Code of Ethics and Conduct

Last updated: July 4, 2025

1. Introduction and Objective

This Code of Ethics and Conduct ("Code") establishes the principles and values that guide the actions of IDGN IT Solutions and its employees. Its objective is to ensure a professional, honest, transparent, and respectful environment in all our relationships, whether with clients, partners, suppliers, government entities, or society. This document is the main guide for our corporate culture and applies to all, without exception.

2. Fundamental Principles

Our conduct is based on the following non-negotiable principles:

• Integrity and Honesty: Acting with uprightness, transparency, and loyalty in all professional activities.
• Legality: Strict compliance with all applicable laws, regulations, and norms in the countries where we operate.
• Respect for People: Promoting a work environment free from discrimination, harassment, and prejudice, valuing diversity and inclusion.
• Confidentiality: Protecting all confidential information to which we have access, whether from IDGN, our clients, or partners.
• Technical Excellence: Committing to the continuous delivery of high-quality services and solutions, always seeking innovation and efficiency.
• Social and Environmental Responsibility: Conducting our business in a sustainable manner, respecting the environment and contributing to the development of the community.

3. Conduct in the Work Environment

We expect all employees to contribute to a healthy and productive work environment. This includes:

• Treating colleagues, superiors, and subordinates with respect and cordiality.
• Collaborating for teamwork and knowledge sharing.
• Using the company's assets (equipment, systems, facilities) responsibly and exclusively for professional purposes.
• Not engaging in or tolerating any form of moral or sexual harassment, intimidation, or discrimination.

4. Relationship with Clients

The client is the focus of our activities. Our relationship must be guided by:

• Transparency: Providing clear, accurate, and complete information about our services, solutions, deadlines, and costs.
• Confidentiality: Rigorously protecting all client information, in accordance with our Information Security Policy and the General Data Protection Policy.
• Quality: Delivering solutions that meet or exceed the client's expectations, fulfilling all contractual commitments.
• Ethics in Business: Not offering or promising undue advantages to obtain or maintain business.

5. Relationship with Suppliers and Partners

We select and maintain relationships with suppliers and partners who share our ethical values. We demand from them:

• Compliance with labor and environmental legislation.
• Rejection of child labor, forced labor, or any analogous condition.
• Integrity in all commercial negotiations.

6. Anti-Corruption and Anti-Bribery

IDGN IT Solutions has zero tolerance for corruption in all its forms. It is strictly forbidden for any employee or representative to offer, promise, give, authorize, or receive, directly or indirectly, any undue advantage (bribes, illicit payments, etc.) to public officials or private individuals to obtain or retain business or any other improper benefit. This guideline is in line with Brazilian Law No. 12,846/2013 (Anti-Corruption Law) and international best practices.

7. Conflict of Interest

A conflict of interest occurs when personal interests of an employee may influence or appear to influence their professional judgment or decisions. Employees must avoid situations of conflict and, if they arise, must immediately report them to their immediate superior and the Compliance Committee for proper handling.

8. Whistleblower Channel

We provide a secure and confidential channel for reporting violations or suspected violations of this Code, internal policies, or current legislation. The channel can be accessed via email at ouvidoria@idgn.com.br. All reports will be investigated with due diligence and impartiality, and retaliation against those who report in good faith is not tolerated.

9. Compliance Committee and Consequences

The Compliance Committee is responsible for disseminating, clarifying doubts about, and ensuring compliance with this Code. Violations of the rules established here are subject to disciplinary measures, which may include warnings, suspension, or termination for just cause, without prejudice to applicable civil and criminal penalties.