Investor Presentaiton

26 GOVERNANCE, RISKS AND COMPLIANCE COMPLIANCE AND CODE OF ETHICS GRI 102-17, 103-2 2021 INTEGRATED ANNUAL REPORT PODCAST CÓDIGO DE ETICA LIM COMPROMISSO TODOS HOS Podcast format Code of Ethics disclosure poster In 2021, we joined the Business Pact for Integrity and Against Corruption, linked to the Ethos Institute, strengthening our commitment to promoting a fairer and more ethical market. The action continues the advances made in the theme in 2020, when the company joined the UN Global Compact. Our action is also in line with SDG 16 Peace, Justice and Strong Institutions, especially target 16.5 - Substantially reduce corruption and bribery in all their forms. - GRI 102-12, 102-13, 103-2, 103-3 [205 Our Code of Ethics disseminates the principles and values of the Company, its subsidiaries and affiliated companies, guiding the conduct of all employees, managers, legal representatives and third-parties, making explicit the pattern of behavior expected in the relationship with stakeholders. Concerning internal integrity policies, we have adopted, among others, the following regulations: Anti-Corruption Policy; Gifts, Ammenities, Entertainment and Hospitality Policy; Policy on Related-Party Transactions and Other Situations Involving Conflict of Interest; Donations and Sponsorship Policy; Internal Investigation Protocol and Ethical Channel Operation; Consequences Policy; Purchasing and Supplies Policy; Risk Management Policy; Good Practices and Competition Policy; and Supplier's Code of Conduct, launched in 2021. The Code of Ethics and these policies are available for consultation on our internal communication platform and the Company's website, GRI 103-2, 103-3 ETHICAL CHANNEL We provide employees and other stakeholders with the Ethics Channel, a tool for reporting conducts in violation of our Code of Ethics and other internal policies. This is an independent, specialized and secure channel, accessible by phone, email or internet, and ensures anonymity and protection for those who make reports in good faith. Such reports are received by an independent company and, based on the identification of the matter of the complaint, are addressed for investigation and accountability with the body or entity responsible for the Company's governance structure. When relevant, actions are established to improve internal controls and/ or apply disciplinary measures. At the end of the process, feedback is given to the reporting individual, through the Ethical Channel. It is worth noting that in 2021, most notifications (99%) were investigate by the compliance area and submitted to the Company's Ethics Committee. Complaint mechanisms Complaints 2019 2020 2021 Number of complaints identified through the mechanism 876 992 1012 Number of complaints addressed Number of complaints resolved 876 992 1012 679 840 919 The main types of reports include: Interpersonal relationships (424), Doubts, criticisms and suggestions (194), Non-compliance with internal regulations (100), Non-compliance with protocols for preventing and combating covid-19 (48), Dissatisfaction with human resources policies (45), Moral harassment (44), Fraud (36), Conflict of interests (33) and other types (88). No reports of corruption involving public officials and government authorities were recorded at the Ethical Channel in 2021. In addition, we were not subject to administrative or judicial sanctions for acts against national or foreign governments, pursuant to the terms of the Anti-Corruption Law. GRI 205-3 COMMUNICATION AND TRAINING Communications on the Code of Ethics and compliance policies, including Anti-corruption Policy, were carried out on a regular basis throughout 2021, in the internal communication vehicles. We had a total of 25 publications in Workplace, with around 30 thousand views. We also released a podcast version of the Code of Ethics, available on the streaming plaform, Spotify. We also carried out 12 training actions, amounting to 18,000 hours, reaching 4,365 professionals, including officers, managers, coordinators, supervisors and other employees. In May 2021, at a Business Meeting with Some disclosures reinforce with employees the Leadership, under the Leader Development Program (PDL), we discussed the Compliance Program with 677 managers participating in the event. For the newly hired employees, these topics are included in the on- boarding process. REPUTATION AND CONFLICT OF INTEREST We monitor operations that are most exposed to corruption and money laundering risks. We also carry out reputational checks on business partners, including suppliers, customers, recipients of donations and sponsorships, through the data mining system in public sources. We also monitor transactions involving Related Parties, as well as we request, annually, the submission of the statement of conflict of interest to our Management, aiming to identify possible conflicts and address them, if necessary. Thus, we ensure that decisions involving Related Parties, and other situations of potential conflict of interest, are made in the best interest of the Company. anti-corruption stance ANTICORRUPÇÃO **ANTICORRUPÇÃO L ANTICORRUPÇÃO ANTICORRUPÇÃO M. Dias Branco adere do Pacto Empresarial pela Integridade e Contra a Corrupção

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