Ethical behavior
GRI 103-2, 103-3

We are committed to running our business to the highest standards of ethics and integrity. Based on this commitment, in 2018 we optimized our Compliance Program, which specifically spells out the conduct we expect from all our own and outsourced employees in dealing with a wide variety of different situations. The Board of Directors is one of the main agents in promoting the program and we are determined to ensure its compliance, with penalties for acts that are not in compliance. Nexa’s Internal Controls, Compliance and Risk Management areas, responsible for managing and disseminating this program, are linked to the Financial Department, with the support of Internal Audit. Compliance-related issues are reported to the Audit Committee, which is responsible for periodically bringing them to the attention of the Board of Directors.

One of the main pillars of the Compliance Program is the Nexa Code of Conduct, essential in guiding activities and supporting decisions made at all levels of our Company. Based on the century-old values of the Votorantim Group, this document was revised in 2018 and guides our internal behavior and the way we interact with different stakeholder audiences.

The Code of Conduct is a public document, shared with all stakeholders, including employees, suppliers, customers, communities, NGOs, government entities, shareholders and other individuals and organizations with whom we interact, to ensure that we achieve excellence in all our practices. Our beliefs and our values are detailed on the internet (www.nexaresources.com/beliefs-and-values). GRI 102-16

In 2019, we launched the integrity due diligence process, which consists of assessing all third-party employees from the point of view of compliance with our program. Thus, we will have a more effective process in risk management and mitigation.

Among the achievements of the year, we also obtained Sarbanes-Oxley (SOX) certification, since we have implemented internal control and disclosure systems as required by U.S. legislation, essential for companies listed on the New York Stock Exchange, such as Nexa.

Following the guidelines for reducing conflicts of interest within the company, in the second half of 2019 a website was created for employees to share potential, actual or apparent deviations from the Code of Conduct, which could be characterized as a risk of favoritism or bias in decision-making situations.

Training in the new policies SDG 10.3

On September 5, 2019, simultaneously in Brazil and Peru, we held another Compliance Day, an annual event to engage the leadership and strengthen the importance of their participation in our program. The event involves executive officers, managers and general managers.

At the same time, we modernized our training platform, providing three mandatory e-learning courses for administrative personnel (Code of Conduct, money laundering prevention and anti-corruption). As for operators, we prepared a video class on the Code of Conduct, which is widely disseminated for generating greater adherence. This approach allows higher engagement rates of the in-company community with our Compliance Program. The four policies – Compliance; Anti-corruption; Antitrust/Competition; and Money Laundering and Terrorism Financing Prevention – and the nine internal procedures that detail the management of these issues on a daily basis are available on the company’s website (ri.nexaresources.com). GRI 205-2 SDG 16.5

No cases of corruption or violation of antitrust laws involving employees or business partners were confirmed in the period. GRI 205-2, 205-3, 206-1

Information and reporting channels GRI 102-17 SDG 5.1

Annually, we prepare and disseminate information to employees on the use and operation of the Ethics Line and the Compliance area, in addition to faceto- face training that is given in corporate units and offices. The main messages on Compliance policies and the Ethics Line channel are also disseminated through e-learning sessions. To make communication even easier, a telephone number was created and communicated to address doubts about ethics and conduct through WhatsApp.

The Ethics Line remains in operation so that the internal and external audiences can report possible violations of the Code of Conduct or any policy, procedure, law or regulation. It was created to be impartial and transparent, in addition to ensuring the confidentiality of information, safeguarding the identity of anyone who accesses it and promoting the best workplace environment for everyone.

Through this channel it is possible to fully and anonymously report any suspicion of financial crime, fraud, corruption, discrimination, harassment or other types of ethical violations. Available in Portuguese, English and Spanish, the service can be accessed through the electronic address: (www.nexaresources.com/ethics-line) or by phone (Brazil: 0800-892-0741; Peru: 0800-50-000 (Spanish) and 0800-50-288; United States: 1-855-888-9926; Austria: 0800-200-288; Canada 1-855-888-9926 and 1-855-350-9393; and Luxembourg: 800-201-11 (English and French).

The channel is managed by a specialized, globally recognized outside company, which performs the initial screening of all reports received to ensure that there is no conflict of interest in the handling of complaints. The Audit Committee and the organization’s leaders, supported by the Internal and Legal Audit areas, decide how to deal with each report received, from its initial understanding, interviews with the parties involved, detailed investigation and conclusion as to the merits or lack thereof regarding the complaint, with the possible application of disciplinary and orientation measures.