CODE OF CONDUCT Our principles and values into practice

Code of Conduct Our principles and values into practice

The Code of Conduct applies to

all companies controlled by Cosan.

COSAN4

Dear employees,

Cosan is a company that constantly seeks consistency and

balance between their goals and practices. Simply put, this

means seeking opportunities and doing business the right way:

operating in a responsible manner with integrity and ethical

standards.

Our Code of Conduct embodies these principles, which are

based on respect, ethics and transparency. Cosan is defi ning

how we expect our employees to do business and how we

work our credibility and reputation.

The Code represents our beliefs and how everyone should act

in everyday life. It addresses various situations of our day-to-day

actions involving the company’s stakeholders: employees, third

parties, suppliers and society in general.

Read, understand, practice and use this guide as a valuable

reference in your daily life!

Marcos Lutz

Chief Executive Offi cer of Cosan

5Code of Conduct

CONTENTS

1. Cosan’s business drivers ...................................................................................6

2. The Code of Conduct .......................................................................................7

2.1 What is the purpose? ...........................................................................................7

2.2 To whom does it apply? .....................................................................................7

2.3 How to report irregularities? ...........................................................................8

2.4 Channels available ...............................................................................................9

3. Work environment ...............................................................................................9

4. Conflict of interests ...........................................................................................10

4.1 Transactions between related parties ......................................................10

4.2 Hiring of relatives ................................................................................................11

4.3 Customers, partners and suppliers relations .........................................11

4.4 Offering or receiving gifts and presents ..................................................12

4.5 Political contributions and activities ..........................................................12

4.6 Use of corporate opportunities ...................................................................12

5. Disclosure of information ..............................................................................13

5.1 Disclosures of financial information .........................................................13

5.2 Communications on behalf of the company .......................................13

5.3 Social Media ........................................................................................................14

5.4 Negotiations with internal information ...................................................14

6. Compliance with laws, rules and regulations .......................................15

6.1 Anti-corruption laws ........................................................................................15

6.2 Antitrust laws .......................................................................................................15

6.3 Laws against forced labor and child labor .............................................16

6.4 Compliance and internal controls .............................................................16

7. Protection of internal information ..............................................................17

7.1 Classification of information ..........................................................................17

7.2 Treatment of confidential information .....................................................17

7.3 Intellectual Property ..........................................................................................17

7.4 Accuracy of financial records of the company ....................................18

8. Protection of company assets .....................................................................19

9. Environment, health, safety and community .......................................19

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1. COSAN’S BUSINESS DRIVERS

Our values determine and guide all decisions taken within the context of our business. Seven values describe our way of being and working:

Agility with discipline

We have a sense of urgency with continuity and method. We know how to use or change processes intelligently. We have the courage to act quickly, using the autonomy achieved.

Create opportunities

We are relentless in the pursuit of alternatives, we take decisions fast and appreciate the courage to take calculated risks. We are in constant motion. We encourage new ideas and do not cling to old paradigms. We believe in new points of view, understanding diversity as something that enriches us.

Develop the human potential

We train, we advise and we are always ready to learn from each other. We recognize when someone stands out. Our major goal is to prepare professionals for the future of Cosan and for life.

Delight and engage the customer

This means to see everything through the eyes of the customer. That’s how we can go further to offer the customer what he does not even know he needs.

Always do better

We seek a better way of doing everything. We overcome challenges and seek larger goals, but not at any cost.

Safety in all operations

We always make plans paying attention to risks, even if small. Each one of us must be the fi rst to follow safety procedures and to care for people.

7Code of Conduct

2.

2.1

2.2

Add to the team

We play together. We value collective results over individual results. To be a team player is a priority for us. We share knowledge. We teach and we are always ready to learn.

THE CODE OF CONDUCT

WHAT IS THE PURPOSE?

The Code of Conduct shows the corporate values of Cosan for all its employees and stakeholders so they can understand it and put it into practice in their daily lives. It should serve as a reference for individual and collective actions and decisions.

Although addressing a variety of practices and procedures, the rules contained herein do not exhaust all the questions that may arise, nor cover all situations that require ethical decisions, but point out the key principles that represent the policies and establish the working conditions in the company.

TO WHOM DOES IT APPLY?

The principles and guidelines of the code must be broadcast among all directors, offi cers, employees (whether contractors, temps, trainees or not, and regardless of their job title or position), customers, suppliers, partners and shareholders.

The code will be strictly observed and violations will be dealt with immediately, adopting the applicable disciplinary and corrective actions.

Actions in violation of the Code of Conduct, based on duly established and proven unlawful conduct, will be reported to

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2.3

the competent authority. Communications will be investigated and reported to the Board of Directors, if the severity so justify. All employees, offi cers and directors are encouraged to report possible violations immediately, even those committed in good faith, as they will not be excluded from the investigation process.

Retaliation motivated due to reporting of misconduct carried in good faith shall not be admitted. Everyone must cooperate with internal investigations that deal with unethical behavior.

An open communication about issues and concerns, without discriminatory acts, it is essential for the successful implementation of this code.

HOW TO REPORT IRREGULARITIES?

The Code indicates what the company expects of each professional in the different situations they might face, at work or not. Whenever you're unsure of how to proceed, see the Code. If you still have questions, consult your supervisor, Human Resources, Audit and Compliance department or the responsible for business control area.

If you do not feel comfortable to contact your manager or any of the aforementioned departments, report the situation or irregularity to the "Ethics Channel".

Unbiased and transparent, "the Ethics Channel" guarantees the confi dentiality of information, preserving the identity of the people involved, either internal or external, and works to promote a better environment for everyone.

Through it, you can ask questions about the Code interpretation and forward reports of noncompliance with the Code, such as corruption, bribery, fraud, damage to the environment, misinformation, inadequate accounting records, misuse of company assets, prejudice, and others.

9Code of Conduct

2.4

3.

Every report received will be treated confi dentially. The issues submitted to the channel are examined by the Ethics Committee, comprised of board members of Cosan.

CHANNELS AVAILABLE

Cosan encourages reports of violations of the ethical principles and guidelines set forth in the Code through the following channels:

• Phone: 0800 725 0039• www.canaldeetica.com.br/cosan

Anonymity and confi dentiality are guaranteed to all whistleblowers.

WORK ENVIRONMENT

The company is committed to maintaining a healthy, safe and productive work environment to all employees, contractors, or any person present in our facilities.

Policies for recruiting, promoting and retaining employees forbid discrimination based on any criteria prohibited by law, including, among others, prejudice of race, sex, physical condition, religion or sexual orientation.

All employees must be treated and treat each other with equality, justice, respect and dignity, always guided by Cosan's business drivers and merit criteria.

Any behavior involving any type of discrimination or harassment will not be tolerated.

It is forbidden to work under the infl uence of alcohol or illegal drugs, because it is considered highly detrimental to health, safety and productivity.

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4.

4.1

Those involved with the use of drugs or alcohol, even outside the premises of the company, are encouraged to seek aid with the Human Resources department for specialized care.

CONFLICT OF INTERESTS

A confl ict of interests occurs when private interests somehow interfere or appear to interfere with the interests of the company.

It can arise, for example, when an employee, offi cer or director commits an act or has an interest that prevents them performing their duties objectively and effectively. Receiving inappropriate benefi ts or advantages as a result of the job position is a confl ict of interest.

Adopting ethically correct principles is an obligation to employees, offi cers and directors in conducting the interests of Cosan.

Situations that may create a confl ict of interests, real or potential, should be discouraged by all.

TRANSACTIONS BETWEEN RELATED PARTIES

It is the commitment of Cosan to maintain transparency in all our transactions and perform them in accordance with the best market practices. Thus, transactions with related parties will depend, for their recruitment, on prior approval of the Board of Directors and shall comply with the conditions set out in the current policy.

Questions related to transactions between related parties must be previously clarifi ed by the Legal department or the Audit and Compliance department.

11Code of Conduct

4.2

4.3

HIRING OF RELATIVES

In order to maintain a healthy, free of potential confl icts of interest environment, hiring relatives is permitted provided that there is no direct or indirect subordinate relationship.

Existing kinship relations, either subordinate relationships or not, including those related to job applicants, should be formally reported by employees to the Human Resources department.

CUSTOMERS, PARTNERS AND SUPPLIERS RELATIONS

A good relationship with customers, partners and suppliers is critical for the company.

Any dealings with third parties, whether formalized or verbal, must be guided by ethics, transparency, impartiality, longevity and professional attitude, always avoiding judgments, behavior or statements that could put at risk the image or the goals of Cosan.

Situations of manipulation, concealment, misrepresentation of data, use of privileged information, misrepresentation or any other action that aims to obtain unfair advantage are strictly forbidden. Cosan forbids any kind of bribe, kickback or similar act, made directly or indirectly to customers, partners or suppliers in order to win or retain business or obtain any other kind of favoritism.

The application of the rules of this Code is mandatory in any negotiation.

It is forbidden to engage third parties to perform any act prohibited by law or by this Code and, therefore, it is forbidden to do business with third parties who intentionally and continually violate the law or the rules relating to this Code.

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4.4

4.5

4.6

This Code of Conduct should be widely publicized to customers, partners and suppliers in order to engage them with the behavior and conduct expected by Cosan.

OFFERING OR RECEIVING GIFTS AND PRESENTS

Gifts, entertainment and hospitality to non-governmental employees, on the occasion of business discussions or the development of business relations, are considered appropriate in conducting the company's business, however, receipt must be conditioned to criteria laid down in the existing Policies for Cosan and its subsidiaries.

Items in violation of the situations provided for in existing Policies and/or that may result in expectation of personal liability should be promptly refused or not provided, as appropriate.

POLITICAL CONTRIBUTIONS AND ACTIVITIES

Political contributions can only be made by Cosan upper management, after examination and approval of the Board of Directors.

Employees, offi cers or directors may make contributions or engage in political activities in their own behalf, but no one will be reimbursed by the Company, directly or indirectly, for personal political contributions.

It is strictly forbidden the payment or offer of advantage, direct or indirect, to public offi ce holders and the like, in Brazil or abroad.

USE OF CORPORATE OPPORTUNITIES

It is forbidden to employees, offi cers or directors to take for themselves business opportunities that may arise through the use of assets, information or corporate positions.

13Code of Conduct

5.1

5.

No employee, offi cer or director may make use of assets, corporate information or position for personal gain of any kind, and are forbidden to compete with the company in any circumstances.

The competition with the company may involve engaging in the same line of business, or any situation where the employee, offi cer or director obtains opportunities related to sales, purchasing, products, services or interests.

DISCLOSURE OF INFORMATION

DISCLOSURES OF FINANCIAL INFORMATION

The company has the responsibility to communicate effectively with the shareholders and the market, so that they receive timely, accurate and complete information about all substantial aspects, the fi nancial condition and results of operations of Cosan.

The reports and documents fi led with or submitted to the Securities and Exchange Commission of the United States and Brazil, as well as other public communications shall include full, fair, accurate, timely and understandable information.

COMMUNICATIONS ON BEHALF OF THE COMPANY

All company communications must be clear, truthful and accurate.

Employees, offi cers and directors should avoid exaggeration, assumptions, conclusions, observations or demeaning characterizations of people and companies.

It is strictly forbidden for employees to communicate with authorities, media, government agencies and third parties, as well as granting interviews, on behalf of Cosan and its subsidiaries.

5.2

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5.3

5.4

Only the Corporate Communications department is authorized to communicate on behalf of the company in any circumstances, or to authorize such a procedure, so any request should be immediately submitted to Corporate Communications.

SOCIAL MEDIA

All employees of Cosan and its subsidiaries are prohibited from publishing or disclosing content on social networks that:

- Contain defamatory statements of the company or competitors.- May cause any type of damage to the company or third parties.- Can negatively impact the image of the company.- Defame employees or incite prejudice against sex, race,

sexual orientation, age, religion, place of birth or disability.- Contain information considered strategic or confi dential.- Defend or allow conducting illegal activities.- May be wrongly interpreted as company policies.- Are not consistent with the culture, values and goals

of the company.- Infringe rights of use licenses, copyright, trademarks or patents,

without express permission of the author and/or company.

NEGOTIATIONS WITH INTERNAL INFORMATION

All non-public information should be considered internal infor-mation and its use is prohibited to trade in securities or to obtain personal benefi ts. The use of non-public information to trade in securities or even “tip” family, friends or anyone else is illegal.

The company have and discloses to the market its Policy for Securities Trading and Disclosure of Relevant Information.

The Investor Relations department can clarify all doubts about the minimum qualifi cation and requirements to buy or sell securities.

15Code of Conduct

6.

6.1

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

ANTI-CORRUPTION LAWS

Under the applicable laws, it is the duty of all offi cers and employees of Cosan and its subsidiaries, in all units and countries of operation, to conduct business with integrity and avoid any form of fraud, bribery, corruption, forgery, dishonesty or money laundering.

It is prohibited under any circumstances to offer, promise, authorize or pay any “valuable item” to a public offi cial, of any nationality, to infl uence or lead to obtain business, retain business, or any other kind of advantage. Employees of business entities of governments, or controlled by governments, also fall into the category of public entities.

Regardless of site of operation, the company must maintain a system of internal controls and records that, in reasonable detail, accurately refl ect all relevant accounting operations.

The company has a comprehensive Anti-corruption Policy, stressing that it is strictly forbidden to have a business relationship with customers, partners or suppliers that are not in accordance with the conditions set forth therein and/or do not commit themselves formally with the observation and compliance with applicable laws.

ANTITRUST LAWS

Antitrust laws prohibit agreements between competitors on issues such as prices, terms of sale to customers and allocation of markets or customers.

Such laws can be very complex and their violations can subject the company and its employees to criminal sanctions, including fi nes, imprisonment and civil liability.

6.2

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6.3

6.4

The Legal Department can clarify any doubts regarding antitrust laws applicable to Cosan and its subsidiaries.

LAWS AGAINST FORCED LABOR AND CHILD LABOR

Cosan opposes and prohibits any form of forced labor, child labor and employing children under 16 years of age, unless under the “Young Apprentice” (“Menor Aprendiz”) contract, in compliance with the special applicable legislation.

It is strictly forbidden any business relationship with customers, partners or suppliers that use forced labor or child labor.

COMPLIANCE AND INTERNAL CONTROLS

All actions must be conducted with a high degree of commitment, in full compliance with the applicable laws, rules and regulations.

No employee, offi cer or director of the company may perform illegal, unethical acts or acts contrary to internal rules, or instruct others to do so.

Questions about the application of any law, rule or regulation may be clarifi ed by the Audit and Compliance department.

Practices contrary to the legislation in force or to internal rules, and orientations to conduct these practices, should be immediately reported to the Ethics Channel.

17Code of Conduct

7.

7.1

7.2

PROTECTION OF INTERNAL INFORMATION

CLASSIFICATION OF INFORMATION

Information is an all-important asset and must be properly used and protected by all, in order to avoid improper or unauthorized use.

All information must be classifi ed as to their level of confi dentiality and treated in accordance with the Information Security Policy of Cosan.

TREATMENT OF CONFIDENTIAL INFORMATION

The proprietary and confi dential information generated and collected in our business are a valuable asset.

For the continued growth and strengthening of our ability to compete, proprietary information should be kept in rigid secrecy unless disclosure is authorized by the company's management or required by law.

Among the proprietary information are included all non-public information that might be useful to competitors or that may be harmful to the company, its customers or suppliers, if disclosed.

Financial information not yet disclosed to the public, in line with the guidelines set out in the Policy for Securities Trading and Disclosure of Relevant Information, are also confi dential.

It is prohibited the discussion of strategic or confi dential matters of the company in public environments.

INTELLECTUAL PROPERTY

Intellectual property, trade secrets, trademarks, copyrights, business, research, product plans, goals, strategies, records,

7.3

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7.4

processes, standards, databases, information of wages and benefi ts, employee medical information, customer lists, personal data of employees, suppliers, and any fi nancial information or prices not released must be protected as a priority.

The use or unauthorized distribution exclusive or proprietary information violate the corporate policy and can be considered illegal.

Improper use or distribution of information can result in negative consequences, both for the company and for those involved, including lawsuits and disciplinary actions.

It is required of employees, offi cers and directors to respect the property rights of other companies and their proprietary information.

ACCURACY OF FINANCIAL RECORDS OF THE COMPANY

The company maintains the highest standards in all matters relating to accounting, fi nancial controls, internal reporting and taxation.

All books, records and fi nancial accounts must accurately refl ect transactions and events, and comply with required accounting principles, the company's internal control systems and applicable laws.

The records should not be distorted in any way to conceal, disguise or change the actual fi nancial position of Cosan and its subsidiaries.

19Code of Conduct

8. PROTECTION OF COMPANY ASSETS

It is the responsibility of employees, offi cers and directors the protection of company assets against loss, theft or misuse.

Any suspected violation of the assets protection should be reported to the Ethics Channel.

Equipment, vehicles, supplies and electronic resources (including hardware, software, mobile phones, smartphones, company e-mails and chat, and associated data) are essential for conducting business and can only be used for that purpose, according to the guidelines and Policies in force.

The use of resources owned by the Company is subject to periodic audits, regardless of previous authorization from the user.

ENVIRONMENT, HEALTH, SAFETY AND COMMUNITY

At Cosan, sustainability management is linked to a global agenda, which includes risk management, fi nancial and environmental impacts, human rights, labor relations and all forms of relations to which we are exposed.

The company's business are conducted in accordance with all applicable laws, and environmental, health and safety in the workplace regulations.

Cosan strives to provide a safe and healthy workplace to our employees, avoiding adverse impacts and damage to the environment and to the communities in which we conduct business.

It is the company's commitment to act responsibly and acknowledge the mutual benefi ts to engage and build relationships with the

9.

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communities in which we operate, always contributing positively and signifi cantly to the local community and ensuring a fair share distribution of benefi ts to all affected parties by these activities.

All employees are encouraged to play a positive role in the community.

21

DISCLAIMER AND COMPLIANCE COMMITMENT TO THE COSAN CODE OF CONDUCT

The Cosan Code of Conduct represents the principles and

actions that guide the company, demonstrating transparency

and professionalism.

I have received and am aware of the standards and practices

set forth in this Code and I agree to comply with and ensure its

continuous compliance, having nothing to report and understand

that any event of breach of this Code of Conduct should be

immediately reported to the Audit and Compliance department.

Name:

Registration:

Unit:

Department:

Signature:

Date:

23Code of Conduct

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