Code of Ethics and Compliance

Integrity and Compliance Program

1. Scope

With corporate commitment and responsibility, Openlex Soluções Tecnológicas LTDA's main scope is to build trust with all employees and partners, clients, government entities and the community. This commitment is expressed primarily through our Code of Ethics, which is conceived, structured and repeatedly reviewed around the rules that reflect our culture, mission and values, with the goal of fostering a culture of integrity, sustainability, honesty, transparency and good-conduct policy.

2. Purpose

Turn data into decisions

Connecting relevant information with intelligence and technology, helping organizations ensure the sustainability of their businesses.

3. Senior Management Commitment

This program is conceived and structured by the Board of Directors together with the Compliance Committee, who are fully committed to the effective implementation and effectiveness of the conduct rules outlined here.

4. Compliance Committee

The Compliance Committee is led by the Compliance Officer Ivan Ervolino, who has full autonomy in the implementation and oversight of the program. The position will be held for a term no shorter than the established stability period, and may only be vacated for justified reason, duly endorsed by the Arbitration Chamber — São Carlos/SP District.

The Compliance Committee is composed of Frederico Amaral de Oliveira and Danilo Amaral de Oliveira, who report exclusively to the Compliance Officer in order to ensure effectiveness and neutrality in conducting the program.

Code of Ethics and Conduct

This Code of Ethics covers the main ethical and moral guidelines that must conduct the company's internal, business and governmental relations. It applies to all employees, including those of the supplier group companies.

5. Commitment and Seriousness

Among the company's values, the pursuit of excellence with ethics and transparency is a pillar supporting the history and growth of Openlex Soluções Tecnológicas LTDA, which is why senior management and employees commit to this code and to compliance with the laws, valuing its applicability and efficiency.

6. Environmental Sustainability

Among the priorities of Openlex Soluções Tecnológicas LTDA, the protection of a balanced environment is grounded in compliance with environmental rules and in programs to combat pollution and foster sustainability, such as: environmental awareness and recycling of materials used.

7. Decision Making

Any decision to be made internally, commercially or in any way related to the corporate structure must be made observing the following guidelines:

• Is this a decision contrary to the law? It must not be made.
• Is this a decision contrary to this code of ethics, the company's values or culture? It must not be made.

In case of doubt about any of the questions above, or in the existence of any conflict of interest, the direct supervisor or the Compliance Committee must be consulted.

8. Conflict of Interest

A conflict of interest occurs whenever there is personal benefit in conflict with ethics or the company's interests. To avoid such situations, the following must be avoided:

• Recruiting or keeping close friends, relatives and spouses on the team;
• Receiving advantages and gifts;
• Buying shares of companies based on privileged information;
• Acquiring products or services on privileged conditions from company suppliers;
• Acquiring shares of suppliers.

In case of doubt about any of the situations above, the direct supervisor or the Compliance Committee must be consulted.

9. Internal Relationships — Mutual Respect

The internal relationship between employees must value full civility and respect, regardless of existing hierarchy. The following are not admitted under any circumstances:

• Conduct that privileges or discriminates against any employee based on social class, color, gender, sexual orientation, origin, race, age, religion, marital status or physical condition;
• Conduct that causes any private or public embarrassment;
• Conduct that disrespects any labor rule or regulation;
• Conduct that puts any employee at risk.

The conduct indicated above will be treated with the necessary rigor, regardless of whether it occurs inside or outside the company's premises.

10. External Relationships — Clients

All work built and developed by the company has client satisfaction as a premise and inspiration. With this objective, every relationship with the client must observe:

• Transparency in the relationship, providing with priority and clarity any information of interest to the client that is not protected by industrial secrecy;
• Prioritize client satisfaction without violating any ethical rule or company culture;
• Respect consumer protection rules, in particular by acting honestly in advertising and sales;
• Pay special attention to after-sales, allowing broad access and clarifications regarding assistance or questions about the service provided;
• Compliance with the provisions of Law 13,709/18 (LGPD), which regulates the protection of personal data, and Law No. 12,965/14 (Brazilian Internet Civil Framework);
• Ensure client security in all its spheres.

In case of doubt about any of the situations above, the direct supervisor or the Compliance Committee must be consulted.

11. External Relationships — Public Clients

Based on the Anti-Corruption Law, the Public Procurement Law, the Administrative Improbity Law, among other related rules, the relationship with public entities will observe the following guidelines:

• Proposals and contracts will be conducted strictly as provided in the Public Procurement and Contracts Law;
• No additional advantages, proposals or contacts will be tolerated, other than those strictly proceduralized in the Public Contract Procurement Manual.

12. External Relationships — Suppliers

The selection of suppliers will be conducted based on the following guidelines:

• Require suppliers to observe this Code of Ethics;
• Prioritize suppliers that have implemented an Integrity Program;
• Select suppliers based on objective criteria;
• Select suppliers based on the highest quality, price, expertise, credibility and market reputation.

13. External Relationships — Competitors

All conduct and decision-making must prioritize the client, guided by ethics and transparency. On this foundation, no conduct characterizing unfair and anticompetitive competition will be tolerated, such as:

• Price-fixing;
• Division of clients and market;
• Use of privileged information;
• Dumping, Tipping or Antitrust practices.

14. Confidentiality and Industrial Secrecy

Any internal information is protected by industrial secrecy and may not under any circumstances be disclosed, shared or reported externally without the express consent of the company. This secrecy equally covers information related to employees.

15. Company Image and Culture

Every employee carries the company's image, and conduct that violates ethics, morals and current laws is not tolerated, both in the workplace and outside it.

16. Integrity Program

Implementation of this integrity program will take place as follows:

• Training: Initial qualification training will take place in individualized sectors, according to the schedule attached to this Code of Ethics.
• Refresher: Qualification training will be repeated every 3 months, according to the schedule attached to this Code.
• Adjustment process: Training dedicated to employees who acted or were involved in unethical conduct, consisting of awareness and warning sessions.
• Support material: During training, study and support material will be distributed with a copy of this code of ethics, including main questions and answers.

Training will be conducted by Ivan Ervolino.

17. Support Channel

Whenever there is any doubt regarding compliance or non-compliance with this code on a conduct, every employee will have access to the Support Channel at the address: compliance@sigalei.com.br.

18. Whistleblower Channel

Whenever there is any conduct that infringes or puts at risk the observance of this Code of Ethics, every employee will have access to the Whistleblower Channel at the address: denuncia@sigalei.com.br.

19. Privacy

Any complaint, support request, inquiry or communication will be kept in total secrecy and must be handled and concluded only between the Compliance Committee and those involved.

20. Oversight and Effectiveness

Compliance with these guidelines will be verified weekly through audits performed by the Compliance Committee, which will keep monthly reports on findings, improvements and treatment of any non-conformities.

21. Treatment of Non-Conformities

Once a non-conformity is identified — whether through the Whistleblower Channel, Audit or any other means — immediate treatment must be carried out, adopting coercive and remedial measures within a maximum of 7 business days of registration.

22. Sanctions and Adjustment Process

Every employee who acts or is involved in unethical conduct will be subject to the following measures:

• Warning and adjustment process, in the case of minor conduct, considered to be that which does not pose risk to the client and does not represent any ethical or legal infraction;
• Dismissal for cause, without prejudice to applicable civil and criminal actions, in cases of conduct contrary to this Code of Ethics or the law.

23. General Conditions

This Code does not exhaust all possible ethical issues related to business activity, and does not restrict possible coercive measures to any conduct that offends common sense, ethics and morals.

This Code of Conduct enters into force upon its disclosure, with no end date, and must be reviewed at least every 6 months.