-Interest Policy defines the guidelines for avoiding situations of conflict of interest, i.e., situations in which the private interests of an individual or a related party may override the interests of the company. In this context, both GOL members and third parties are expected to report any situations of potential conflict of interest that they identify, so that these situations can be reassessed and the associated risks mitigated.

We believe in a fair and transparent market, which is why we have a Policy on Transactions with Related Parties, which aims to provide transparency to this type of transaction. Related Parties are people or entities with which the Company has a certain relationship that allows them to negotiate under conditions that are not independent, as other partners negotiate, due, for example, to their corporate relationships.

To support this objective, GOL requires its suppliers, business partners or other third parties to inform if they are aware of being a Related Party of GOL, before entering into a commercial relationship.

Because GOL prefers to work with third parties that conduct their activities in accordance with ethical principles similar to its own, GOL conducts due diligence on its potential suppliers, agents, business partners and other counterparties with whom it does business.

This process is carried out through research and analysis of information and documents with the aim of identifying risks related to corruption and ethical-reputational issues that may arise from the signing of contracts, partnerships or other types of associations.

For us, valuing people, complying with rules and regulations, and constantly seeking development are fundamental. That's why GOL invests in training and activities that reinforce the principles of our culture.

Our Culture of Integrity is the guiding principle of our actions and should be the basis of all our attitudes. Raising awareness of compliance issues among all members of the company is key to maintaining and developing this culture. Periodic materials will be developed to familiarize our members with compliance issues. These trainings and communications are intended to reach all GOL members, and to that end, we conduct training for everyone, regardless of position or function, including members of senior management.

With the launch of the Rumo Certo - Ethics and Compliance Program in 2018, GOL has developed a series of videos aimed at all members, so that everyone in our company is aware of the paths to take and can contribute to our culture of integrity.

The videos are divided into themes and, through a simple narrative, address issues related to compliance and provoke reflection on how we should act in our working relationships and also in society. The online training is available in Portuguese, Spanish and English in all countries where we operate. In addition to online training, face-to-face sessions are held, either at the request of the business units or when more exposed areas or compliance-sensitive processes are identified. In these cases, the presentations are given by members of the Compliance Department in a practical and interactive workshop format, allowing for an exchange with the affected areas, clarification of doubts and bringing the parties closer together.

The purpose of our communications is to reinforce relevant information, keep compliance issues present in the daily lives of team members, and translate our policies into practical examples so that everyone can identify risk situations in our daily operations and know how to act. They are held periodically and cover a variety of topics, such as when new policies are introduced, procedures are updated, or issues are identified about which members have concerns.