Code of Ethics.

1. Purpose and Scope

This Code of Ethics sets out the core principles and standards of conduct that guide all activities of Epic Digital Tecnologia de Informação Ltda. and its subsidiaries. It applies to all employees, service providers, partners and anyone acting on behalf of Epic Digital.

Our commitment is to conduct business with the highest standards of integrity, honesty and respect for all stakeholders, including clients, employees, partners and the communities we serve.

2. Core Values

Integrity: We act with honesty and transparency in all our relationships. We keep our promises and take responsibility for our actions.

Excellence: We pursue the highest quality in everything we do, continuously improving our skills and deliverables.

Respect: We treat everyone with dignity and respect, valuing diverse perspectives and promoting an inclusive environment.

Innovation: We embrace creativity and new ideas, always looking for better ways to serve our clients and improve our processes.

Collaboration: We work together as a team, supporting one another and our clients to achieve shared goals.

Accountability: We take ownership of our work and its results, learning from both successes and mistakes.

3. Professional Conduct

3.1 Client Relationships

We are committed to providing exceptional service to our clients. This includes:

• Delivering work that meets or exceeds the agreed standards and deadlines
• Communicating openly and honestly about project status, challenges and opportunities
• Protecting clients' confidential information and intellectual property
• Avoiding conflicts of interest that could compromise our objectivity
• Providing honest assessments and recommendations, even when they are difficult

3.2 Workplace Conduct

All members of the Epic Digital team must:

• Treat colleagues with respect and professionalism
• Promote a collaborative and supportive work environment
• Communicate constructively and resolve conflicts professionally
• Respect the time, work and contributions of others
• Maintain appropriate boundaries in professional relationships

4. Anti-Corruption and Compliance

Epic Digital maintains a zero-tolerance policy for corruption, bribery and fraud. We comply with all applicable laws and regulations, including the Brazilian Anti-Corruption Law (Law No. 12,846/2013) and international anti-corruption standards.

Prohibited conduct includes:

• Offering, giving or accepting bribes or kickbacks
• Making improper payments to public officials
• Falsifying records or financial statements
• Participating in fraudulent activities of any kind
• Using company resources for personal gain

For full details, see our Anti-Corruption Policy.

5. Confidentiality and Data Protection

We are committed to protecting confidential information and personal data. All team members must:

• Protect confidential client and company information
• Comply with data protection laws (LGPD, Brazil's General Data Protection Law, Law No. 13,709/2018; GDPR; and other applicable regulations)
• Access only the information necessary for their job responsibilities
• Immediately report any suspected data breach
• Properly dispose of confidential information when it is no longer needed

6. Respect and Non-Discrimination

Epic Digital is committed to maintaining a work environment free of discrimination and harassment. We prohibit discrimination based on:

• Race, color, ethnicity or national origin
• Gender, gender identity or sexual orientation
• Age or generation
• Religion or belief
• Disability or health condition
• Socioeconomic status
• Any other characteristic protected by law

Harassment of any kind, including sexual harassment, bullying and intimidation, is strictly prohibited and will result in disciplinary action.

7. Conflicts of Interest

Team members must avoid situations where personal interests could conflict with their duties to Epic Digital or our clients.

• Financial interests in competitors or suppliers of clients
• Outside employment that interferes with responsibilities at Epic Digital
• Personal relationships that could influence business decisions
• Use of company information or resources for personal benefit

Any potential conflicts of interest must be disclosed to management immediately.

8. Reporting and Enforcement

All team members are encouraged to report any violations of this Code of Ethics or other concerns about unethical conduct.

• Direct supervisor or manager
• Human Resources
• Compliance Committee

Epic Digital prohibits retaliation against anyone who reports concerns in good faith. All reports will be investigated promptly and confidentially.

Violations of this Code may result in disciplinary action, including termination of employment.

9. Acknowledgment

All members of the Epic Digital team are required to read, understand and comply with this Code of Ethics. Annual training on ethical conduct is mandatory for all employees.

Epic Digital Tecnologia de Informação Ltda.
São Paulo, Brazil · Orlando, FL, USA
www.epic.digital