CEO

Fabio Schvartsman

Chief Financial Officer

Luciano Siani Pires

Executive director,
Ferrous Minerals and Coal

Peter Poppinga

Executive director
Base Metals

Eduardo Bartolomeo

Executive director
Sustainability and Institutional Relations

Luiz Eduardo Osorio

Executive director
Business Support

Alexandre Pereira

Director
of People

Marina Quental

General Counsel

Alexandre D'Ambrosio

Director of Strategy, Exploration
New Business and Technology

Juarez Saliba de Avelar

Dear colleagues,

This is Vale’s new Code of Ethical Conduct, which contains principles and directions to guide the professional conduct of everyone that works for our company or acts on behalf of it. This recent update sought to transform the document so that it is more detailed, simple and easy to consult.

We are counting on you to turn our company into a global standard for ethics and integrity, assuring the observance of our Code at every level, location and environment of our company.

We are proud to promote and being keepers of our Code!

Yours sincerely,
Executive Board

• Practice Active Genuine Care, taking care of yourself and others and letting others take care of you;
• Prioritize health and safety over production in situations that pose risks to anyone;
• Exercise your right to refuse to work in situations that pose a risk to health and safety;
• Act immediately when you identify any situation that poses a risk to health and safety to anyone;

• Understand and comply with legal requirements and internal standards related to health and safety;
• Only execute activities if you are trained and authorized, have the right tools, and are in a fit physical and mental state;
• Never work under the influence of alcohol, illegal drugs or other drugs that could affect your capacity to perform your activities and thereby endanger your own life and others’ lives;
• Promote a physically and mentally healthy and safe work environment;

• Follow the company’s rules on performing periodic occupational medical tests;
• Make sure you know how to proceed in emergency situations;
• Report any unsafe act or condition in the work environment, as well as work-related accidents or illnesses, using the proper internal channels and procedures.

• Respect the human rights of all the people with whom you interact in your work;
• Monitor risks of human rights violations in our operations, projects and the communities where we operate, to voluntarily identify, prevent, mitigate and rectify possible negative impacts;
• Never condone sexual exploitation of children and adolescents and always support the fight against it;
• Never condone child labour and always support the fight against it;

• Never condone any kind of employment practice that could be interpreted as equivalent to forced or slave-like labour and always support the fight against it;
• Respect the prevailing legislation, the rights, the relationships with the territories and the way of life of the communities in areas influenced by Vale's operations and projects, including Indigenous peoples.
• Look for peaceful resolutions to conflict situations while protecting people’s physical integrity, preserving property and maintaining production processes.

• Underpin all your relationships with respect, recognizing other people’s qualities and rights;
• Work collaboratively, encouraging diversity of ideas and stimulating constructive dialogue;
• Never allow personal characteristics to interfere in work or limit professional development;
• Recruit, recognize, promote and remunerate based on merit, with equivalent opportunities for all professionals. Seek to expand diversity when building your team;
• Act and make decisions without prejudice, discrimination or individual preferences. Promote a work environment that reflects this conduct;

• Report any prejudicial or discriminatory conduct you have experienced or your colleagues have experienced in your presence;
• Do not allow your words and actions to harm work relationships or cause embarrassment in others and avoid offensive or derogatory words, nicknames or jokes;
• Never practice, disseminate or tacitly allow any kind of bullying, sexual harassment, aggressive behaviour or violent acts;
• Respect everyone’s religious beliefs, as well as every person’s right not to take part in religious activities;

• Respect everyone’s political ideologies and never conduct any political activity or advertising while on the company’s premises;
• Never use your position to impose your political or religious opinions on others;
• Never associate the Vale brand with any political or religious activity without a competent prior authorization;
• Respect people’s freedom of association and collective bargaining.

• Respect legal requirements, such as environmental regulations and permits.
• Report any environmental incidents or accidents to the responsible Vale area.
• Develop and operate projects in a way that minimizes environmental impacts and avoids environmental liabilities.

• Achieve the company’s targets related to sustainably consuming resources such as water, electricity and fuel, as well as to reducing atmospheric emissions and residues.
• Ensure that hazards, risks and potential environmental impacts are identified and controlled according to applicable legislation throughout each project’s lifecycle.

• Never agree on prices, production levels or market strategies with competitors, nor adopt any other practice that limits free competition;
• Avoid contact with competitors, except on specific occasions such as conferences;
• In dealing with competitors, only share public information;
• Only obtain information on competitors through legal means and public sources;

• Never share confidential information of competitors with whom you have previously worked or to whom you have provided services;
• Refuse any offer of confidential information regarding competitors;
• Only supply truthful information on our products;
• Act with transparency toward internal and external stakeholders, only sharing accurate information and never omitting significant information;

• Ensure that accounting, financial and management records and reports reflect reality and always comply with prevailing legislation;
• Do not join nor accept fraudulent or unlawful activities.
• Never allow money laundering. Report situations that could constitute this practice, such as large cash payments or payments made by parties not involved in a transaction;
• Collaborate with supervisory authorities and with internal and external auditors.

• Never make decisions or influence negotiations that could benefit you, a relative, a financial dependent or those with whom you have romantic relationships;
• Never influence or participate in recruitment and selection decisions involving relatives or those with whom you have romantic relationships;
• Never be a business partner with, never receive any financial benefit from, and never perform any kind of administrative, supervisory, regulatory, managerial or advisory role for, any of Vale’s competitors, any company that does business with Vale, nor any company that is in a procurement or acquisition process involving Vale;
• Never be a business partner with and never conduct any other kind of business involving, employees who are part of your team, employees in whose career-related decisions you participate, nor any other employee with whom the business generates conflicts of interest;

• Never request or receive any pay or benefits of any kind from any of Vale’s suppliers, competitors, clients or their representatives as a bargaining tool to obtain improper advantages;
• Never request or receive any pay or benefit of any kind from any of Vale’s suppliers, competitors, clients or their representatives that violates internally-established values and levels of approval;
• Never remain in a professional relationship involving direct or indirect subordination with an employee or a service provider if you are related, if the person is financially dependent upon you or if you are romantic partners.
• Always inform your manager about situations that could represent conflicts of interest, and always perform your duties to rectify such situations.

• Do not offer, promise, give, transfer, receive or authorize a bribe of any kind.
• Respect our Global Anti-Corruption Program and all applicable anti-corruption and anti-bribery laws and regulations;
• Do not make facilitating payments unless there is an imminent threat to your safety or freedom, or to someone else’s safety or freedom.
• In the case of making facilitating payments, be accurate and complete when recording payments or financial transactions in our books and records;
• Be aware and report any suspicion of bribery or any violation of our Global Anti-Corruption Program.

• Dedicate your working hours to performing professional activities related to Vale. Other activities should preferably be done during lunchtime and other breaks;

• Strive to protect the company’s assets, especially those for which you are responsible, such as Personal Protective Equipment (PPE), vehicles, equipment, furniture, radio sets, computers and phones;

• Never use or loan the company’s goods for personal purposes;
• Only use your corporate credit card in line with the company’s rules and always keep your expense records up-to-date.

• Always select suppliers based on objective, technical, financial, and legal compliance factors and Vale’s required criteria regarding integrity, health, safety and environmental stewardship, guaranteeing fair conditions for all bidders;
• Never allow suppliers to provide any services or materials that are not itemized in procurement documents, even if this seems to benefit Vale.

• Protect the information used in relationships with suppliers and bidders, such as technical, commercial, strategic, registration, financial and managerial data, whether it belongs to Vale or third parties;
• Never maintain commercial relations with suppliers that do not act in line with our standards of ethical behaviour.

• Receive and offer gifts and hospitality in a transparent, open way and only at opportune moments;
• Refuse and never offer gifts and hospitality in exchange for favours, benefits or advantages, or that are aimed at influencing the receipt, procurement or maintenance of business deals;
• Ensure that all gifts and hospitality received and offered by Vale respect internally-established values and levels of approval;
• Never accept or offer gifts or hospitality in cash or equivalent forms, such as gift vouchers or other vouchers involving external stakeholders.

• Be careful when talking about our business information in informal environments and public areas, because you never know who might be listening.
• Never use Vale’s information and content for private purposes, nor for any use that is not aligned with the company’s objectives and without the proper approval.
• Only share Confidential, Restricted and Internal Information with authorized people who need it.

• Share public information preferably through the appropriate corporate channels, such as the Communications and Investor Relations areas.
• Only share business information with external parties when this is in Vale’s interests, and only after receiving the necessary internal approval.
• Report information security incidents, such as the disclosure, unauthorized modification, loss or theft of business information and the improper use or sharing of credentials, such as name badges and access passwords.

• Always act according to our Values.
• Never make any commitment on behalf of Vale, unless this is part of the scope of your work and the adequate levels of approval have been granted.
• Use simple, optimistic, warm and transparent language, and respect Vale's positions.

• Never criticize colleagues or Vale on social networks or in other channels in a way that could improperly expose our employees or our company. Instead, submit criticism or allegations to the company’s official channels.
• Only use Vale’s name and brand to represent the company institutionally. Never use them to obtain any kind of benefit.