Anti-Corruption Policy and Code of Ethical Conduct.

Scope

The long-term success of EPIC DIGITAL rests on the principle of ethical conduct by its employees, who carefully observe laws and internal regulations and respect the highest standards of conduct and ethical integrity.

EPIC DIGITAL is founded on the idea that no one in the company may sacrifice their integrity, whether to obtain personal advantages or to obtain benefits for the business.

The Code of Ethical Conduct and Anti-Corruption Policy applies to all employees.

Workplace

EPIC DIGITAL respects and promotes human rights in its activities. It is committed to a non-discriminatory workplace and prohibits discrimination and harassment against any person based on race, color, nationality, creed, religion, age, sex, sexual orientation, physical disability, or any status protected by law.

A diversity of people brings broader professional and personal experience, contributing to distinctive service for an equally diverse range of clients. Applying diversity standards to contracts with suppliers and clients demonstrates that business is based on service quality, credibility, and price.

Secrecy and Confidentiality

All employees and suppliers are responsible for safeguarding information, whether confidential or not, related to EPIC DIGITAL, clients, and suppliers, as set out in the GENERAL SECRECY AND CONFIDENTIALITY UNDERTAKING.

Inside Information Policy

Inside information means any nonpublic information about a public entity. The use of inside information is governed by laws, including those that prohibit its misuse. EPIC DIGITAL has conduct standards in place to ensure compliance with these laws and prevent improper occurrences.

Anti-Corruption Policy

Purpose and Scope

To describe and explain the prohibitions against bribery, corruption, and other fraud in all operations of EPIC DIGITAL Tecnologia de Informação Ltda. (headquarters and branches), establishing guidelines and conduct standards and ensuring that Employees observe the requirements of the Brazilian Anti-Corruption Law (Federal Law No. 12,846, the Brazilian Clean Company Act, enacted on August 1, 2013) and Decree No. 8,420/2015, reinforcing the commitment to conduct its business with the highest standards of honesty and integrity. This Policy must always be interpreted and applied together with the INTERNAL REGULATIONS of EPIC DIGITAL.

This Policy applies to all employees, officers, clients, suppliers, and partners of EPIC DIGITAL.

Rules: Introduction

EPIC DIGITAL (headquarters and branches) is committed to promoting ethical conduct in compliance with the legal system in force and with the principles and values set out in its INTERNAL REGULATIONS. EPIC DIGITAL (headquarters and branches) must comply with all legislation that applies to the business and activities it carries out, including international or transnational legislation where applicable.

General Considerations on the Anti-Corruption Law: Law No. 12,846/2013 and Decree No. 8,420/2015. The anti-corruption law, regulated by Decree No. 8,420/2015, provides for the administrative and civil liability of persons for acts committed by their employees or by third parties acting on their behalf against the public administration, whether domestic or foreign.

Conduct prohibited by the Anti-Corruption Law

• I. Promising, offering, or giving an undue advantage to a public official or to a third party related to them;
• II. Provably financing, funding, or sponsoring the commission of unlawful acts;
• III. Hindering investigation or oversight activities of public bodies, entities, or officials.

Culture and Awareness

Refusing to tolerate any act of noncompliance with the law, especially acts of corruption, is part of the Organizational Culture of EPIC DIGITAL (headquarters and branches). All actions, programs, and projects are always designed and developed based on best practices and in strict compliance with the applicable legal system.

Responsibility of all employees

Employees must stay alert to situations that may indicate that undue advantages or payments are occurring, and they are required to report all suspicious situations to EPIC DIGITAL Management.

Employees must pay special attention to transactions in which the undue payment or benefit may be received by any person, whether a Public Official (including their family members) or not, and they are required to report all suspicious situations to EPIC DIGITAL management.

All employees are responsible for reporting any violation and/or suspected violation of the rules of this Policy.

Reports of violations and suspected violations, whether identified or anonymous, may be made directly to EPIC DIGITAL management.

Responsibilities of suppliers and business partners

• EPIC DIGITAL suppliers and/or partners must know the full content of the Anti-Corruption Law and comply with all of its rules;
• No EPIC DIGITAL supplier and/or business partner is authorized to offer any benefit on behalf of EPIC DIGITAL for the purpose of obtaining an undue benefit, especially in dealings with public officials;
• No EPIC DIGITAL supplier and/or business partner is authorized to outsource, transfer, or share an obligation arising from a signed contract without express authorization previously provided for in a rule or in a contract signed with EPIC DIGITAL (headquarters and branches);
• All EPIC DIGITAL suppliers and/or partners are responsible for reporting any violation and/or suspected violation of the rules of this Policy;
• Reports of violations and suspected violations, whether identified or anonymous, may be made directly to EPIC DIGITAL Management.

Examples of Situations Requiring Attention

Employees, officers, and suppliers or partners of EPIC DIGITAL (headquarters and branches) have a duty to ensure compliance with anti-corruption rules and with this Anti-Corruption Policy, remaining vigilant about the activities and practices of other employees, partner companies, or third parties and reporting suspicious situations to EPIC DIGITAL Management.

Examples of situations that require careful analysis:

• Any refusal to comply with anti-corruption rules;
• Carrying out unusual procedures or contracting, or procedures or contracting outside established procedures, without an exception authorization previously provided for in a rule of EPIC DIGITAL (headquarters and branches);
• A transaction with a third party that has a poor business reputation or refuses to provide all information about the deal.

Any employee who identifies any of these situations, or any other suspicious situation, must report it (even anonymously) to EPIC DIGITAL Management.

Sponsorship

Events or initiatives may be sponsored without breaching this policy or the Anti-Corruption Law, provided the sponsorship is unrelated to any purpose of undue benefit. In all cases, approval from EPIC DIGITAL Management is mandatory, after submission of a project detailing the amounts involved, the benefits to the business and/or society, and information about the sponsored party. The project must include a history and profile analysis of the sponsored party, with emphasis on an unblemished reputation and no involvement in situations of suspicion of, or conviction for, crimes such as fraud and corruption. Those responsible for the sponsorship proposal will also be responsible for monitoring the proper use of the assets given as sponsorship. All sponsorships must be based on formal contracts between EPIC DIGITAL (headquarters and branches) and the institutions receiving the sponsorship.

Gifts and Hospitality

Gifts and hospitality, understood as courtesies and payment of entertainment expenses, will be permitted only for institutional, commercial, or marketing purposes, and always in compliance with the law and with the Internal Regulations of EPIC DIGITAL and of the companies or entities with which it maintains relationships.

No giveaway, gift, trip, or entertainment may under any circumstances be given to any person, whether a Public Official or not, to improperly influence or reward an act or decision, as actual or intended compensation for any benefit to EPIC DIGITAL (headquarters and branches), its owners, and its employees (Direct and Third-Party).

No form of gift that may be intended to obtain an undue benefit is permitted. This excludes institutional or promotional gifts or invitations, meaning those that display the company's logos and/or products and are of Nominal Value.

Employees of EPIC DIGITAL (headquarters and branches) are not permitted to accept courtesies, gifts, or any benefit of any kind or value from persons in any way connected with corporate activities (outsourcing companies, partners, clients, etc.) and that are in any other way capable of giving the impression that they are intended to obtain or grant an undue benefit.

Employees who receive benefits or courtesies outside the permitted cases must notify EPIC DIGITAL Management, which will evaluate the case and, when possible, forward the items for donation.

Participation in Competitive Bidding, Purchasing, and Contracting

All purchasing and contracting must follow the terms of the Purchasing Policy and/or the Contracts Policy of EPIC DIGITAL (headquarters and branches). Contracting for goods and services through the improper use of influence over any person, whether a Public Official or not, is prohibited.

Employees of EPIC DIGITAL (headquarters and branches) may not receive or offer any kind of gift or entertainment, from or to any individual or legal entity, whether a Public Official or not, that may improperly influence or reward an act or decision, as actual or intended compensation for any benefit to the Company and its owners.

Specific situations: Public Procurement

Participation in Public Procurement must strictly follow the legislation in force. All information provided must be truthful. No action aimed at facilitating or circumventing the requirements of an ongoing bidding process is authorized. No direct or indirect action with any public official or other person intended to secure a contract with the Federal, State, or Municipal governments by circumventing competition rules is authorized.

Any act for the following purposes is prohibited:

• Frustrating or defrauding, through agreement, collusion, or any other means, the competitive nature of a public bidding procedure;
• Preventing, disrupting, or defrauding the performance of any act of a public bidding procedure;
• Removing or seeking to remove a bidder through fraud or the offer of an advantage of any kind;
• Defrauding a public bidding process or a contract arising from it;
• Fraudulently or irregularly creating a legal entity to participate in a public bidding process or to enter into an administrative contract;
• Fraudulently obtaining an undue advantage or benefit from modifications or extensions of contracts entered into with the public administration, without authorization in law, in the public bidding notice, or in the respective contractual instruments;
• Manipulating or defrauding the economic and financial balance of contracts entered into with the public administration.

EPIC DIGITAL may decide to restrict contracting with the public sector.

EPIC DIGITAL (headquarters and branches) must comply with all legislation that applies to the business and activities it carries out. Information requested by tax auditors of any government entity must be answered truthfully, and offering any kind of advantage to the auditor to avoid or prevent an inspection, and thereby obtain an undue benefit, is not permitted.

Compliance Monitoring

Employees must be aware that violations of this Code will be treated with the utmost seriousness and will be subject to the applicable disciplinary actions, regardless of hierarchical level, without prejudice to the applicable legal penalties.

Violations may result in penalties at the discretion of EPIC DIGITAL, ranging from a warning to dismissal, always in accordance with the civil, labor, and criminal legislation in force. Where a violation may cause damage to EPIC DIGITAL, the company may file a lawsuit and claim the corresponding damages.

EPIC DIGITAL (headquarters and branches) monitors compliance with this policy using internal tools, particularly information from Management and Audits.

Direct Communication Channel

Just as each Employee is responsible for their own actions, they may also be held responsible for the actions of third parties if it becomes clear that they knew those persons were violating the Code and did nothing.

EPIC DIGITAL (headquarters and branches) follows corporate governance best practices, respecting the confidentiality of reports and protecting whistleblowers by preserving the confidentiality of information.

Reports must be sent to:

• Email: condutaetica@epic.digital
• Or, alternatively, reported to EPIC DIGITAL management: Fabio Munhoz Perachini · CEO · +55 11 99950-6847

The confidentiality of anyone who raises concerns or reports will be respected, and no retaliation or intimidation against the reporter will be tolerated.

Statement of Agreement

The commitment of all EPIC DIGITAL employees is essential for this Code of Ethical Conduct and Anti-Corruption Policy to be a true instrument of guidance and conduct, lived and applied in everyday professional life.