Code of Ethics and Conduct

DATE OF ELABORATION: MARCH 5, 2025

01. Objective

The Code of Ethics and Conduct of D EMPREENDIMENTOS translates the principles, rules and standards of conduct that must be observed and considered in relationships established with various stakeholders.

Ethics is zeal for coexistence and, therefore, being ethical goes beyond following rules and norms, involving integrity, equity, transparency, justice and commitment. Thus, this Code of Ethics and Conduct aims to establish standards of conduct to be observed by all those who have a relationship with D EMPREENDIMENTOS, in order to contribute to collective well-being, avoiding situations that may cause conflicts of interest, as well as defining the necessary guidelines for their solutions and preserving the image and reputation of D EMPREENDIMENTOS.

Through these guidelines, D EMPREENDIMENTOS increasingly seeks cohesive action, based on ethical standards of governance and business sustainability.

02. Scope

The guidelines of this Code apply to all those who have a relationship with D EMPREENDIMENTOS, in any action or business that involves the interests of D EMPREENDIMENTOS.

03. Mission, Vision and Values

The company's values are an expression of its personality, being responsible for defining our identity and our way of being and acting. That's why we value unity, always collaborating, as it guarantees deliveries and our constant growth.

We seek results through feedback from our employees, customers and business partners. Improving the user experience is what drives us.

We seek to establish new standards of excellence, technology and innovation within the market in which we operate, as the basis of our strategy is disruption. We are a Company driven by our ideals and faithful to our values. We believe in transformation, in our customers' daily lives, in our team's life and in market dynamics.

04. Conduct in Social Relations

Included in the conduct of social relations are: employees and directors (Brazilian, naturalized or foreign), affiliates, agents and representatives who act on behalf of D EMPREENDIMENTOS.

a) Relationship with clients

Provide clear information to clients about their rights and obligations under current legislation and regulatory bodies, as well as provide them with transparent, courteous, impersonal and efficient service, respecting all their rights and seeking solutions that meet their interests;
Value transparency and confidentiality of information, preserve the relationship of trust and harmony with our clients.
Do not share information about which you are not certain, preserving the privacy of the parties involved, sharing only what is expressly authorized.

b) Relationship with employees

Relationships should be based on cooperation, cordiality and respect, always oriented towards improving results;
The work environment must be preserved, always seeking to improve quality of life, hygiene and other factors that aim at good performance of activities;
The correct and responsible posture of employees is fundamental to maintaining an environment of respect and ethics, and creating healthy relationships with all stakeholders;
Expected behaviors include: collaboration; putting yourself in the customer's shoes; always telling the truth; passion for what you do; innovation and compliance with all D EMPREENDIMENTOS policies and procedures.
All employees must be treated with dignity and respect. Moral and sexual harassment, as well as abuse of power and discrimination are intolerable. D EMPREENDIMENTOS does not tolerate any type of discrimination.

c) Relationship with partners and third-party service providers

The selection and hiring of partners and third-party service providers must be based on technical, professional and ethical criteria, always conducted through competitive processes that guarantee the best cost-benefit ratio;
Avoid hiring or terminate the contract, as the case may be, of partners and third-party service providers with questionable reputation (whose performance indicates conduct divergent from this Code), who use child labor or in conditions analogous to slavery, as well as those who disrespect the environmental, cultural and social heritage of the community in which they operate.
All contracts entered into by D EMPREENDIMENTOS from the effective date of this Code must contain an anti-corruption clause appropriate to the risks represented by the counterpart's performance, providing for indemnities, penalties and/or the possibility of contractual termination in case of non-compliance with ethical standards and practice of fraud and corruption.

d) Relationship with the public sphere

Know, respect and comply with internal rules regarding the relationship with the public sector;
Refrain from any action, directly or indirectly, in favor of an offer, payment, promise of payment, gifts, authorization and/or approval of provision, of any money, goods or any other item of value for the benefit of any 'elected politician' (any person and/or individual who, by election, appointment, designation, contract or any other form of donation or bond, is, or holds a position as an official agent, employee or representative of a 'government authority', applying and not limiting to any federal, state, municipal, local or similar government, legislative judicial, executive, regulatory, administrative, agency, commission, court, tribunal, or any authority with jurisdiction over D EMPREENDIMENTOS and any direct, indirect or foundational administration entities of federal, state, municipal, territorial administration and any company or entity directly or indirectly controlled by any body and/or entity in the exercise of government function and any other authorities with jurisdiction over D EMPREENDIMENTOS.
Additionally any political party or national or foreign official, or any candidate for domestic or foreign political office with the purpose of influencing any official act or securing any improper advantage, or otherwise in violation of any applicable anti-corruption right, including:
Brazilian Anti-Corruption Law and its Decree (Federal Law No. 12,846/2013 and Decree No. 8,420/2015);
Brazilian Conflict of Interests Law (Federal Law No. 12,813/2013);
Brazilian Administrative Improbity Law (Federal Law No. 8,429/1992);
Brazilian Penal Code (Decree-Law No. 2,848/1940);
Brazilian Public Procurement Law (Federal Law No. 8,666/93),
Brazilian Electoral Law (Law No. 9,504/1997),
Brazilian Money Laundering Law (Law No. 9,613/1998) and
FCPA (Foreign Corrupt Practices Act) and all its updates and amendments over time.
D EMPREENDIMENTOS and its affiliates, directors, employees, agents or representatives acting on its behalf shall not make or authorize any bribe, discount, payment, influence payment, tip-off or other illegal payment of funds in violation of any law, rule or regulation.
Refrain from all forms of solicitation of authorities and/or public officials, with the aim of obtaining privileges or advantages;
Repudiate any form of corruption and disclose to its teams the rules brought by Law 12,846/2013 (Brazilian Anti-Corruption Law) and Law No. 9,613/1998 (Law on 'Money Laundering' crimes).

e) Relationship with the press

We must ensure the reliability of information transmitted to media outlets, ensuring that any statement or pronouncement on behalf of the company is made only by authorized persons;
Forward any request made by media outlets (newspapers, TV, radio, websites, etc.) to the Marketing Department of D EMPREENDIMENTOS.
It is forbidden to expose internal matters to the press, as we value the confidentiality of information;
Know how to separate your personal opinion from D EMPREENDIMENTOS's opinion and remember not to associate your opinion with the Company's image.

f) Gifts, Presents and Favors

D EMPREENDIMENTOS does not allow its employees to offer or accept directly, or through third parties, gifts, presents or favors that may indicate any type of favoritism to the company or the individual and that may affect decisions in negotiations;
Values or gifts above R$ 500.00 must be directed to the Compliance area, which will take the matter to the Governance, Risks and Compliance Committee;
Institutional gifts of small value, such as agendas, pens, pen drives, t-shirts, among others, will not be considered in these cases;
The receipt of any gifts, invitations or presents that, considering the circumstances, may be interpreted with the intention of affecting the impartiality of their recipient must be reported to the Risk and Compliance Department, and in these cases, they must be immediately refused.

g) Donations

Any form of contribution, donation and/or incentives to politicians, candidates for any type of public office at any government level, whether municipal, state or federal, and political campaign with funds and/or assets of D EMPREENDIMENTOS is prohibited.
Employees (internal, external and third parties), affiliates, directors and representatives of D EMPREENDIMENTOS who interact directly or indirectly with politicians, political candidates, political campaign and other campaign purposes must immediately communicate the fact to D EMPREENDIMENTOS and its directors.

05. Specific Topics

I. Conflict of interest

For the purposes of this Code, a conflict of interest is understood as anything that may favor the individual to the detriment of the Company. In order to avoid conflicts of interest, whenever the situations exemplified below are found, they must be immediately and formally communicated to the Risk & Compliance Department, via the following email: compliance@midassolucoes.com.br

Development of activities outside the company that interfere or may interfere with the business of D EMPREENDIMENTOS;
Private relationships with clients, suppliers or competitors that compromise impartiality in business;
Existence of kinship or personal relationship that may bring benefits to the individuals involved or harm to D EMPREENDIMENTOS;

II. Prevention of Money Laundering and Terrorism Financing

D EMPREENDIMENTOS maintains strict controls regarding the Prevention of Money Laundering and Terrorism Financing, not being complicit in transactions based on illicit activities;
All employees must be trained and guided regarding the rules and internal procedures related to the prevention of money laundering, provided for in the Policy for the Prevention of Money Laundering and Terrorism Financing;
Employees must be aware of the importance of the fight against organized crime and collaborate to prevent money laundering and terrorism financing, immediately communicating to the Risk and Compliance Department any operation that may be considered suspicious for presenting evidence or certainty that it is related to money laundering and/or terrorism financing.

III. Information Security

The confidentiality of financial data constitutes a duty of D EMPREENDIMENTOS to keep customer data protected.
Maintaining the strict confidentiality of D EMPREENDIMENTOS information to which they have access due to the functions performed is one of the greatest responsibilities of persons subject to the Law. The use and handling of this information deserves special attention, as it seriously impacts the organization's image;
Use all information to which they have access, or come to know, only for the purpose of their professional activity;
Maintain confidentiality about personal or non-personal data, or confidential facts to which they have access, in order to preserve, within the law, the interests of D EMPREENDIMENTOS and its clients, or any person, even after leaving the company;
Immediately communicate any incident that may put at risk the security and privacy of personal data;
Do not obtain advantages, for yourself or for third parties, resulting from privileged access to information, even if they do not cause harm to D EMPREENDIMENTOS;
Never, under any circumstances, share your corporate passwords with third parties;
Access to systems, documents, solutions, programs, applications or other electronic/physical means of the company and its clients must be made exclusively for professional use. They must not be used for external purposes, personal benefit or disclosure to third parties;
All D EMPREENDIMENTOS employees are subject to the terms of the Confidentiality Statement signed by them, which regulate the use and care to be taken with the organization's confidential Information.

IV. Economic sanctions

D EMPREENDIMENTOS, as well as its affiliates, directors, employees, agents and representatives who act on its behalf, will be subject to:

The applicable sanctions by virtue of a designation on lists of prohibited persons, including but not limited to lists maintained by the US Department of the Treasury, the United Nations Security Council, the European Union and Her Majesty's Treasury ('Sanctioned Person');
Organization, resident or located in a country, region or territory that is the subject or target of any applicable comprehensive sanctions ('Sanctioned Country') (for example, Cuba, Iran, Sudan, Syria, Democratic People's Republic of Korea or the Crimea region in Ukraine); or
Involved in any transactions or activities prohibited with any Sanctioned Person or Sanctioned Country, or otherwise in violation of any applicable sanctions.

V. Harassment

D EMPREENDIMENTOS values a healthy and psychologically safe work environment, not tolerating any type of harassment in behaviors such as those exemplified below:

Verbal or physical abuse;
Aggressiveness;
Verbal or physical sexual advance and also, with sexual connotation jokes and;
Disrespectful comments and public exposure of an employee;
Violent communication;
Unprofessional behaviors;
Isolation or limitation of a professional's performance;
Religious persecution;
Request for unnecessary or impossible activities;
Xenophobia.

06. Training

The Compliance area will conduct training for D EMPREENDIMENTOS employees, at least annually, on Ethics and Conduct and other relevant content, using participation control instruments, as well as mechanisms to verify understanding of the information, with the objective of increasing the degree of adherence to D EMPREENDIMENTOS guidelines.

07. Doubts, Queries, Clarifications and Complaints

The Risk and Compliance Department is available to persons subject to this Code to advise, clarify, guide and evaluate non-compliance or potential non-compliance with this Code of Ethics and Conduct.

In case of doubts about this document, queries and guidance on the correct conduct to be adopted, contact the Risk and Compliance Department immediately and formally.

In case of suspicion or knowledge of facts that may harm D EMPREENDIMENTOS, or even infringe, contradict or even seem to contradict the principles of this Code of Ethics and Conduct, it is the duty of all subjects to this Code, whether natural or legal persons, to contact the compliance department (Wilson de Sousa Ribeiro) immediately, at the email compliance@midassolucoes.com.br.

D EMPREENDIMENTOS does not tolerate any form of retaliation against the whistleblower who has made a good faith communication, even if unfounded. Any retaliation, if proven, will be considered a violation of this Code of Ethics and Conduct.

If you suffer retaliation, or have any concerns about any type of retaliation, contact the Risk and Compliance Department immediately or register a new report via email, as no form of retaliation or threat will be tolerated by D EMPREENDIMENTOS.

Communications received by email will be forwarded for investigation and treatment by the Governance, Risks and Compliance Committee (GRC).

The treatment of complaints will be carried out through investigations - internal and/or external, and when the investigation of the facts is completed, the Governance, Risks and Compliance Committee (GRC) will deliberate on the merits or lack of merit of the complaint. If the complaint is found to be well-founded, the Committee (GRC) will also deliberate on the appropriate measures to be adopted regarding the natural/legal person reported, based on Chapter 8 - Penalties in case of non-compliance, which is part of this document.

08. Penalties in Case of Non-Compliance

In case of violation of any norm established in this Code, the Governance, Risks and Compliance Committee (GRC Committee) will be activated, and must evaluate the facts, in order to ensure the prompt interruption of the irregularity, the timely remediation of the damages generated and apply, as the case may be, the disciplinary measures below, in any order, depending on the severity of the situation:

a. Warning through formal letter and registration in the dossier of the person subject to the Code of Ethics and Conduct, as the case may be; and/or

b. Suspension of activities, which may vary from three to thirty days; and/or;

c. Termination/dismissal under the law.

09. Management of the Code of Ethics and Conduct

The management of the Code of Ethics and Conduct of D EMPREENDIMENTOS is the responsibility of the Compliance Department (Wilson de Sousa Ribeiro) who is responsible for its dissemination, updating and application.

The Code is a dynamic document, subject to periodic revisions. Comments and suggestions from employees will always be welcome and may be received by the Risk and Compliance Department.

Each person subject to this Code must acknowledge their knowledge, through a document available at the time of hiring.

The sending of the Code of Ethics and Conduct for acknowledgment will be carried out by the HR Department together with other documents pertinent to the hiring of employees, with this same department being responsible for storing the signed document.

10. Final Provisions

D EMPREENDIMENTOS will not use directly or indirectly the proceeds of any capital issuance, or lend, contribute or make such proceeds available to any subsidiary, or other person, to finance or facilitate any activities or businesses prohibited from or with any Sanctioned Person and/or Sanctioned Country.

Conflicts arising from this document must be directed to the Compliance Department (Wilson de Sousa Ribeiro) for treatment.

This document is integrated with the other policies of D EMPREENDIMENTOS and will come into force on the date of its approval by the Governance, Risks and Compliance Committee (GRC).

11. Versioning

Date	Version	Responsible	Description
04/15/2025	1.0	Compliance	Document creation

12. Approval

Elaboration

Compliance Department - Wilson de Sousa Ribeiro

Approval

Governance, Risks and Compliance Committee (GRC)

D EMPREENDIMENTOS LTDA, CNPJ 45.810.376/0001-08
R. Pernambuco, Room 09, 750, Chacara Brasil - São Luís, MA.
ZIP 65066-851

Last update: 03/05/2025