PROCEDURE

7.1. The following attachments are part of this Policy:

ATTACHMENT 1 – EXAMPLES OF POSSIBLE SITUATIONS OF CONFLICT OF INTERESTS.

ATTACHMENT 2 – RULES ABOUT FREEBIES, GIFTS AND HOSPTALITIES.

ATTACHMENT 3 – FLOW TO IDENTIFY AND COMMUNICATE CONFLICT OF INTERESTS SITUATIONS.

ATTACHMENT 1 – EXAMPLES OF POSSIBLE SITUATIONS OF CONFLICT OF INTERESTS

1. Examples of Conflict of Interests Situations The following situations are practical examples that can help identify Conflict of Interests situations:

1.1. External functions: It is common that Employees act in social causes, volunteer activities or take other roles in the society. However, Employees that perform or intend to perform external functions, paid or not, shall analyze if such activity is allowed under their labor agreement, and also the possible impacts of this external function to the activities performed at Hyundai. For instance: participation in companies/entities as owner/shareholder; lecturer; teachers; brokers; candidacy and/or election for public positions; executive positions in other companies and/or philanthropic entities. Remembering that participation in a company that is a competitor of Hyundai is always prohibited.

1.2. Personal relations in supplier contracting: Employee that, on behalf of Hyundai, hires or influence the hiring of a supplier with who such Employee has a friendship relation or in which a relative or person with whom he has a romantic relationship works.

1.3. Personal relations in supplier management: Hyundai Employee that is responsible for managing a supplier with whom he/she has a friendship relationship or in which a relative or person with whom he has a romantic relationship works.

1.4. Employee-supplier relationship: Hyundai Employee who is the owner, representative or employee of a company that maintains or intends to maintain a business relationship with Hyundai.

1.5. Gifts, presents and hospitalities: Hyundai Employee who is performing a bid process and receives gifts and hospitalities from one of the participants or is invited by one of the participants to visit his company, all expenses paid, and offered freebies, gifts or entertainment (see item 2.4 of attachment 2) unrelated to the visit.

1.6. Government Relations: Hyundai Employee that is a government agent or has family members who are government employees in a position that could influence Hyundai ́s activities.

1.7. Personal relations in the workplace: Hyundai Employee who is either directly or indirectly involved in the recruitment, promotion, assessment or has any hierarchical relationship with people who have a family or romantic relationship.

1.8. Competitor relations: Hyundai Employee, their relatives or people with whom they have a romantic relationship who maintain business relations directly or indirectly with competitors of Hyundai, such as, dealerships, distributors, suppliers, service providers, consultants, etc.

1.9. Personal Advantage: Hyundai Employee who uses his position to obtain personal benefits from third parties (for instance, goods, services, advantages, job for other people, etc.). 1.10. Opportunities Deviation: Hyundai Employee who deviates to himself or for third parties, Hyundai business opportunities. It is important to highlight that Conflict of Interests situations are not limited to these examples only. In case there is any situation that is not found in this document and if it causes any kind of doubt about being or not a situation of Conflict of Interests, seek guidance from the Compliance team that will be able to solve your doubts through the e-mail compliance@hyundai-brasil.com.

ATTACHMENT 2 – GIFTS, PRESENTS AND HOSPTALITIES

1. Scope

1.1. The scope of this Attachment 3 is to define the criteria for receiving and offering freebies, gifts, hospitalities and entertainment and establish procedures in order to register, evaluate and guide the eventual acceptance of freebies, gifts and hospitalities.

2. Terms and definitions

2.1. Public Administration: the term Public Authority is broadly defined to include, but is not limited to national and foreign bodies of the direct or indirect administration, of any of the powers of the Union, States, Federal District, Municipalities, and Territory (whether executive, legislative, judicial or administrative), public enterprises, mixed economy companies or concessionaires of public services such as: regulatory agencies, customs, notaries, police stations, tax offices, issuers of government authorizations, approvals, licenses and visas.

2.2. Public Agent: any natural person (i) acting on behalf of the Public Administration; (ii) who works for a company performing typical activity of the Public Administration; or (iii) representing a political party or candidate for public office.

2.3. Gifts: products, without commercial value distributed as a courtesy, advertisement, institutional promotion, in events or on commemorative days. Gifts are typically marked by the company’s logo, such as keychain, pens, calendars, scratch pad, or other similar products.

2.4. Entertainment: incentive trips, tickets for concerts or any other kind of events (sportive, cultural, etc.), with the purpose of providing leisure activities.

2.5. Hospitalities: refers to transportation (air, ground and/or sea), accommodation, transfer and food for the participation in seminars, trainings, technical update events, etc.

2.6. Politically Exposed Person (PPE): any person who performs or has performed, in the last 5 (five) years, relevant public functions or functions in Brazil or abroad, such as heads of State, ministers, congressmen, officials of public, judicial or military authorities. It also includes candidates from political parties and any person related to a political party.

2.7. Presents: items for personal use or consuming, which have commercial value, without promotional character and that does not fit in the definition of gifts. The following, without limitation, are considered examples of gifts: chocolate, panetones, alcoholic beverages, electronic devices, jewelry, and others.

2.8. Third-parties: any person or legal entity, who maintain or intend to maintain business relations with Hyundai. They can be, for example, dealerships, distributors, suppliers, service providers, competitors, consultants, other business partners or even competitors, public agents, etc.

2.9. Undue advantage: any benefit, even if not economic, gifts, entertainment, airline tickets, accommodation, donations, sponsorships, cash amounts, offered, promised or delivered with the purpose of improperly influencing or rewarding any act, decision or omission of a person, be it a Hyundai Employee, third parties or a Public Agent.

3. GENERAL CRITERIA TO OFFER OR RECEIVE:

3.1. Hyundai understands that Gifts, Freebies and Hospitalities may help strengthen the business relations and, in some countries, they are culturally acceptable. However, a certain caution is needed for the acceptance or offering of a present, gift or hospitality not to be misunderstood as a possible benefit, favoritism or exchange of favors, that may eventually have influence over the capability of people to act in a neutral and professional way, for that matter they should observe the following criteria:

3.2. PRESENTS AND GIFTS

3.2.1. Must occur in compliance with the national and international law applicable, as well as Hyundai ́s and involved third party ́s policies and rules;

3.2.2. Must be given or accepted in order to promote the brand, as a demonstration or explanation of products and services or in ceremonies or corporate events;

3.2.3. Must be given or accepted in a transparent way and that does not cause any embarrassment in case of public exposure for Hyundai or its Employees;

3.2.4. Must be given and/or accepted without any expectations of reciprocity, obligation or favor exchange; and

3.2.5. They cannot be uncommon or excessive, such as, high-priced presents, gifts and hospitalities, offered without clear or justified motivation, received from a person (either natural or legal) in a short frequency (less than 12 months). For instance: cellphones, jewelry, imported beverages, electronics, trips, accommodation, air tickets, and others.

3.3. HOSPITALITIES AND ENTERTAINMENT

3.3.1. Must be given and/or accepted without any expectation of reciprocity, obligation or favor exchange;

3.3.2. Must be directed to Hyundai and have a strictly professional nature; and

3.3.3. If the event, training, conference or seminar has clear business purposes, related to the activities of the invited party.

3.4. IT IS PROHIBITED TO ACCEPT OR OFFER IF THEY:

3.4.1. Influence or seem to influence a business decision;

3.4.2. Cause or seem to cause an undue advantage or any type of embarrassment to any of the parties involved;

3.4.3. Occur regularly/repeatedly for the same person;

3.4.4. Come from a Third-party that takes part in a bid, hiring or contract renewal process with Hyundai;

3.4.5. Occur with money (currency paper, bank transfer or Pix) or any other payment method, such as gift-cards, shares, loans, payment of vacation daily rates, or with uncommon items; or

3.4.6. Violate Hyundai or third party policies.

3.5. LIMIT VALUE AND PROCESS FOR RETURNING GIFTS AND PRESENTS

3.5.1. The limit value of gifts and presents to be received or offered will be communicated annually by the Ethics and Compliance team. In the absence of a specific communication, the amount may not exceed the limit of US$50 per year from each supplier or business partner.

3.5.2. In case of doubt about the value of gifts or presents to be received or offered, the Ethics and Compliance Team should be consulted via e-mail compliance@hyundai-brasil.com.

3.5.3. In case the gift or freebie received is not in Compliance with the criteria defined, it must be refused for not being in compliance with the rules established in this policy, and the refuse must be formalized on e-mail, acknowledge for the offer and inform the Third-party about this policy, the Code of Ethics and Conduct and the necessity of always keeping the impartiality and objectiveness in the business relations, adding the e-mail of the Ethics and Compliance Team (compliance@hyundai- brasil.com) to these communications.

3.5.4. If the refusal of the gifts and presents is not feasible, the Employee who received it must notify the Ethics and Compliance Team, which will register the occurrence and, together with the Head of the Employee’s department, will decide on the destination of the present and gifts, which may be directed to a charitable entity (indicated by the Social Responsibility area and following the guidelines of the Donations and Sponsorship Policy) or to be raffled among the department’s employees.

3.6. PROCEDURES FOR RECEIVING OR OFFERING HOSPITALITY AND ENTERTAINMENT

3.6.1. In order to be considered, the offering or receiving of entertainment and hospitality must comply with the criteria established in item

3.6.2. Employees must submit any invitations for the approval of the Head of Section and and Head of Department. In case of doubt, the leadership must consult the Ethics and Compliance Team via e-mail compliance@hyundai-brasil.com.

3.6.3. Invitations must always be addressed to Hyundai and the leadership will decide the must suitable Employee to participate, considering his/her activities and technical qualifications.

3.6.4. In case the invitation involves trips (national or international) the expenses with accommodation and food must be paid by Hyundai in accordance with the Business Trip Policy.

3.6.5. In case hosting Third-party is taking part in a bidding process at Hyundai or a contract renewal and the participation the event is essential from the technical update and competitive point of view, the Department in question is allowed to participate in the event provided that all the costs are paid entirely by Hyundai (registration, trip expenses, etc).

3.6.6. The Employees must not receive presents, gifts and invitations to hospitalities in their residences. If this comes to happen, the Employee must refuse it and communicate the Third-party about Hyundai’s policies and inform the Compliance team (compliance@hyundai-brasil.com).

3.7. PEPs AND PUBLIC AUTHORITIES

3.7.1. It is not allowed to offer or accept presents, gifts, directly or indirectly, to or from national or international Politically Exposed Person (PEPs) or Public Authorities.

3.7.2. In protocol situations, gifts, presents and hospitalities may be offered or received, within the limits of this Policy and the applicable laws, upon previous assessment of the Ethics and Compliance Team.

3.7.3. Invitations to PEPs for taking part in events must be formally approved by the Vice-President of the concerned area after assessment of the Ethics and Compliance Team.

3.7.4. It is strictly forbidden to bear expenses related to the participation of PPEs in events, such as seminars, congresses, visits and technical meetings, in Brazil or abroad. Exceptions must be evaluated and approved by Hyundai’s Ethics and Compliance Committee.

3.7.5. The payment of expenses related to the participation os PPEs in events of any natrure is prohibited. Exceptions must be assessed and approved by Hyundai’s Ethics and Compliance Committee.

3.7.6. If a request of offer for presents or gifts by PEPs or person related (directly or indirectly) with Public Authorities or any Public Agent, please submit information of the request to the team of Ethics and Compliance for evaluation of the situation and how to conduct the matter. Do not take any decision that might expose Hyundai or its Employees to undesired situations.

3.8. ACCOUNTING RECORDS

3.8.1. All expenses incurred with gifts, presents and hospitalities must be registered appropriately in Hyundai accounting records.