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Code of Ethics

Version 1.0 | January 2026

1. Purpose and Scope

This Code of Ethics establishes the fundamental principles and standards of conduct that guide all activities at Epic Digital Tecnologia de Informação Ltda. and its subsidiaries. It applies to all employees, contractors, 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 honestly and transparently in all our dealings. We keep our promises and take responsibility for our actions.

Excellence: We strive for 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 fostering an inclusive environment.

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

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

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

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 agreed-upon standards and timelines
  • Communicating openly and honestly about project status, challenges, and opportunities
  • Protecting client confidential information and intellectual property
  • Avoiding conflicts of interest that could compromise our objectivity
  • Providing honest assessments and recommendations, even when difficult

3.2 Workplace Conduct

All Epic Digital team members are expected to:

  • Treat colleagues with respect and professionalism
  • Foster a collaborative and supportive work environment
  • Communicate constructively and address conflicts professionally
  • Respect others' time, work, and contributions
  • 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 12.846/2013) and international anti-corruption standards.

Prohibited conduct includes:

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

For complete details, please refer to our Anti-Corruption Policy.

5. Confidentiality and Data Protection

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

  • Safeguard client and company confidential information
  • Comply with data protection laws (LGPD, GDPR, and other applicable regulations)
  • Only access information necessary for their work responsibilities
  • Report any suspected data breaches immediately
  • Properly dispose of confidential information when no longer needed

6. Respect and Non-Discrimination

Epic Digital is committed to maintaining a workplace free from 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. This includes:

  • Financial interests in client competitors or vendors
  • Outside employment that interferes with Epic Digital responsibilities
  • 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. Reports can be made to:

  • 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, up to and including termination of employment or contract.

9. Acknowledgment

All Epic Digital team members 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