ULTRAPAR HOLDINGS INC

Foreign Filer Report • Mar 19, 2022

6-K 1 MainDocument.htm 6-K

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form 6-K

Report o f Foreign Private Issuer

Pursuant t o Rule 13a-16 Or 15d-16 Of

The Securities Exchange Act Of 1934

For the month of Ma rch 20 2 2

Commission File Number: 001-14950

ULTRAPAR HOLDINGS INC.

(Translation of Registrant’s Name into English)

Brigadeiro Luis Antonio Avenue , 1343, 9 th Floor

São Paulo, SP, Brazil 01317-910

(Address of Principal Executive Offices)

Indicate by check mark whether the registrant files or will file annual reports under cover of Form 20-F or Form 40-F:

Form 20-F _ X Form 40-F _

Indicate by check mark if the registrant is submitting the Form 6-K in paper as permitted by Regulation S-T Rule 101(b)(1):

Yes _ No _ X

Indicate by check mark if the registrant is submitting the Form 6-K in paper as permitted by Regulation S-T Rule 101(b)(7):

Yes _ No _ X

ULTRAPAR HOLDINGS INC.

TABLE OF CONTENTS

ITEM
1. Corporate policy on anti-corruption and the relationship with the public and private sector;
2. Code of Ethics

CORPORATE POLICY ON ANTI - CORRUPTION AND THE RELATIONSHIP WITH THE PUBLIC AND PRIVATE SECTOR

1. PURPOSE

This Policy establishes the rules of prevention and the fight against corruption and introduces the guidelines to be followed in the relationship with the public sector , Brazilian or foreign , and priva te entities . This policy also introduces guidelines rela ted to prevention of Money Laundering and Financing of Terrorism .

1. SCOPE

This Policy ap p li es to all companies controlled by Ultra Group . In companies where the control is shared or where it holds minority interest, Ultra Group will endeavor to ensure that the principles and guidelines of this Policy will be substantially applied .

The provisions of this Policy should also guide the conduct of all External Representatives , Business Partners , Suppliers and Service Providers o f Ultra Group , as well as any individual or legal entity operating in the interes t or to the direct or indirect benefit of Ultra Group or any of its subsidiaries .

This Policy shall be read in conjunction with the Code of Ethics and other Corporative P olicies and rules defined by the Ultra Group. In the event of conflict of the guidelines herein with other procedure s of the Company and of its Business , the Risk, Compliance and Audit Department shall be consult e d.

1. D EFINITIONS

For purposes of this Policy , capitalized terms hav e the m eaning attributed to them in Exhibit I – Glossary .

3.1. C ORRUPTION

For the purposes of this Policy , corruption o c c urs when s o meone asks , offer s , prom ises , demands , aut h oriz es, receiv e s or gives , directly or indirectly , Undue Advantage to a Public or Priva te Officials , Brazilian or foreign , or to a pe rson indica te d by them . An advantage , which may or not be an asset , is undue when there is no legal or regula tory contractual provision authorizing it or when it is promised or given so that the Public or Private Officials do or refrain from doing something that breaches the law, this Policy or his duty or loyalty .

The practice of corruption by any Partners , Employees , External Representatives and Business Partners , Suppliers and Service Providers of Ultra Group is prohibited . The mer e offer or request of Undue Advantage t o Public or Private Officials is considered a violation of the guidelines of this Policy , irrespective of the fact that such Undue Advantage has been accepted, delivered, received or r eached the intended benefits .

There is no exception to “ minor Undue Advantage s ” , being irrelevant th e amount or c h aracter istic of the advantage .

3.2. INFLUENCE PEDDLING

Partners , Employees , External Representatives , Business Partners , Suppliers and Service Providers of Ultra Group should not, directly or indirectly , ask, offer, demand, authorize, receive or give , directly or indirectly , advantage in order to influ ence acts practiced by Public or Private Officer .

1. STRUCTURE OF THE ETHICS AND COMPLIANCE PROGRAM AND RESPONSIBILITIES

The Compliance and Ethics Program (“ Program ”) consists in a group of people , policies , procedure s, guidelines and cultur e , with the intent to consolida te the principa l a ction s and best practice s, as well as defin e and promo t e an environment ad h erent to law s, r egulation s , good practice s and Corporative Policies of Ultra Group .

The Program a ssists Ultra Group to transform its values into ethical conduct . Compliance co vers a s eries of preventiv e, monitor ing and corre c tiv e efforts , minimizing risks of noncompliance with guidelines and consequent adoption of legal or regula tory sanctions , including those related to the Anticorruption Law, or of noncompliance with th e principle s upheld i n our Program , in this Policy or in our Code of Ethics .

The areas and stru c tur e s below are directly i nvolv ed i n the management o f the Program . Accordingly, the inst ances and areas have the following respons i bili ti es:

4.1. CONDUCT COMMITTEE

The Conduct Committee is a non-statutory body , linked to the Board of Directors of Ultrapar . The principa l duties of the Conduct Committee are as follows :

• manage the application of the Code of Ethics, its guidelines and related policies
• supervise the application and effectiveness of the Code of Ethics principles
• review and approve the Compliance and Ethics Program and supervise its application, in order to ensure compliance
• propose and evaluate new policies associated with the Code of Ethics, as well as propose changes to it and the policies currently in force associated with it
• oversee investigations promoted by the DRCA
• recommend the appropriate disciplinary, administrative or judicial measures, related to a subject within its authority, to be adopted by Ultra Group’s bodies, as well as resolve on the need to report the matter to the Risk and Audit Committee or the Board of Directors of the Ultra Group for additional measures that may be applicable
• formally report the Committee’s resolutions to the Board of Directors in the most relevant cases
• forward to the Risk and Audit Committee and the Board of Directors annual reports describing their activities and those of the P rogram, without prejudice to extraordinary reports, whenever necessary
• answer questions about the application or interpretation of the Code of Ethics provisions, the policies adopted by Ultra Group and, in the areas within its agency , the law and the Regulation

4.2. RISK, COMPLIANCE AND AUDIT DEPARTMENT ( DRCA )

DRCA is responsible for :

• Propose and revi ew policies rela ted to the Program , as well as coord inate their reco m menda tion by the Conduct Committee and the respectiv e approval by the Board of Directors
• Guide and develop training topics for the Program
• De velop the corporat e communication of the Program
• Manage Ultra Group’s Open Channel
• Condu ct and/or oversee interna l investigation s i n Ultra Group
• Support and reco m mend delibera tions of consequ ence s
• Monitor the Program in all th e Business es of Ultra Group
• Represent Ultra Group institu tionally in the Compliance theme
• Follow up the development o f the activities of the Compliance areas of the Business
• Propo se improvement actions to the Program

4.3. BUSINESS COMPLIANCE AREA S

Compliance Areas are responsible for :

• Ensure the compliance with the guidelines o f the Program in the Business
• Implement and monitor the adherence to this Policy in the B usiness
• Plan, de velop , implement and execut e the Program and it s controls in line with the guidelines of Ultra Group and the risks of the Business
• Ap ply and control training o n Compliance in the B usiness
• Disclose the Program in the B usiness
• Ensure the realiza tion of Background Check s according to this Policy
• A ssist the Board of Executive Officers o f the Business in Compliance aspects that are relevant to decision-making proc es s
• A ssess the Program i n the Business
• Condu ct interna l investigation s in the B usiness , as requested by and in coord i na tion with the DRCA
• Periodically r eport to the DRCA the evolu tion of the Program in the B usiness

4.4. BUSINESS AND HOLDING L EGAL AREA S

L egal Areas are responsible for :

• Support the Compliance Areas and/or DRCA i n the prep a ration of guidelines on anticorruption clauses to be adopted i n the agreements
• Technically assist t h e Business i n the evaluation and formaliza tion of requests of donations and sponsorships , pursuant to this Policy
• Support the Compliance Areas in the preparation and revi ew of agreements and terms, pursuant to this Policy
• Support the Compliance Areas and/or DRCA in cases of Red Flags , intera cting with the DRCA if ther e are doubts
• Immediately inform the Compliance Area o f the Business , the DRCA and the Holding L egal Department any notifica tion , subpoena , letter and other documents issued by the prop e r authorities in connection with the object of this Policy , in addition to any operation or investiga tion conducted by proper bodies – inclu ding bo d ie s of control and inspection or police authority , involving the Business , [ Partners , Employees , Business Partners or External Representatives of Ultra Group ]
• Allow the Holding L egal Department free access to all facts, data , documents and information necess ary to the corre c t understanding and evaluation o f the cas e

• The Legal Areas of the Business shoul d align with the Holding L egal Department the adequate defini tion of s trat egies and intera ction with the lawyers hired for cases rela ted to this Policy

• ANTI-CORRUPTION GUIDELINES FOR CONTRACTING TRANSACTIONS AND BUSINESS

5.1. EXTERNAL REPRESENTATIVES , BUSINESS PARTNERS , SUPPLIERS AND SERVICE PROVIDERS

The action s of External Representatives , Business Partners , Suppliers and Service Providers may pose risks t o Ultra Group , since Ultra Group , it s Partners and Employees may be held liable for these actions , even when they were not aware of or aut h oriz e d these action s .

The actions prohibited by this Policy cannot be performed by Ultra Group , it s Partners or Employees ne ither directly or in directly , through individuals or externa l legal entitie s , which are External Representatives , Business Partners , Suppliers or Service providers .

The sub contracting of Public Officials by External Representatives , Business Partners , Suppliers and Service Providers of Ultra Group is forbidden, except if previously and formal ly approved by the Compliance Area , when there is no conflict of interest , and a fter realiza tion of Background Check and an alysis made by the Business Legal Department or by the Holding L egal Department , as appropriate .

5.2. DILIGENCE FOR CONTRACTING EXTERNAL REPRESENTATIVES , BUSINESS PARTNERS , SUPPLIERS AND SERVICE PROVIDERS

The contra c t ing of External Representatives , Business Partners , Suppliers and Service Providers must be preced e d by a Background Check . The formaliza tion of the co m mercial relationship , e ither through agreement , proposa l , term or o therwise, should contain anticorruption clause pursuant to this Policy . The Background Check m ay also be conducted in customers in order to meet specific legislation .

If Red Flags a re identified in the Background Check , the respectiv e Compliance Area shall be consult e d, before the relationship with the External Representative , Business Partner , Supplier or Service Provider i s formal ly agreed or continu e d .

The minimal requirements to be assessed in the Background Check , as well as procedure s fo r classifica tion of critic al i ty , ren ewal and vali dity should follow the criteria established by the DRCA to the responsible areas .

5.3. CONTRACTING FORMER PUBLIC OFFICIALS

Every contracting of Former Public Officials by Ultra Group should meet the following criteria :

• No t be pro h ibi te d by law or executive act
• Respe ct all period s of legal or regula tory quarantine, when applicable
• A ssess , e ven when not prohibited , if it may caus e negativ e perception or be considered as conflict of interests
• No t aim the obtaining of Inside Information , for own benefit or for benefit of third parties , obt a i ne d a s a result of th e activities exerci se d by Former Public Officials
• Be submitted for analysis by the Compliance Areas on any conflicts of interests
• No t present any Red Flag after the Background Check
• Be previ ously a p prov e d by the respectiv e Business Legal Department or Holding Company

The guidelines for contracting Former Public Officials should , also , b e observ e d i n the process o f contracting of legal entities whose partners , managers or officers are Former Public Officials . These guidelines also apply when the activity obje c t o f the contracting i s performed directly by Former Public Officials .

5.4. CONTRACTING PUBLIC OFFICIALS

Every contracting of Public Officials by Ultra Group should meet the following criteria :

• Not be prohibited by law or executive act
• Even when not prohibited , b e preced ed by evaluation to check if it may cause negative perception or be considered as conflict of interests
• No t permit the obtaining of Inside Information , for own benefit or for benefit of third parties, as a result of the activities exercised by the Public Officer
• The position or function exerci se d by the Public Officer is not incompatible with his working hours or activities
• There is n o rela tion between activities exerci se d by the Public Officer and those exercised by the areas of operation of the Business
• No favoritism in the contracting o f the Public Officer
• B e subm itted to analysis by the Compliance Area before contracting
• N o t present any Red Flag after the Background Check
• Be approved by the respective Business Legal Department or Holding Company before the contracting

Every contra c t ing of Public Officials should be formaliz e d by contra c t, cont aining cl e arly the purpose of the agreement , compensation and anticorruption clause pursuant to this Policy .

The guidelines for contracting Public Officials should , also , be observed in the process of contracting of legal entities whose partners, managers or officers are Public Officials . These guidelines also apply when the activity object of the contracting is performed directly by the Public Official .

5.5. CORPORATE TRANSACTIONS AND CONSORTIUM

Ultra Group is commit te d t o conducting a proper and reasonable due diligence in process e s involving corporate transactions ( for instance, mergers and a c quisi tion s) and formation of consortium and associations in order to verif y any irregulari ti es or illegal actions, for the purposes of this Policy , by the legal entities i nvolv ed .

Accordingly, prior to any transa ction, the Business area respons ible for the process and the Business Legal Department , if involved in the process, shoul d meet with th e Holding L egal Department and the DRCA in order to defin e the sc o pe of the due diligence process that will analyze Compliance issues . This analysis should also be coord i na te d with the M&A Board of Executive Officers of the Holding Company and precede any opera tion of that nature carried out by Ultra Group .

5.6. ANTICORRUPTION CLAUSE

All and any instrument o f contracting o f the Business and of the Holding Company should contain clause that assures and pr ovides for th e compliance , by the counterparty , with guidelines s e t out in this Policy and in our Code of Ethics , and with all and any applicable anticorruption law and regulation .

This clause should pr ovide fo r the possibili ty of automatic contra c tual rescission in case of noncomp liance .

1. FURTHER ANTICORRUPTIO N GUIDELINES FOR BUSINESS

6.1. ASSOCIATIONS, CLASS ENTITIES AND OTHER REPRESENTATIVE ENTITIES

Associations, class entities and other representative entities have important rol e i n the socie ty, as they have right to peti tion , efficiently and legally defend ing and represent ing legitimate interest s, in their respectiv e se c tors of representa tion .

It is forbidden , from every aspect , to use those entities to obtain Undue Advantage s . A legal and transparent relationship with associations and class entities should follow the guidelines below :

• The affiliation shall be formaliz ed in agreement or similar term o f association , with goals and co u nt e rparts clearly defin ed
• Ordinary p ayments should be stated in the term of ass ociation a s monthly fee, monthly or annual contribu tion s or the like
• When there are extraordinary payments , t h e y should :
• b e revi ewed by the Board of Executive Officers o f the Business before approval
• b e preced ed by descriptive term si g n e d , bound to the term of ass ociation , de scribing the goal , destina tion , instruments of rendering of accounts and cont aining anticorruption clause
• b e listed in the descriptive term o f the proje c t, when i nvolv ing External Representatives of any nature , such as consult ant s, lawyer s, a dvisor s, among other subcontra c t ed partie s
• Prohibition of direct payments on behalf of and for the account of subcontracted parties , t o entities al ien to the term of ass ociation or t o the descriptive term of extraordin ary projects , and such payments s hould b e ma de solely to the affiliated entity
• All payments should be accounted for in specific account of easy identifica tion for control

Every Business should ensure that the rela tionship with associations and class entities is based on transparency and on legitimate and legal interest s.

6.2. DONATIONS AND POLITICAL CONTRIBUTIONS

This Policy prohibits Ultra Group to make any donation or political contribu tion , directly or indirectly – in cash or the equivalent, produ c t or service - to any political part y or to candidat e t o political office .

This Policy does no t aim to prevent Employees from particip ating in the political process or from making personal donations or political contributions , following their own convic tion s. However, these convictions , donations or political contributions cannot be rela ted to Ultra Group .

6.3. DONATIONS AND SPONSORSHIPS

In view of its social responsibilities (either philanthropic, cultural, academic , sports, environmental, among other), Ultra Group may authorize donations and sponsorships t o the public or priva te sector , and in all hypotheses, the guidelines of this Policy shall be observed .

Donations and sponsorships should observ e the guidelines below :

• No actual or apparent conflict of interests
• The beneficiary shall be a public or private entity , being prohibited donations or sponsorships to individuals
• The beneficiary , as well as indiv idual s or other related entities should hav e been object of Background Check . This guideline also ap p li es to sponsorships where there is contracting of External Representatives for performance of a project .
• All donations or sponsorships should b e a p prov e d acc o rding to the grant s of authority defin ed i n the Holding Company and/or i n the Business and formalize d thr o ugh written agreement or term, which should clearly and accurately descr ib e the destina tion of the goods or re source s ( as appropriate ), benefi t solely the beneficiary , cont ain th e mandato r y rendering o f accounts by the beneficiary and cont ain anticorruption clause pursuant to this Policy .

The provisions of this section also a p pl y to sponsorships , including , without limita tio n , Rouanet Law and Sports Incentiv e Law .

6.4. TRAVEL, ENTERTAINMENT AND HOSPITALITY

The payment or reimbursement of expenses , i nvolv ing Public or Priva te Officials , related to travels , hospitali ty , meals , as well as invitation to a ttend corporat e events or le cture s will only be permi t t e d when :

• C omplies with applicable laws and regulations
• Is made o n good faith, without expectati on of return
• Is clearly related to leg a l and leg itimate action s i n the best interest of the Business
• Refers to direct payment to supplier and never involves direct or indirect payment to Public or Private Officer
• Does not involve disbursement or reimbursement to family members or friends of Public or Private Officer , inclu ding costing through gift coupons or prepaid vouchers
• D oes not represent frequent or daily payments of expenses to the same person
• For hospitali ty ( meals , lodging , air ticket s etc.), it should be propor tionate to average and reasonable standards, according to policies adopted by the Holding Company and/or by the Business
• The circu m st ance s i nvolv ed cannot be considered a s actual or apparent conflict of interests , ne ither cause the percep tion of Undue Advantage

It will be incumbent on the Compliance Areas and respectiv e Boards of Executive Officers to establish and ma i nt ain system of grants of authority and financial and accounting controls that allow to ident ify and trace disbursement s related to these expenses .

6.5. OFFER OR DELIVERY OF CORPORATE GIFTS

Corporate gifts cannot seek the interfer ence in Public or Private Officer ’s decision . The delivery or offer of corporate gifts should have a clear and transparent purpos e, which should be reasonable and proportionate , preserv ing the impar t iali ty of the rela tion s and the reputation and image of Ultra Group .

C orporate gifts should :

• Comply with Ultra Group’s Code of Ethics, applicable laws and regulations
• Be cl early related to institutional marketing actions
• No t have co m mercial value , that is, they should b e institu t iona l g i ft s (exa mpl e s: pen s, T-shirt s, institu tional book s)
• A re duly reported to the immediate manager

The offer of corporate gifts pro h ibi ts :

• T ransaction in cash or similar ( for example , gift coupon ), i rrespective of value
• Gift aimed t o influenc e act or decis ion o f the Public or Private Official

• At t i t ude that can be considered as actual or apparent conflict of interests

• GUIDELINES FOR RELATIONSHIPS WITH PUBLIC OFFICIALS

7.1. RELATIONSHIPS WITH PUBLIC OFFICIALS

The relationship with Public Officials should represent the interest s of Ultra Group , based on transpar ency , legali ty and legitimacy , and may occur in many contexts:

Daily Opera tion al – contact with a Public Officer as part of a daily operational activity . A few nonexhaustive examples : counter contacts at public agencies , customs clearance , inspections at highways , obt ain form s or certi ficate s, notary office transa ction s .

Specific – contact with Public Officials through representatives of a de fined process. A few nonexhaustive examples : bidding , i n s pection s, tax assessments , tax discuss ion s, obtain licenses or permit s, obt ain tax incentiv e s, nego tiate conduct adjustment agreements .

Institut ional – contact with Public Officials through interlocutors of regulat ory, governmental or specialized themes . A few nonexhaustive examples : regula tion , legislation , sectorial discuss ion s.

I ntera ction s with Public Officials should respe ct this Policy and the applicable laws and standards .

Specifically in relation to the institutional or specific contacts, the formal scheduling and the preparation of the meeting reports, previous comments, minutes or equivalent annotations are advisable to facilitate the recovery of the history of these contacts.

R elationship s with Public Officials should be made by person s qualified and trained pursuant to this Policy and the principle s o f the Code of Ethics of Ultra Group and should occur in professional environment s at business hours, prefer ably with the participa tion of more than one representative of Ultra Group . In the event of personal or social contacts with Public Officials , professional issues of Ultra Group ’s interest shall be avoided. C om m unica tion s with Public Officials should be made only through corporate communication mean s.

If Public or Priva te Officials request payments or Undue Advantage s in violation of this Policy , they must be immediately, expressly and clearly rejec t ed and the fact should be promptly co m munica te d t o the DRCA or t o the Ultra Group ’s Open Channel .

7.2. RELATIONSHIP AIMING DISCUSSION OF LEGAL OR REGULATORY RULES

Whenever it is in the interest of Ultra Group to discu ss the edi tion or review of legal or regula tory standard, either with the Executive , Legislativ e or Judici ary Branch , or with administrativ e authority , or with public company or mixed-economy company, the positions and intentions of Ultra Group should be stated in writing and on their own b e half, before duly authorized internal agents , e ven when using External Representatives services upon their preparation and disclosure .

When Ultra Group uses a union , association , class entity or other ent iti es of representa tion to which it is a part, the positions and intentions of Ultra Group should be stated to th a t body following the same requirements mentioned above .

N o payment of advisory service in the interaction aiming at discuss ing legal or regula tory standard can have a value or scope incompat ible with the provision of services , which could cause a percep tion that such value is intended to influenc e the edition , cancellation or change of th a t standard, being forbidden payment of success fee .

7.3. BID DING AND AGREEMENTS WITH THE PUBLIC ADMINISTRATION

The participation in public bidding processes must comply with the guidelines of the Bidding and Administrative Agreements Law (as provided in the Chapter 13 hereof) and further applicable legislations.

When taking part in a public bidding process, the Partners or Employees of Ultra Group as well as external individuals and legal entities acting on behalf or according to the interests of Ultra Group shall comply with the following:

• not offering an Undue Advantage , directly or indirectly, to a Public Officer or a third party related to it
• not simulating competition with other companies
• not aiding preparing the bidding documentation as it is the responsibility of the contracting body. This aid also includes comments to the drafts of the tender document (except concerning public consultation), basic designs, technical studies, reasons for dismissal, non-requirement of bid tender, adhesion to the register of price records or any informed purchase
• respecting the competitive tendering
• providing accurate information to current and potential customers about the products and services of Ultra Group
• only when necessary, sharing technical documentation with current or potential customers through a corporate email or by using cloud platforms made available by Ultra Group
• offering and selling to the current and potential customers only products and services of Ultra Group that really meet their actual needs

The Employees, External Representatives and Business Partners of Ultra Group are the ones responsible for taking part in the public bidding, seeking new agreements or maintaining those already existing with the public administration as they have already undertaken training about the best practices and relations with Public Officials .

All the bidding processes or agreements entered with Public Officials must be registered and controlled by the Compliance Areas jointly with the respective Legal Areas and other applicable areas of the Business.

While dealing with Public Officials in all the government spheres (federal, state and municipal), it is prohibited to undertake any illegal, unethical or immoral conduct, including but not limited to:

• H amper or violate, through adjustment, combination , abstention or otherwise, the competitive nature, or prevent, impact or violate the performance of any act related to the public bidding process
• Remove or seek to remove any offeror, by means of fraud or offer of any type of advantage
• Create, by means of fraud or unlawful means, legal entity to participate in the public bidding procedure or enter into an administrative agreement
• O btain any unfair benefit, by means of fraud, from the amendments to the extensions of the agreements entered into with the public administration, not authorized by law, in the invitation to the public bidding process or in the respective contractual instruments .
• Manipulate or defraud the economic-financial balance of agreements entered into with government authorities.

7.4. KIN RELATIONSHIPS WITH PUBLIC OFFICIALS

The Employees must inform the Compliance Area about any kinship or friendship with Public Officials whenever such condition may represent a conflict or potential conflict, either actual or potential , or if it risks any transaction undertaken by Ultra Group and its Business or even its reputation.

The Compliance Area must assess whether such kinship represents an actual or potential risk, guiding its Employees and making decisions, such as replacing the Employee involved in the conflicting transaction or cancelling said transaction, among other possible measures so that the kinship does not result in an actual or potential conflict of interests or risk to the reputation of the Ultra Group.

Likewise, any Partner, External Representative or Business Partner must inform about this condition to the highest hierarchical level who works as their contact in the Ultra Group. Said contact must decide on whether or not the transaction shall be given a go and on retaining or replacing said Partner, External Representative or Business Partner in the transaction.

1. PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM

Ultra Group is committed to adopt measures to mitigate the risks of being associated with operations involved in Money Laundering and Financing of Terrorism.

In order to fight the corruption and the money laundering, Ultra Group must ensure that:

• a Background Check with External Representatives, Business Partners, Suppliers and Service Providers be made under the terms hereof
• the commercial conditions follow the market practices
• the registration and identi fication of the customers are maintained
• every business conducted has been duly formalized and the agreed conditions have been recorded
• there is proof that the products were delivered/received and/or that the services were rendered
• the billing data meets the related negotiation data, which one may find on the orders or agreements entered
• the transactions made are pursuant to the Corporate Policies of Ultra Group and the applicable legislation

• eventual commercial or financial discounts, commissions, bonus and rewards granted for a justified reason, providing the tracking and rationale of the calculation, all according to the approval and monitoring controls for the areas

• TRAINING

DRCA , jointly with the Compliance Areas and the Holding L egal Department, must set the periodicity and content of the anticorruption training to be applied in Ultra Group. E very Employee must take part in said recurrent training. The Compliance Areas of the Business must ensure that their essential Employees, External Representatives and Business Partners take part in the training about the subjects provided in this Policy.

1. RECORDS AND CONTROLS

10.1. ACCOUNTING AND FINANCIAL RECORDS

Ultra Group must maintain the accounting books and records with the due supporting documentation to fully and accurately reflect all its transactions.

All and any financial transaction must be entered with accuracy and timel iness with sufficient data to inform the reality of the accounting records of Ultra Group and allow any party of interest to track all the payments made.

All the accounts of Ultra Group must be informed in its books and accounting records.

10.2. INTERNAL AND FINANCIAL CONTROLS

Ultra Group must maintain internal controls to ensure the prompt preparation and the reliability of financial reports and statements.

This Policy will be regularly monitored by DRCA . The Compliance Areas must maintain the procedures required to ensure the compliance with the provisions hereof to stop and avoid any tort in its activities and business, such as errors, omissions , distortions and frauds in its accounting and tax practices, reports, notices to the market and other documents.

1. ULTRA OPEN CHANNEL

Ultra Group provides the Open Channel so that any external or internal person can clarify questions or report suspected violations of this Policy, as well as the Code of Ethics, other policies and internal rules, and the applicable legislation.

Telephone

0800 701 7172

Webs ite

www.canalabertoultra.com.br

Complaints or requests for guidance can be made anonymously, in order to protect the identity of the person who submitted them. It is prohibited to threat, intimidate or retaliate anyone who:

i. reports any breaches to this Policy or any other internal policy or rule or applicable legislation to the Ultra Group, and/or

ii. state any doubts, suspicions or worries concerning the subject

The Channel is maintained by an independent company and every report is independently and diligently assessed.

1. SANCTIONS

Ultra Group must maintain controls and constantly monitor itself in order to stop and avoid any misconduct towards the principles and guidelines set herein.

Any potential breach or failure to comply with the provisions hereof will be assessed by DRCA .

Besides the potential of resulting in great losses to Ultra Group, the failure to comply with the Anticorruption Laws may lead the breaching party to face criminal, civil and administrative penalties enforced by the authorities. Furthermore, the breaching party may face disciplinary measures as well, based on the applicable legislation, including verbal or formal warning, suspension and financial sanction. It may also lead to the breaching party being justifiably dismissed without prejudice to the adoption of further legal measures applicable.

1. DOCUMENTS AND RULES RELATED

Besides this Policy, the issues provided herein are also the subject matter of the following guidelines and rules, which must also be complied with by anyone subject to this Policy:

• The Ultra Group Code of Ethics and other Ultra Group Corporate Policies, as applicable
• Law No. 12.846/2013 (Anticorruption Law)
• Decree No. 8.420/2015
• Administrative Misconduct Law – No. 8.429/1992
• Conflicts of Interest Law – No. 12.813/2013
• Bidding and Administrative Agreements Law – No. 8.666/1993 and No. 14.133/2021)
• Brazilian Criminal Code and other Brazilian criminal laws
• Federal Administration Code of Conduct
• United States Foreign Corrupt Practices Act (FCPA)

Ultra Group may be subject to the laws and regulations applicable and in force in the places it also operates.

EXHIBIT I – GLOSSARY

For the purposes of this Policy:

• “Private Officer ”: any manager or Employee who directly or indirectly represents a legal entity of private law.

• “Public Official ”: for the purposes of this Policy, any Brazilian or foreigner person who is part of the structure of any of the three branches, state government or foreign government or a third party related to said institutions by means of election, appointment, contracting or any other kind of investiture or related to, with powers, holding a position, being employed or undertaking any duties in the direct or indirect administration, vested with powers to represent a public body, be it an employee, manager, holder of a position or candidate to an elective position or from a political party. It may also define whoever temporarily or without compensation holds a position, is employed or undertakes any public duties in bodies, regulatory agencies and government entities (including state banks and companies, sovereign wealth funds and public universities) or any person working with the diplomatic representation of Brazil or any other foreign country as well in legal entities directly or indirectly controlled by the Brazilian or foreign government or even in Brazilian or international public organizations (including but not limited to UN, World Bank or IMF). The Public Official also means any person acting as an officer before the abovementioned entities, including the private advisor that also holds a position, acts on behalf of a governmental body or with a public international organization, or with a company owned or controlled by a governmental body. It includes all the candidates for public office as well as political parties. A “Public Official ” is also a candidate for public office.

• “ Business Legal Department(s) ”: legal areas of each Ultra’s Business .

• “ Compliance Area(s) ”: Business Compliance Area(s) , to support the execution of the Ultra Group’s Compliance and Ethics Program , with functional report to Risk, Compliance and Audit Department .

• “Open Channel” or “Ultra Open Channel”: Ultra Group's institutional channel to clarify any doubts and worries, requests for guidance and to receive any complaints. The anonymity is guaranteed. The channel is managed by a specialized company contracted by Ultra Group.

• “Code of Ethics”: Code of Ethics of Ultra Group.

• “Employee(s)”: member(s) of the Board of Executive Officers, the Board of Directors and the ir Committees, Advisory Councils, Fiscal Council, full-time and part-time employee(s), intern(s) (as per the Internship Law – Law 11.788/2008) and young apprentice(s) (as per the Apprenticeship Law 10.097/2000).

• “Board of Directors”: The Board of Directors of Ultrapar.

• “ Board of Executive Officers ”: each of the Boards of Executive Officers of the Business or Holding, as applicable

• “ Holding L egal Department ”: Ultrapar’s Legal Department

• “R isk, Compliance and Audit Department ” or “ DRCA ”: Ultrapar’s Risk, Compliance and Audit Department , responsible for managing Ultra’s Compliance and Ethics Program and reporting to the Board of Directors, through the Conduct Committee.

• “ Former Public Officials ”: whoever has been a Public Official in the last 5 (five) years.

• “Financing of Terrorism”: directly or indirectly providing financial support with the intent of being entirely or partially used — or knowing beforehand that they will be used — by terrorist groups for terrorist acts.

• “Supplier(s) and Service Provider(s)”: suppliers and service providers (except for those service providers already included in the definition “External Representative(s)”).

• “Ultra Group”: Ultrapar and its subsidiaries in Brazil and abroad.

• “Inside Information”: the one concerning secret or pertaining subjects related to the decision-making process undertaken by the Executive, Legislative or Judiciary Branch and that has an economic or financial consequences and that has not been disclosed to the general public.

• “ Money L aundering ”: money laundry crime is typified in Brazil as the concealment or disguise of nature, origin, location, arrangement, operation, or ownership of assets, rights or values arising, directly or indirectly, from a criminal offense.

• “ Anticorruption Laws ”: are the laws and regulations set forth in Chapter 13 of this Policy.

• “ Business ”: corporations directly or indirectly controlled, in Brazil and abroad, by Ultra Group.

• “ Business Partners ”: distributors, resellers and sales representatives .

• “ Policy ”: Corporate Policy Anticorruption and of Relationship with the Public and Private Sector of Ultra Group .

• “ Background Check ”: a combination of survey and research in public databases as well as questionnaires to identify any kind of reputational history that may represent a risk to Ultra Group or expose it.

• " Red Flags ": any fact or circumstance that indicates or suggests any act of corruption or violation of this Policy.

• “ Partner (s) ”: Ultra Group shareholder(s) who may come to speak in Ultra Group’s name .

• “External Representative(s)”: means the individual(s) or entity(ies) representing the interests or acting on behalf of the Ultra Group, regardless of any proxy or agreement, including, but not limited to, advisors, consultants, accountants, intermediary parties, lawyers and brokers, among others.

• “Influence Peddling”: requesting, demanding, charging or obtaining for itself or for another party an advantage or promise of advantage to influence how a public officer acts while undertaking their duties.

• “Ultrapar” o r “Holding” : Ultrapar Participações S.A., publicly traded corporation .

• “ Undue Advantage(s)”: advantage not supported by a legal or regulatory provision that could authorized the interested party or advantage promised or granted in order to convince the Public or Private Officer to do something or refraining from doing anything, representing a breach of their duties or trustiness for the position. As it is a wide term, the Undue Advantage may include any item (tangible or intangible asset) with an equity value or not, including but not limited to cash, gifts, travel, hospitality, entertainment, donations, among others, with the purpose of influencing the actions of P ublic or P rivate Officials .

CODE OF ETHICS

Mes sage from the leadership

Over 80 years we have built one of the largest corporation s o f B razil , always observing ethics and transparency in the search for our goals, developing our interna l and externa l relations with integri ty and respe c t, and contribu t in g t o the growth and well-being of our co m muni ti es.

Aiming at ma i nt aining our credibili ty , reputation and continu ing to be successful in our business , we must have this Code of Ethics as base to all of our decisions and a ction s. All the individuals of the Company are not only responsible for their own actions, but for promo ting a cultur e in conformi ty with our Code of Ethics and applicable laws .

In this new review , our Code of Ethics reaf firms the reli a bility on our employees , partners , suppliers , customers and external representatives to ma k e correct decisions in view of ethical dilem m as that could arise from our activities . Herein you will find guidelines and instructions that will support you in choosing the correct path to follow .

Our Open Channel is also accessible, at any time , to clear doubts and recei v e su g gest ion s or re port s, inclu ding anonymously, of viola tions of the Company ’s Policies and applicable legislation .

Thank you for helping to build the futur e o f Ultra. We rely on you to ensure the integri ty of our Company in all daily activities and at t itudes.

Chairman of the Board of Directors

Ultrapar CEO

INTRODUCTION

Ultra Group is committed to ethics , integri ty and transparency in all its business es and at all levels of relationship . The responsibility for the compliance is shared among everyone, including Senior Management , irrespective of position or fun ction .

The Code of Ethics (“ Code ”) is p u blic and ac c ess ible by any person or company , regardless of the type of relationship with Ultra Group and its Business . It ap p li es to a ll m anage rs and employees o f Ultra Group , without e xceptions , i n B razil and abroad . The adherence to the Code is mandatory and formalize d by the acceptance agreement .

The provisions of this Code shall also guide the conduct of all external representatives , business partners , customers , suppliers and service providers o f Ultra Group , as well as of any individual or legal entity operating in the direct or indirect interes t or benefit of Ultra Group or any of its subsidiaries .

Along the Code , we will present conduct recommendations on Laws and Internal Policies , as well as information about ac c ess t o the channels in order to clear doubts or report situa tion s that run counter to the guidelines of this Code of Ethics .

Ultra Group o f fer s training o n the Code of Ethics and the Compliance Program . Each person is responsible for di sclosing and multipl y i ng the content of this Code , foment ing the ethical and integrity cultur e of Ultra Group .

To learn more about the themes addressed by the Code of Ethics and the Ethic and Compliance Program of Ultra Group , or if you need guidance in connection with any theme or situation , please contact the Open Channel or your Compliance area .

ETHICS IN MANAGEMENT

EQUITY AND DIVERSITY

• We treat all of our relationship public on fair and equita ble m a nner and we disapprove all and any a c t o f discrimina tion or undue favor itism to any pe rson or company .

• We encourage diversi ty and we do no t toler a te , under no circumstance, discrimina tion or pre judice of any nature , e ither of gender , ra ce , religi on , age , political convic tion , marital status , sexual orientation , handicap , place of birth , social class, am o ng other .

TRANSPARENCY AND RESPONSIBILITY

• We a do p t procedure s that ensure that our public will be duly informe d ab o ut relevant aspect s of our activities , so that our communications and information are true, clear , a ppropriate and timely .

• We are concerned about the consequences o f our a c ts, weighing the effects of our a ction s on the socie ty , external representatives and ourselves before proceeding .

C OMPLIANCE WITH LAWS

• We comply with all laws and regulation s o f the countries where we o perate .

• We do not tolera te corrup tion, fraud s in bidding processes and public agreement s, anti-competitive practices and any o ther illegal conduct , including , without limita tion, those provided for in the Anticorruption Law , Criminal Legisla tion , Improbi ty Law , Competition Law , Bidding Law and the U.S. Foreign Corrupt Practices Act .

• We adopt risk management processes , internal controls , inclu ding financ ial and accounting , audit, information security and anticorruption and co mpetitive controls , in tended to monitor the compliance with standards and p reven t and c urb illegal acts ( such as corrup tion , bribery, fraud , influence peddling , undue exchange of favors and money laundering ).

SUSTAINABLE DEVELOPMENT AND HSE – Health, Safety and Environment

• W e are aware o f the poss ible environmental impact o f our business . A ccordingly , we c arry o ut our business with responsibility and integrity, always committed to the sustainable and rat ional use of natural re s ources .

• We develop mec hanism s that maximize energy efficiency and contribu te to the sustainable development o f our business and the regions where we operate .

• Any environmental impacts of our activities are monitor e d thr o ugh integrated management policies , processes and systems of HSE – Health, Safety and Environment .

• We operate with transparen cy and social inclusi o n in the regions where the business activities of Ultra Group are carried out , through community relationship programs , promo ting development i n the areas surrounding our operations .

• We seek sustainable enga ge ment in all the business of Ultra Group , systematically reviewing our activities , investin g in sustainable improvements and ado pting measures aligned with the Environmental, Social and Governance - E SG practices .

ETHICS IN RELATIONSHIPS

SHAREHOLDERS AND INVESTORS

• We adopt policies and practices that promo t e alignment between the interest s o f our shareholders , investors and administrators and the interest s of Ultra Group .

• We m onitor the occurrence of any conflicts of interest s and tr e a t t he m with obje c tivi ty , soundness and impar t iali ty , in line with our Corporate Policy of Conflict of Interest s and Related-Party Transactions .

• We follow the Corporate Policy Material Notice Disclosure Policy and Securities Trading Policy , which sets out rules for disclosure of our information t o the market and procedure s to prevent the use of information no t disclosed to the public f o r own benefit in the trading of securities .

• We adopt appropriate and transparent daily communication practices with analy sts, investors and other stakeholder s, seeking to keep them inform e d o f our activities , business and results.

E MPLOYEES

• We adopt policies and practices aimed at providing to our employees dignified , healthy and motivating work conditions, free from embarrassment s and any t ype of prejudice or disc rimina tion. This conduct shall also apply to the public with which we relate .

• We r espe ct the human rights and promote a work environment of divers ity and inclusio n and we do not tolerate any type of pre judice or discrimina tion , either of race, gender, religion, age, marital status, sexual orientation , place of birth, political conviction, social class or handicap .

• We promote the human and prof e ssional development of our employees . We encourage and promote the individuals b as ed on their performance , qualifica tion and behavior in line with the interest s and princ iple s of the organization, pursuant t o criteria of assessment, requirements of the position and equal op p ortuni ti es .

• We respect the right t o free union association and we c omply with union conventions and collective agreements .

• We respect the freedom of associa tion with socia l and pol itical movements or with other entities , provided that they do not conflict with their jobs and observe the current laws .

• We encourage diversi ty in our re lationship s, act ively promo ting the right to difference and contribu ting to an environment where people may act in conformity with their individua l value s, without prejudice to the values of Ultra Group .

• We adopt actions of prevention and fight against any t ype of di srespe c t, harassment , o f fens e , prejudice or d iscrimination and we do not tolera te this kind of actions . All the employees shoul d assume the com mitment to prevent and avoid this kind of behavior . We encourage employees to report these situations to the Open Channel .

• Likewise, we do not tolerate , i n Ultra Group and in our scope of operation, and we adopt practices to prevent and fight every form of undignified labor , such as forced labor, child labor, slavery or analogous to slavery .

• We maintain an exce l lent image of the company in the real and virtual world . A ccordingly , all the employees should adopt a conduct that does not run counter the values and reputation of Ultra Group , even outside the working hours and/or work environment .

CUSTOMERS AND CONSUMERS

• Our purpose is to identif y and cover the needs and interest s of our customers and consumers .

• We adopt practices of identifica tion of the needs , expectati on s and opini on s of our customers and consumers aiming at the improvement of our product s and services .

• We seek to maintain ethical , transparent, integral and long-lasting relationships with our customers and consumers .

• We do not adopt any marketing, publici ty or sales strategy that might deceive our customers or consumers in relation to the quali ty, purpose and pr ic e of our product s or services .

• The practice of illegal or unethical acts is not accepted .

EXTERNAL REPRESENTATIVES

• We seek to ensure that third parties that represent or act on behalf of Ultra Group d o it respecting our values , Corporate Policies and governance practices .

• We do not use external representatives to dis simula te illegal or unethical practices .

• We do not hire or ma i nt ain re lationship s with external representatives presenting conducts or behaviors that run counter to the principle s of this Code .

BUSINESS PARTNERS ( DISTRIBUTORS , RESELLERS AND COMMERCIAL REPRESENTATIVES )

• We seek to ensure in our partnership s the continui ty of our values and business practices .

• We seek to ensure that our partners will follow the principle s of this Code and of our Corporate Policies , reflecting on sustainabl e ba s is the way we carry out our business .

• We did not start neither maintain relationship with partners presenting conducts or behaviors that run counter to the principles of this Code .

• We seek in our partners a good co m mercial practice , integri ty in the management of business and social and environmental commitment .

• We do not inter fere or close deals that may affect the independ ence of distributors or resellers , in compliance with the guidelines of the Corporate Competition Policy .

S UPPLIERS AND SERVICE CONTRACTORS

• We s elec t qualified suppliers and service providers which may properly meet the interest s of Ultra Group .

• The hiring of suppliers and service providers should consider solely the needs of Ultra Group , without conflict of interest s .

• We maintain selection policies and practices that e nsure transparent, impe r so n a l , technical , honest and fair processes for all the ones involved and, therefore, without improper favoritism of a supplier or service provider to the detriment o f others .

• We seek to ensure that our suppliers and service providers will follow the principle s of this Code and of our Corporate Policies .

• Our suppliers and service providers should carry out their business in conformity with the principle s of this Code and with applicable anticorruption , competition and environment protection laws .

• We do not tolerate any form of undignified or forced labor, child labor, slavery or analogous to slavery in our supply chain, or practices that caus e environm e ntal damages.

C OMPETITORS

• We adopt a Corporate Competition Policy , which sets out guidelines to curb conducts against the economic orde r in future co m mercia l practices and corporate relations . We are com mitted to protecting and preserv ing principle s that should govern the market , like free initiative, free competition and consumer defense, among other .

• We respect our competitors .

• We do not share information that might af f e c t free competition .

• We c ompet e on ethical basis and observing the competition and antitrust legisla tion. We do not form neither participa te in any t ype of cartel. We do not sign commercial agreements with competitors with the aim to combin e pr ic es, profit marg in , divid e customers or market s , or to r estrict or somehow impact competition .

• We do not accept that our professionals get i nvolv ed in anti-competitive practices .

MEDIA

• We maintain a relationship with the media based on impart iali ty and on tru e , clear, appropriate and timely information .

• Upon participa tion in virtua l commun i tie s or discuss ion forums , we seek to follow the guidelines of this Code , ado p t ing a n ethical and i n tegral conduct. We do not link the communications and personal opini on s made in such environment s t o Ultra Group and it s Business .

S OCIAL NETWORKS

• We do not discus s restricted or confiden tial matters of Ultra Group and its Business in social networks .

• We encourage ethical, safe and legal use of communication and intera ction technologies , inclu ding social networks . We reject the use of social networks , by our employees , to make offenses and perpetrate illegal and unethical acts , or acts that run counter to the conducts established in this Code of Ethics . We a lso recom m end discretion and good judgment in social networks , always intera cting with others on a legal and respe c t ful way .

• We strengthen the use of caution when posting on social networks and when posting unauthorized mess a ges or images about Ultra Group . A posting may be inadequa te or give rise to mis interpreta tion, i nvolv ing our brands and reputation , a f fe c t ing the value of Ultra Group .

• We care for sensitive personal data of employees , suppliers , customers and competitors , prote cting their privac y , and we do not make verbal or written declara tions that might affect their image or contribu te to the di ssemination of rumors involving them, who should always be treated with respect .

R ELATION WITH THE GOVERNMENT

• We adopt corporat e policies and practices to ensure that our relations , partnership s and business with public bodies , companies , employees and representatives , at all levels, are based on honesty , transparency and responsibility .

• W e manage our business without ideological or p olitical influence , and we promote an environment free from irregulari ti es .

• We do not offer or yield to improper requests or advantage s of any nature . The rules for relationship with the Public Power are descri bed in t he Corporate Anticorruption Policy and Relationship with the Public and Private Sector .

CLASS ENTITIES AND ASSOCIATIONS

• We recognize the import ance of the role of the entities and trade associa tions in the econom y and promo tion of discussion s i n the respectiv e se c tors of representa tion .

• We respect the autonom y of the entities and trade associa tions and we support their initiatives, always in compliance with the lega l and regulat ory principles of this Code and of our Corporate Policies .

WORK ENVIRONMENT ETHICS

PROFESSIONAL EXCELLENCE

• We perform our work with dedica tion and responsibility . We always seek to do our best .

• We have respect for a ll people, without any type of d iscrimination or prejudice .

• We learn from our mistakes and try our best not to repe a t them. We accept cr i ticism and try to learn from it .

• We give reasoned , respectful and professional opini on s and cr i tic ism s in the interest of Ultra Group .

• We care for tangible and intangible resources, inte l lectual property and premises of Ultra Group .

CONFLICTS OF INTEREST

• We follow the Corporate Policy for Conflict of Interest s and Related Party Transactions , which promo t e s transparency and independ ence in the relations hips betwe en Ultra Group and its related parties .

• We avoid situations that represent actual or apparent confli c ts between personal interest s and the interest s of Ultra Group , a cting on impartial, ethical and honest b a sis , and condu cting our professional activities in benefit of our Business .

• We seek to ensure that no improper advantage is directly or indirectly provided to our employees or to individuals from their family relations .

• We seek to ensure that related part y transactions will be carried out on equitable basis, without participa tion of the ones involved in the internal decision-making process of Ultra Group .

UNDUE ADVANTAGES OR BENEFITS

• We follow the Corporate Anticorruption Policy and Relationship with the Public and Private Sector and , accordingly , we do not tolerate that our employees or t hird parties perpetrate acts of corruption with public or private agents .

• We never promise, receive, request or accept improper advantages or benefits f or our activities , either in the public or private se c tor .

• We do n o t use confidential or insider information to obtain undue profit, for own benefit , or for benefit of third parties or external representatives .

• We do not ask neither accept, for own benefit or b e nefit of third parties , pa yment s, incentiv e s, financ ial or no t , or undue benefits of any nature from customers , business partners , suppliers , service providers or third parties to perform their activities at Ultra Group .

• We do not request jobs or benefits for relative s or friends in companies of customers , external representatives , business partners , suppliers or service providers .

PROTECTION OF THE COMPANY’S ASSETS AND RESOURCES

• We care for the integrity of goods and a sse ts of Ultra Group , and f or their responsible use, in order to prevent damages , misuse and waste of resources , as well as mis a ppropriation of goods and assets .

• Good s, equipment and premises of the companies of Ultra Group are destin ed solely for the performance of its business . W e care for the equipment and proper use of the assets of Ultra Group , inclu ding the ones provided for the performance of functions by the employees .

• We use corporate equipment for private affairs on modera te basis, not affecting the produ c tivi ty of the work, data security and provided that using common sense, within the legal boundaries, in compliance with ethical and moral principle s.

• Mobile devices , e-mails, corporate programs and systems , as well as the c o ntent contained or transited in the equipment and corporat e networks are the property of Ultra Group and may be monitor e d at its sole discreti o n .

• Under no circumstance do we share personal passwords of access t o equipment and/or systems .

• All files and information created, received, transit ed or f iled in the electronic systems of Ultra Group or in its corporate equipment are the property of Ultra Group and should be classifi ed and tr e at e d acc o rding to applicable s tandards. Management processes , proje c ts and product formulas are inte l lectua l propertie s of Ultra Group and should be tr e at e d as confiden tial, and cannot be shared without formal authorization .

INFORMATION SECURITY AND DATA PROTECTION

• We comply with Brazilian laws and standards on privac y and personal data protection , including the General Law on Personal Data Protection – LGPD.

• Due to the activities of Ultra Group , employees have access to a series of confidential information and documents , physical and ele ctronic. All and any information , including personal data and sensitive personal data , a nd documents rela ted to the a ctivities of Ultra Group , it s customers or poten tial customers should be tr e at e d on confiden t ial basis .

• We protect every information and document to which we have access and we do not disclose them to employees or third parties who do not need that information to perform their work . It is everyone’s duty to prevent unauthorized access to information , as well as accidental or illegal situations of destru ction , loss or change of information .

• We follow the Corporate Policy of Privac y and Personal Data Protection which implement s and direc ts to good practices and ensures proper tr e atment o f personal data by everyone .

• We respect the data privac y of our employees , customers , business partners , suppliers and service providers , as well as their right s over their data .

• We are aware that the mail received or sent through equipment and systems is the property of Ultra Group . Accordingly, Ultra Group reserv es the right to inspec t and monitor the use of information systems , as well as a c cess any file , document or mes sage that is filed and/or process e d in our technology environment .

GIFTS, ENTERTAINMENT AND HOSPITALITY

In our commercial relations , we avoid situations of actual or potential conflicts of interest . Accordingly, we do not accept any gift , present, ent ertainment or hospitali ty with the purpose to obtain any type of improper advantage . In addition :

• We do not accept or of f e r gifts or presents in kind or the equivalent .

• We do not accept invitation s or ticket s , exce p t f o r institu t iona l or sponsored events , of collective nature , and with prior consulta tion o f the immediate superior , who has the responsibility to assess the exist ence of a possible conflict of interest s . In case of doubt , please contact Ultra’s Compliance area or the Open Channel .

• We comply with all legal provisions on the theme .

PERSONAL RELATIONSHIP WITH CUSTOMERS , EXTERNAL REPRESENTATIVES , BUSINESS PARTNERS , SUPPLIERS AND SERVICE PROVIDERS

• We do not engage in private deals with customers , external representatives , business partners , suppliers or service providers , except for daily consumption relations , provided that there is formal communication t o the im mediate superior and the Compliance area ’s opinion .

• We do not request from customers , external representatives , business partners , suppliers or service providers any favors, re ward s or incentiv e s of any nature in order to generate personal benefits , for us or for external representatives .

MANAGEMENT OF THE CODE OF ETHICS

CONDUCT COMMITTEE

The Conduct Committee is a body related to the Board of Directors of Ultrapar , which consists of an independent and external President , as well as four Executives of Ultra Group , including the Risk, Compliance and Audit Board of Executive Officers (“DRCA”) . Thi s body , operationally supported by the DRCA , meets periodica lly with the following purposes, according to the intern al regulati o n :

• manage the application of the Code of Ethics, its guidelines and related policies
• supervise the application and effectiveness of the Code of Ethics principles
• review and approve the Compliance and Ethics Program and supervise its application, in order to ensure compliance
• propose and evaluate new policies associated with the Code of Ethics, as well as propose changes to it and the policies currently in force associated with it
• follow up investigations promoted by the DRCA
• recommend the appropriate disciplinary, administrative or judicial measures, related to a subject within its authority, to be adopted by Ultra Group’s bodies, as well as resolve on the need to report the matter to the Risk and Audit Committee or the Board of Directors of the Ultra Group for additional measures that may be applicable
• formally report the Committee’s resolutions to the Board of Directors in the most relevant cases
• forward to the Risk and Audit Committee and the Board of Directors annual reports describing their activities and those of the Ethics and Compliance Program, without prejudice to extraordinary reports, whenever necessary
• answer questions about the application or interpretation of the Code of Ethics provisions, the policies adopted by Ultra Group and, in the areas of its authority, the law and the Regulation

RISK, COMPLIANCE AND AUDIT DEPARTMENT

The DRCA is responsible for the following :

• Propo se and revi ew policies rela ted to the Program, as well as coord inat e their reco m menda tion by the Conduct Committee and respectiv e approval by the Board of Directors
• Guide and develop training topics for the Program
• Develop the Program’s corporate communication
• Manage Ultra Group’s Open Channel
• Condu ct and/or oversee the interna l investigation s at Ultra Group
• Support and reco m mend delibera tion s of consequ ence s
• Monitor the Program in all th e Business es of Ultra Group
• Represent Ultra Group institu t ional ly in the Compliance theme
• Follow up the development of the activities of the Compliance areas o f the Business es
• Propo se improvement of the Program

BUSINESS COMPLIANCE AREA

Business Compliance Areas are responsible for :

• Ensure the compliance with the guidelines o f the Program in the respective Business
• Implement and monitor the adherence to this Code in the Business
• Plan, develop , implement and execut e the Program and it s controls in line with th e guidelines of Ultra Group and the risks of its Business
• Ap ply and control the training
• Disclose the Program in the Business
• Ensure the conduction of Reputa tional Surveys according to this Corporate Anticorruption Policy and Relationship with the Public and Private Officers
• A ssist the Board of Executive Officers o f the Business with relevant Compliance aspects for decision making
• Evaluate the Program i n the Business
• Condu ct interna l investigation s i n the Business, as requested by and in coord i na tion with the DRCA
• Periodically r eport to the DRCA the evolu tion of the Program in the Business

OPEN CHANNEL

Ultra Group’s Open Channel is available to any external or internal perso n to clarify questions or report suspected violations of this Policy, as well as the Code of Ethics, other policies and internal rules, and the applicable legislation .

Telephone

0800 701 7172

Webs ite

www.canalabertoultra.com.br

Complaints or requests for guidance can be made anonymously, in order to protect the identity of the person who submitted them . It is forbidden to conduct any a c t o f threat , intimida tion or retalia tion to any person who :

i. r e ports viola tion s of this Code or of any o ther policy or interna l regulation , or legislation applicable t o Ultra Group , and/or

ii. reports doubts, suspicions or concerns in relation to this m a tter

The Channel is opera te d by independent company and all reports are checked with independence and dilig ence .

It is every employee s’ duty to immediately inform any susp icion of viola tion of this Policy , any other policies or procedure s of Ultra Group or applicable laws through the Open Channel .

VIOLATION OF THE CODE OF ETHICS

All the professionals of Ultra Group shoul d adhere to this Code of Ethics and to the respective guidelines and Policies , inclu ding the re port of any viola tions in the work environment . Any prof e ssional who viol at es the provisions of this Code of Ethics and the respective guidelines and Policies i n this document , or the principle s and standards of conduct adopted by them , is su bject to disciplinar y m e asure s such as:

• W arnings
• Suspension
• Sanctions, including financial penalty
• Dismissal
• Applicable legal measures

IN CASE OF DOUBT

This Code s e eks to estab lish the general guidelines on the values and expected behavior s of our p u blic . In case of doubt , please contact Ultra’s Compliance area or the Open Channel . The adoption of the Code of Ethics does no t e xhau s t the ethical themes and expected behavior s .

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Date: March 18, 2022

ULTRAPAR HOLDINGS INC.
By: /s/ Rodrigo de Almeida Pizzinatto
Name: Rodrigo de Almeida Pizzinatto
Title: Chief Financial and Investor Relations Officer

( Corporate policy on anti-corruption and the relationship with the public and private sector , Code of Ethics )