Code of Ethics and Conduct

Summary

CHAPTER I - INTRODUCTION

1.1 Purpose

1.2 Scope

CHAPTER II - FUNDAMENTAL PRINCIPLES AND VALUES

2.1 Commitment to Ethics and Legality

2.2 Transparency and Good Faith

2.3 Professional Secrecy

2.4 Social Responsibility and Sustainability

CHAPTER III - INTERNAL CONDUCT POLICIES

3.1 Customer Relationship

3.2 Internal Relationship

3.3 Relationship with Third Parties

CHAPTER IV – CONFLICT OF INTEREST

4.1. Definition and Nature of Conflict of Interest

4.2. Internal Controls and Supplier Hiring

4.3. Communication of Conflicts of Interest

4.4. Hiring Companies with Participation of Professionals or Family Members

CHAPTER V - CORRUPTION AND BRIBERY

5.1 Commitment to Integrity and Transparency

5.2 Fences and Prohibited Conduct

5.3 Relationship with Public Agents

5.4 Prohibition of Political-Partisan Activities

5.5 Reporting Channel

CHAPTER VI - GOODS AND HERITAGE

6.1 Responsible Use of Goods and Resources

6.2 Confidentiality and Information Security

6.3 Behavior on Social Networks and the Internet

6.4 Protection of Intellectual Property and Confidential Information

CHAPTER VII - DISCIPLINARY MEASURES

7.1 Responsibility for Reporting Violations

7.2 Consequences of Infractions

7.3 Penalties for Legal Entities

CHAPTER VIII - REPORTING CHANNEL

8.1. Provision of a Reporting Channel

8.2. Whistleblower Protection Guarantee

8.3 Guarantee of Secrecy and Anonymity in Complaints

8.4. Handling Complaints in Good Faith

CHAPTER IX - FINAL PROVISIONS

CHAPTER I - INTRODUCTION

1.1 Purpose

This Code of Ethics and Conduct aims to establish the guidelines that guide the actions of professionals at R. V. Pinheiro Advogados (“Office”), ensuring that all activities carried out by the Office are based on the highest ethical and legal standards. Professional ethics, transparency and responsibility must be fundamental principles in the execution of the services provided, ensuring that the commitment to justice and the interests of clients is always observed. This document also aims to promote a respectful, collaborative work environment free from inappropriate conduct.

This Code complies with the provisions of Law No. 8,906/1994 (Advocacy Statute) and the OAB Code of Ethics and Discipline, as well as the best governance practices applicable to law. Its compliance is essential to maintain the credibility and trust that the Firm places in its professionals, clients and other parties involved.

1.2 Scope

This Code applies to all members of the Firm, including partners, associates, lawyers, interns, consultants and administrative collaborators, as well as third parties who maintain any type of professional relationship with the Firm. Suppliers, service providers and business partners must also adhere to these guidelines and ensure that their activities are conducted ethically and transparently.

Compliance with the standards established in this Code is not optional, and any violation may result in disciplinary measures, as detailed in the following chapters.

CHAPTER II - FUNDAMENTAL PRINCIPLES AND VALUES

2.1 Commitment to Ethics and Legality

The Firm conducts its activities based on legality and the principles of professional ethics. All its members must perform their duties in compliance with legal standards, the Law Firm Statute, the OAB Code of Ethics and Discipline and other applicable regulations.

Strict compliance with legal and regulatory standards ensures that the Firm operates with integrity and in line with the values of law. Therefore, any conduct that could compromise the professional integrity or image of the Firm will be treated seriously and may result in disciplinary sanctions.

2.2 Transparency and Good Faith

All professional relationships established by the Firm must be conducted with complete transparency and good faith, ensuring that the information shared is always clear, precise and objective. The commitment to transparency applies both to relationships with clients and to internal interactions between members of the Firm.

Good faith must be a non-negotiable principle in all actions and decisions taken by the Firm's professionals. Acting with loyalty and respect for the commitments assumed is essential for preserving the credibility and reputation of the Firm.

2.3 Professional Secrecy

Professional secrecy is an essential pillar of law and must be strictly respected by all members of the Firm. Information obtained in the exercise of the profession, whether in meetings, documents, correspondence or other means, cannot be disclosed to third parties without the due authorization of the client or without the legal provision to do so.

Violation of professional secrecy compromises not only the relationship of trust between lawyer and client, but can also lead to severe disciplinary and legal sanctions. Therefore, all professionals must act with caution when handling confidential information, ensuring that the privacy and interests of clients are preserved.

2.4 Social Responsibility and Sustainability

The Office recognizes its social role and is committed to adopting sustainable practices in its operations, seeking to minimize environmental impacts and contribute to the development of society. The Firm encourages pro bono advocacy actions, participation in social projects and dissemination of legal knowledge as a way of giving back to the community.

Social responsibility is also reflected in valuing diversity and combating any type of discrimination. The Firm promotes an inclusive, respectful and egalitarian work environment, ensuring that all its members have opportunities for professional and personal development.

CHAPTER III - INTERNAL CONDUCT POLICIES

3.1 Customer Relationship

Relationships with customers must be conducted in a professional, ethical and transparent manner. All lawyers and employees of the Firm must treat clients with respect, diligence and commitment, ensuring clear and objective communication about the services provided.

It is prohibited to promise results or generate unrealistic expectations for clients, and technical responsibility and professional independence must always prevail in the conduct of legal work. Accountability must be carried out periodically and in detail, ensuring that customers are always informed about the progress of their demands.

3.2 Internal Relationship

The in-person and virtual work environment must be based on cooperation, mutual respect and the appreciation of each professional. Any form of harassment, discrimination or abusive conduct will not be tolerated and must be reported immediately through the appropriate channels.

Office members must work collaboratively, always seeking technical improvement and the exchange of knowledge among colleagues. Respect for hierarchy and internal organization is essential to guarantee a productive and harmonious environment.

3.3 Relationship with Third Parties

Third parties who provide services to the Firm must observe the same ethical standards established in this Code. Any irregularity or misconduct must be communicated to the Office's management so that the appropriate measures can be taken.

The hiring of suppliers and service providers must be carried out based on objective criteria, prioritizing companies and professionals that share the Office's values and ethical principles.

CHAPTER IV – CONFLICT OF INTEREST

4.1. Definition and Nature of Conflict of Interest

At the Office, all professionals must avoid situations in which their personal interests may interfere with the performance of their duties and the fulfillment of their professional obligations. A conflict of interest may occur when the actions or interests of a professional in the Firm become incompatible with the interests of the Firm or its clients.

A conflict of interest occurs whenever personal interests or those of third parties may influence the ability of a professional to act impartially, especially when there is a benefit to be obtained or a loss to be avoided as a result of the choices made.

4.2. Internal Controls and Supplier Hiring

Due to the ethical obligations of law, it is crucial that the Firm identifies and prevents the actions of its professionals in cases that may create a conflict between the interests of two or more clients. To ensure integrity and professional ethics, the Firm adopts a system of governance and internal controls to check conflicts of interest, this step being mandatory before accepting new clients or opening new cases.

In addition to internal control mechanisms, the Office also establishes that the hiring of suppliers is carried out based on technical, professional criteria and free from any conflict of interest, whether real or apparent.

4.3. Communication of Conflicts of Interest

All professionals must immediately communicate to management any situation involving a possible or actual conflict of interest, whether with the Firm or its clients.

4.4. Hiring Companies with Participation of Professionals or Family Members

The Office is permitted to hire companies in which a professional has participation or involvement of family members, as long as the process is transparent and approved internally, with decisions being properly conducted by professionals exempt from the situation.

CHAPTER V - CORRUPTION AND BRIBERY

5.1 Commitment to Integrity and Transparency

The Office adopts a zero tolerance policy against any form of corruption, bribery or practice that compromises the integrity of its operations. All members of the Firm must act transparently and ethically in their relationships with clients, partners and public agents, ensuring that no irregular conduct is carried out in the name of the Firm.

The Office strictly complies with the provisions of the Anti-Corruption Law (Law No. 12,846/2013) and other applicable national and international legislation, preventing any act that could be interpreted as illicit favoritism or obtaining undue advantages.

5.2 Fences and Prohibited Conduct

No member or collaborator of the Firm may, directly or indirectly, offer, promise, give or accept any undue advantage, including payments, gifts, favors or benefits that may influence the decision-making of public or private agents.

Prohibitions cover not only money, but also high-value gifts, travel, entertainment, business opportunities or any other advantage that could be interpreted as bribery or corruption. The Office's policy establishes that any benefit granted to third parties must be documented and justified according to ethical and legal criteria.

5.3 Relationship with Public Agents

In relationships with public agents, it is essential that all interactions are guided by transparency and legality. It is prohibited to offer any type of financial compensation or undue benefit to public officials, whether to speed up processes, influence decisions or obtain commercial advantages.

If any Firm professional is approached with undue requests or is faced with situations that may constitute illicit practices, they must immediately notify the Firm's management so that appropriate measures can be taken.

5.4 Prohibition of Political-Partisan Activities

The Office does not make donations to political parties, electoral campaigns or candidates for public office. Any involvement of its professionals in party political activities must occur exclusively on a personal basis, without any association with the Firm.

5.5 Reporting Channel

The Office provides a secure and confidential reporting channel so that any suspicion of corruption, bribery or inappropriate conduct can be reported. All reports will be investigated impartially and confidentially, ensuring that corrective measures are taken as necessary.

CHAPTER VI - GOODS AND HERITAGE

6.1 Responsible Use of Goods and Resources

The Firm's assets and assets, made available to its members and collaborators, must be used in a responsible and careful manner. Everyone has the obligation to ensure the conservation of the Office's material and technological resources, ensuring that there is no damage, loss or waste.

Technological resources, such as computers, printers, communication systems and other tools provided, must be used exclusively for the performance of professional functions. The use of equipment and technologies for personal purposes is not permitted, except for exceptions previously authorized by the administration.

6.2 Confidentiality and Information Security

Information security is fundamental to the integrity of the Office and the protection of customer data. Therefore, professionals must maintain confidentiality regarding personal passwords and access data, which must not be shared with other team members. Institutional electronic mail must be used exclusively for professional purposes, and the sending of non-corporate content, such as personal messages, political campaigns, jokes or any material that is not related to the work environment, is prohibited.

6.3 Behavior on Social Networks and the Internet

When using the internet and social networks, all members of the Office must adopt an ethical and prudent stance. It is essential that online interactions do not expose the name or image of the Firm in a pejorative manner. Derogatory or offensive comments about co-workers, clients, partners or any party involved in the Firm's activities are strictly prohibited.

Furthermore, professionals must refrain from getting involved in situations that could compromise their image or that of the Firm, especially in ethically questionable contexts or that could generate negative repercussions.

6.4 Protection of Intellectual Property and Confidential Information

The Firm's intellectual assets and confidential information, including methodologies, intellectual works, and data from clients and third parties, must be treated with the utmost diligence and respect. The transfer of any technology or information owned by the Firm or its clients outside the corporate environment is prohibited, without due authorization.

Care for intellectual property is essential for preserving the Office's competitiveness and credibility, in addition to ensuring trust and protection of clients' sensitive data.

CHAPTER VII - DISCIPLINARY MEASURES

7.1 Responsibility for Reporting Violations

All members of the Firm, as well as third parties with whom the Firm maintains professional relationships, have the responsibility to report any act or situation that contradicts the guidelines established in this Code of Ethics and Conduct. The omission of any irregularity or violation will be considered a serious ethical failure, subject to sanctions, regardless of the position or function.

Complaints must be sent through a direct channel provided by the Office, a safe and confidential means, which guarantees absolute secrecy, including regarding the identity of the complainant. The Office ensures that there will be no retaliation of any kind against those who report infractions in good faith, creating an environment in which transparency and correction are priorities.

7.2 Consequences of Infractions

When a violation of any principle established in this Code is proven, the Office will take the necessary measures according to the severity of the infraction. Disciplinary actions can range from warnings, whether verbal or formal, to more severe measures, such as temporary or permanent suspension, contractual termination, or even the exclusion of the individual from the membership, if the case involves such circumstances.

In addition, the Office may resort to the application of additional legal sanctions, including civil or criminal actions, depending on the nature of the infraction. This may involve fines, the return of amounts obtained improperly and any other penalties provided for in current legislation. The investigation process will always be conducted rigorously, respecting the rights of defense and adversarial parties, in order to ensure that all measures are proportional to the infraction committed.

7.3 Penalties for Legal Entities

In the case of legal entities associated with the Office, such as suppliers, service providers or commercial partners, who are responsible for violations of the rules of this Code, the Office may adopt both administrative and judicial sanctions. These sanctions include fines, as well as other penalties stipulated by the Anti-Corruption Law (Law No. 12,846/2013), or by legislation applicable in similar situations. The application of these measures aims to ensure that all commercial and professional relationships maintain the ethical standards required internally.

CHAPTER VIII - REPORTING CHANNEL

8.1. Provision of a Reporting Channel

The Office will provide a safe and confidential communication channel for reporting inappropriate conduct. The channel will guarantee anonymity and protection to prevent retaliation. All complaints will be analyzed by an internal committee, which will take the appropriate measures, always respecting the principles of confidentiality and impartiality.

8.2. Whistleblower Protection Guarantee

The Firm ensures that all its members are protected against any type of retaliation as a result of complaints or reports made in good faith, in accordance with this Code of Ethics and Conduct, as well as other internal Firm policies and procedures.

8.3 Guarantee of Secrecy and Anonymity in Complaints

Professionals have the option of registering complaints anonymously. Even though the Office takes all measures to preserve anonymity, in some specific situations, the identity of the complainant may be revealed during the investigative process, when necessary. The Firm is committed to protecting this identity within legal limits.

It is important to highlight that, when the complaint is anonymous and does not provide sufficient details, the investigation may be hampered, limiting the possibility of an adequate investigation.

If the professional chooses to reveal their identity when making a report, the Firm undertakes to keep this identity confidential, respecting legal limits. Access to information will be restricted to those responsible for investigating the case, guaranteeing the privacy of the complainant.

8.4. Handling Complaints in Good Faith

The Office will handle all reports based on the presumption of good faith. Even if a complaint proves to be inconclusive or unfounded at the end of the investigation, the complainant will not suffer reprisals, as long as the complaint was made with the intention of contributing in a positive way. Only reports proven to be made in bad faith may result in sanctions.

CHAPTER IX - FINAL PROVISIONS

9.1. This Code comes into force on the date of its publication and will remain valid until revised or updated. Compliance with its guidelines is essential for maintaining the Firm's credibility and reputation.