CODE OF CONDUCT

OBJECTIVE

This Code of Conduct sets forth the general principles and rules that guide Intrust Associates in conducting its business.

SCOPE

This Code applies to all Intrust professionals, whether external or internal: partners and employees, as well as suppliers of goods and services and partners. Everyone who has any connection with the organization, whether suppliers, customers, or employees, will be informed of the content of this Code and asked to comply with it.

DEFINITIONS

Intrust: refers to Intrust Associates, always considered for the purposes of interpreting this Policy in conjunction with the companies that make up its economic group.

Employee: someone who performs a function in the company.

PRINCIPLES

The Code of Conduct is the company's main operating guideline and defines how business is conducted, the main rules to be observed, and prohibitions on undesirable behavior.

Knowledge of company rules, transparency, security, reliability, good faith, non-retaliation, confidentiality, respect for human beings, ethics, and integrity are some of the principles that should govern all relationships involving Intrust Associates (“Intrust”).

VALUES

The values considered relevant by the company's founders and partners are reflected in this code, with Intrust's values defined as follows:

Our purpose is corporate expansion, helping Brazilian and international companies to establish themselves globally through business and bureaucratic mechanisms.

With this in mind, our values are to work for sustainability inside and outside our company, acting with respect, honesty, humility, commitment, excellence, simplicity, and a focus on results for our clients.

What is the Code of Conduct and what are its objectives?

This Code of Conduct provides guidance to Intrust professionals on the key points of all activities carried out within the company.

It also presents best practices and guidelines, in addition to reinforcing the commitment to comply with laws, contracts, internal regulations, and integrity.

Knowledge of this code is mandatory for all employees and other third parties of the company, guiding the preparation and structuring of corporate documents, as well as guiding the decision-making of the organization and each individual.

Code of Conduct Management

Compliance with this Code will be assisted by the company's Senior Management, with support from the Head of Compliance. This professional will also be responsible for disseminating the guidelines and standards set forth in the document. In addition, the Head of Compliance will be responsible for receiving and handling complaints occasionally submitted by suppliers, internal employees, and/or partners.

Relationship with the public sector

Relationships with public officials shall be conducted with respect and consideration for the institutions and employees working therein, and shall not involve any undue advantage under any circumstances.

For the purposes of this Code, the following shall be considered:

Public Agent: anyone who exercises, even temporarily or without remuneration, by election, appointment, designation, hiring, or any other form of investiture or bond, mandate, position, employment, or function in the entities mentioned in the previous article (Administrative Impropriety Law - Law No. 8,429/92);

Public Administration: agencies and entities of the Brazilian State or any Foreign Country, in all its Powers (Executive, Legislative, and Judicial) and all its spheres (Federal, State, and Municipal). Furthermore, the following are also considered Public Administration: (i) legal entities controlled, directly or indirectly, by the Brazilian State, a foreign country, or international public organizations; (ii) diplomatic representations of foreign countries.

Conflict of interest and dealing with clients

Intrust Associates employees must perform their duties in the best interests of the company and its clients, without violating laws or contracts and/or causing harm. Employee behavior must follow the organization's principles and, above all, be honest and polite, always reflecting the values described in this document.

Fighting Corruption

Intrust Associates professionals are committed to complying with Brazilian anti-corruption legislation, primarily Law 12.846/13 and the international guidelines of the Foreign Corrupt Practices Act of 1977 (FCPA) and the United Kingdom Bribery Act of 2011 (UKBA).

Employees and third parties must contribute to the fight against corruption. To this end, it is necessary to refrain from acts such as donations, promises, and/or offers, directly or indirectly, of undue advantage to public officials or third parties related to them.

Use of equipment, systems, information, and data

The equipment, networks, systems, software, and other information and communication technologies (collectively, “equipment and systems”) and the information stored therein and/or transmitted through them belong to or are controlled by Intrust and shall be accessed and used exclusively for the performance of your duties, the performance of their professional activities, and/or the fulfillment of any service agreement entered into between Intrust and a third party or its employee.

Employees and third parties must ensure the security and integrity of the equipment, systems, and information made available to them directly or indirectly by Intrust, undertaking to:

Not use them for personal purposes or purposes other than those mentioned without the prior and express authorization or request of Intrust Associates.
Exercise the necessary caution when displaying data on screen, printer, or recording it on electronic media, in order to prevent unauthorized third parties from gaining access to it.
Do not leave your workstation without logging out of your browser and professional email account, thus ensuring that no unauthorized third parties can access them.
Do not disclose your passwords for accessing equipment and systems to anyone and take the utmost care to ensure that they remain known only to you.
Do not use the same password(s) used for personal accounts, such as social networks and personal email, on equipment and systems provided by Intrust Associates.
Change your password whenever determined by Intrust or if you suspect it has been discovered by third parties, and do not use simple combinations that can be easily discovered.

Employees and third parties must agree not to use the equipment, systems, and information made available directly or indirectly by Intrust to commit any illegal acts and/or acts harmful to Intrust or third parties, such as:

Acts contrary to laws, regulations, codes of conduct, and other policies developed by Intrust.
Acts intended to defraud the law or any third-party rights, including copyrights.
Acts contrary to morality or good customs, or that disrespect anyone's rights to honor, privacy, image, and personal and family intimacy, under the terms of applicable legislation.
Browsing pornographic websites, websites that advocate drug use or pedophilia, or racist and similar websites.
Use of obscene, offensive, or indecent language or images, in violation of mutual respect and/or conduct expected in the workplace.
Transmission or dissemination of false messages or news, as well as illegal, slanderous, abusive, defamatory, harmful, threatening, vulgar, obscene, or otherwise objectionable materials under laws, regulations, codes of conduct, and other internal policies.
Transmission or dissemination of information about illegal activities and incitement to crime.
Sending unsolicited advertising material (e.g., spam, junk mail, chain letters), and/or direct mail, chain letters, or pyramid schemes to third parties.
Transmission or propagation of programs or files containing viruses or other code that may cause any damage or risk to the recipient, third parties, or Intrust Associates' equipment, networks, systems, and other information and communication technologies.
Obtaining or attempting to obtain unauthorized access to other Intrust equipment, networks, systems, and other information and communication technologies.
Acts intended to interfere with, interrupt, or in any way harm any services or products offered by Intrust or third parties.

Employees and any third parties must report any abnormalities, damage, disablement, or loss observed in the equipment and systems provided by Intrust to the Executive Board or the Compliance area.

Due to professional activities, there is the possibility of monitoring and inspecting computer equipment and systems, including professional emails, as well as the use of information and data from machines, in order to ensure greater security for Intrust, its members, and third parties, within the limits of applicable law.

Intelectual Property

Knowledge management involves analyzing and creating documents, strategies, theses, and procedures to be used by employees or customers.

Materials consulted by employees for the preparation of authorial documents or revisions must be kept, as well as materials prepared after research.

The retention, extraction of copies, or removal of any information, project, or document related to the activities performed by Intrust is prohibited.

Privacy and confidentiality

With regard to customer relations, employees must maintain confidentiality regarding information made available to them as a result of activities, consulting, and similar work carried out at Intrust Associates.

Therefore, it is prohibited to obtain, store, use, or pass on material that violates copyright or intellectual property laws, causes moral damage or is offensive to individuals, or is contrary to the interests of the organization. These rules apply to materials produced by Intrust, as well as those originating from or sent by customers and/or partners.

All information provided to you or to which you have access as a result of the performance of your duties, the performance of your professional activities, and/or the fulfillment of any contract entered into between Intrust and a third party or your employer must be kept in a completely secure location, controlled by Intrust and inaccessible to third parties, unless duly authorized by Intrust to proceed otherwise.

Privacy and Personal Data Protection

Intrust understands the extreme importance of and is concerned with the privacy and protection of personal data. For this reason, it has developed and implemented its Privacy Policies and Privacy Governance Program in order to establish principles and rules to be adopted when handling such information and to provide visibility to the owners of its operations, in compliance with applicable legislation.

In this sense, it is the duty of each employee and third party to faithfully comply with applicable legislation (including, but not limited to, the General Data Protection Law – Law No. 13,708/2018), Intrust's internal policies, programs, and regulations related to privacy and personal data protection, in addition to keeping up to date with any changes to such documents.

Equal Opportunities

Intrust values and establishes a balanced work environment with equal opportunities for all. It is understood that the hiring and retention of professionals is based on the free choice of recruiters and leaders. Technical aspects and personal attributes will therefore be considered and evaluated.

Thus, no prejudiced or discriminatory practices will be tolerated, whether based on color, race, religion or creed, gender, sexual orientation, politics, or culture.

Similarly, no undue advantage or favoritism will be allowed for any employee, third party, partner, supplier, customer, or other party related to the company.

Combating harassment

All company professionals have a duty to respect employees in general, whether they are internal, suppliers, and/or external partners. In addition, acts that constitute “moral harassment” and “sexual harassment” are not permitted. This attitude contributes to an honest and healthy work environment.

Employees in higher positions should not use their position to expose subordinates to embarrassing and/or humiliating situations.

Gifts, hospitality, donations, and sponsorships

The receipt of gifts and/or hospitality must be proportional to the work performed by whoever received them. Under no circumstances should gifts and/or hospitality be received or granted as a reward for undue advantage.

Donations to campaigns, politicians, and/or sponsorships are not permitted. Professionals who wish to do so individually may do so, provided that it is in their own name and under their own responsibility, and that they notify company management in advance.

Use of social media

Intrust professionals are prohibited from posting any content representing the company on personal social media accounts, unless authorized by management or the Compliance department.

Content that has already been published by Intrust may be shared on social media.

Social media includes Facebook, LinkedIn, Twitter, WhatsApp, Instagram, TikTok, and similar platforms.

Proper use of company assets and structure.

All assets and resources made available by Intrust to its employees must be used responsibly and without waste. Employees are responsible for protecting the company's assets in order to prevent misuse and ensure they are cared for, thereby preventing theft, loss, and/or fraud.

Reporting irregularities

Intrust encourages employees and third parties to report questions, concerns, and reports of actions suspected of violating the rules contained in this Code of Conduct or any other rule, provided they are made in good faith, with the assurance that all reports will be reviewed independently and impartially.

The following should be reported:

Irregular acts: deliberate provision of incorrect, incomplete, or ambiguous information; violation of the employment contract, this Code of Conduct, internal policies and procedures, company guidelines, and applicable law;
Fraudulent acts: deliberate misappropriation, falsification of any kind, illegal removal of company data, money, and/or goods;
Acts of corruption: using illegitimate, illegal means that are contrary to internal rules and violate the law to obtain personal gains or gains for other individuals in an improper manner, whether in relations with public or private entities;
Acts of unfair competition: using illegitimate, illegal means that are contrary to internal rules and violate the law, violating the equality of competing companies or abusing economic position;
Others: any situations in which you need to express your concerns or the employee feels the need to obtain support from the Compliance area.

Intrust Associates is committed to protecting the rights of employees who, in good faith, report violations of the Code of Conduct, suspected irregularities, fraudulent acts, or corruption, guaranteeing anonymity if desired by the whistleblower and not tolerating retaliation or reprisals.

Making reports dishonestly, with the aim of harming another company or individual to obtain any kind of advantage, does not constitute a report made in good faith and is a violation of this Code of Conduct. Reports made in bad faith are subject to appropriate action being taken against the reporter.

Validity

This code will take full effect on January 28, 2025, and is binding on Intrust Associates employees, service providers, and interns.

São Paulo, 28 th of January 2025.

Reviewed in: 02/06/2025.

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