Code of Ethics and Conduct

At akquinet Brasil, our professionals take doing the right thing seriously. Together, we have shown we can achieve success by delivering value and opportunity to our clients and our people, while being a force for good.

Our shared commitment to operating with high ethical standards and to making a positive difference in everything we do is what makes akquinet Brasil special.

We innovate with integrity, using our understanding of technology and its impact on people to build inclusive, responsible and sustainable solutions to today's social and business challenges. To do so we need to empower our professionals to make sound decisions and act responsibly.

With our Code of Ethics we want to help our professionals make ethical behavior a natural part of our daily work — with each other, our clients, partners and community.

Our Code is more than a document: it reflects what we believe, how we live and how we lead. It is fully embedded in everything we do. Through it we improve our performance and build the reputation of akquinet Brasil. It is how we put integrity into action — every one of us, every day.

Leonardo Libardi
CEO, CMO — akquinet Brasil

This Code is a handbook that sets guidelines for professional behavior and interactions involving akquinet Brasil.

Its purpose is to ensure transparency in processes and standardize conduct, supporting decision-making and fostering ethical behavior through actions based on the values promoted by akquinet Brasil and the law.

• Life first.
• Respect our planet and community.
• Value the people who make our company.
• Act with integrity.
• Make it happen.

Our values are unfolded into fundamental principles that guide us so akquinet Brasil remains an ethical company, growing continuously and sustainably.

Understanding and following these values and principles means always learning and practicing the expected key behaviors every day: open and transparent dialogue, empowerment with commitment, responsibility for the whole, and active listening and engagement with colleagues and society.

This Code must be observed by Partners, Board Members, President, Directors, Employees, Interns, Apprentices, Outsourced Workers, Business Partners (consultants, commercial agents and associates) acting on behalf of akquinet Brasil, Vendors and Service Providers (other contractors and subcontractors of akquinet Brasil).

All recipients must use the provisions set out in this Code as an ethical and behavioral reference for their relationship with akquinet Brasil and in performing their activities in any location and segment where the company operates.

Ethics is a daily practice that requires constant effort in every decision we make. Acting with integrity and responsibility requires judgment.

The akquinet Brasil Ethics Program aims to implement business actions aligned with the company's ethical principles, promoting a more compliant environment. These actions are carried out through:

• Activity risk management and internal control standards: we recognize the risks of our business and maintain a formal governance structure to prevent and mitigate them, across their various dimensions and origins.
• This structure is based on a lines-of-defense model, with clearly defined roles and responsibilities and periodic monitoring that gives us visibility into the main risks and effectiveness of critical controls; and
• Training: periodic activities providing guidance on how to overcome dilemmas and make responsible decisions. Always collaborate, take part and stay up to date.

We put people at the center of our decisions and believe every worker has the right to a safe and healthy environment. Our most important indicators are health, safety and risk. We believe that operating with excellence — and, consequently, with more safety — makes production and financial goals a natural outcome of responsible, conscious management.

We recognize mistakes may happen and, when they do, they must be addressed honestly and never hidden. That is why we report every incident, near-miss and unsafe condition. When we act ethically we deal with our failures openly, professionally and immediately, always putting life first.

We recognize that our decisions can affect the lives of other people, akquinet Brasil employees or not. Because of that, we adopt standards that enable operational discipline and plan and execute our activities in an ethical, responsible and safe way.

We respect nature and believe that respect is one of the pillars of our operational excellence. We are aware of the importance and global context of preserving natural resources.

That is why we make commitments in our operational practices, balancing our environmental impact with adequate control and offset measures, always pursuing sustainable progress.

We respect and promote Human Rights, continuously seeking to prevent potential impacts and violations and, when necessary, working to mitigate and remedy them across akquinet Brasil activities and along our operational chain. We follow the UN Guiding Principles on Business and Human Rights and the laws of each country where we operate, along with national and international standards.

We encourage employees, third parties and communities to report situations where Human Rights are not respected.

We value diversity and promote an inclusive environment. We invest in our employees' continuous development because we believe akquinet Brasil's growth is tied to the growth of everyone who builds our business day to day.

We recognize people and provide opportunities in a fair, equal and merit-based way.

We ensure everyone is respected and has the opportunity to develop their potential, regardless of cultural or ideological differences, disabilities, gender, race, ethnicity, nationality, origin, political convictions, religious beliefs, age, marital status, union membership, social class, sexual orientation, gender identity or any other condition. We are committed to creating a respectful, dialogue-based environment where people can be themselves.

We do not tolerate any form of prejudice, discrimination, racism, homophobia, moral or sexual harassment, humiliation, intimidation, ridicule, hostility or embarrassment. We encourage these situations to be reported through our Whistleblower Channel (available on our website).

Including differences is a starting point for a fairer, more equal world. For us, difference truly makes a difference.

We build our work environment on relationships of mutual respect, ethics and integrity. We know each person is unique, as is the context in which they live day to day. Our management models seek to recognize and consider these elements before making any decision that may affect our employees.

We are a company with active listening that values the expression of opinions and diversity of viewpoints. We act with maturity and respect in the face of dissent, constantly learning.

Under no circumstances do we retaliate against expressions of disagreement. We know how to deal with our mistakes and therefore reject any concealment of problems. Everyone is expected to practice open and transparent dialogue.

Conflicts of interest arise when someone acts for their own benefit, or to benefit relatives, close people, shareholders, vendors or public officials, whether or not akquinet Brasil benefits or is harmed.

We reject and prevent any action, influence or decision motivated by interests contrary to standards that are not exclusive and legitimate to akquinet Brasil.

We believe free competition is the best way to do business fairly and healthily.

We act with integrity and foster a business environment free of fraud and manipulation of any kind, whether in tenders or in contracts with the public or private sector.

Any information about the market and competitors that is deemed attractive to the business must, without exception, be acquired through lawful and honest methods; obtaining it illegally or unethically is prohibited.

We know corruption happens when someone gives, promises, offers or authorizes favors or something of value, directly or indirectly, to influence a decision, gain an undue advantage or obtain or keep business — public or private.

Besides being illegal and unethical and subject to criminal liability, corruption has serious consequences for the company and society. akquinet Brasil has zero tolerance for bribery and corruption and does not protect those who engage in these practices — be they a partner, employee or any third party.

akquinet Brasil has an Anti-Corruption Policy that provides all Members and related parties with guidance on preventing and fighting corruption.

All communication means such as emails, websites and other platforms used for professional purposes are property of akquinet Brasil, and their use is subject to the guidelines of this Code and must be restricted to professional matters.

All communications must use formal language. Slang, vulgar expressions or any term that could harm akquinet Brasil's image or affect a healthy work environment are prohibited. Access to email and other communication tools outside business hours by people who do not hold trusted positions is only allowed with prior authorization from the responsible manager.

We are responsible for akquinet Brasil's assets, including equipment, materials and information — printed or digital. Ensuring proper access and safe maintenance of this information and assets is part of our business ethics.

Access to information is part of our daily duties and a key competitive advantage for our company. Therefore, any and all data produced during our activities is the property of akquinet Brasil and must always be classified according to internal rules (confidential, restricted, internal use and public).

Recipients of this Code must be guided by confidentiality, sharing with third parties only information that is strictly necessary for the good conduct of business and never irrelevant or unrelated to the transaction in question.

The following are considered confidential:

• Market, client or third-party information acquired through the relationship between the Recipient and akquinet Brasil;
• Information related to any financial transaction or commercial activity carried out by akquinet Brasil;
• Personal information;
• All information that, due to the data involved, must be treated as confidential.

Ending the relationship with akquinet Brasil does not release the party from confidentiality obligations.

We must be consistent with our values and practice them daily in every aspect of our business, including the selection of and relationship with our Vendors and Service Providers.

Our relationships with Vendors and Providers, which are part of our value chain, are guided by good faith, honesty, ethics and transparency, and always aim to contribute positively to the economic and social development of the regions where we operate.

We pursue results that are always aligned with our values. We work to be recognized as a socially responsible and sustainable company.

We trust people and have a governance model that establishes autonomy with accountability, making clear what is expected of each of our members. We must reflect before acting and must always report any failure or mistake that occurs. This behavior is part of our maturity and evolution.

All members must adopt conscious waste-disposal actions, as well as separating selective and electronic waste, which must be delivered to the person responsible for proper destination. Conscious use of water and energy is also encouraged. We require the same posture from our Partners, Vendors and Service Providers, particularly regarding compliance with regulations on special waste disposal.

We know how much effort it takes to build a company's reputation and how quickly it can be destroyed. Building it is a daily exercise, made up of small and large actions taken by all of us.

Respect for akquinet Brasil's reputation is the result of responsible and correct actions, ethical decisions, immediate corrections and respect for our Code of Ethics and Conduct and our company's values.

We comply with the laws of the countries where we operate. We maintain an organized system of formal records of our activities and results in accordance with laws, regulations, principles and standards.

We are committed to transparency and clarity regarding our values, principles, policies and governance, and we engage regularly with our External Stakeholders.

There is no room for informal, disguised or hidden activities at akquinet Brasil.

akquinet Brasil expects this Code of Ethics and Conduct to apply to all Recipients, without distinction.

Anyone found to have violated the principles of this Code of Ethics and Conduct and akquinet Brasil's other policies and standards is subject to the disciplinary measures below, applied in accordance with local laws and the severity of the violation:

• Warning;
• Training;
• Suspension;
• Dismissal;
• Disqualification (vendors and service providers);
• Other legal measures.

akquinet Brasil provides a Whistleblower Channel to report, exclusively, violations of this Code and the company's other policies.

The channel is anonymous and identification is optional. Reports are handled with discretion, respecting the privacy of those involved.

This Code remains in force until it is reviewed and a new edition is published.

A new review must take place at least every 12 months.

Distribution may be physical or digital, upon acknowledgment of receipt, and a copy is always available on the company's Intranet for consultation.

I declare that I have read and understood the content of the akquinet Brasil Code of Ethics and Conduct, available on the company's intranet.

Signing this statement demonstrates my commitment to fully comply with the aforementioned Code of Ethics and Conduct.