Compliance Policy

1. Introduction

This Policy consolidates PraQuitar Tecnologia e Serviços Financeiros Ltda.'s commitment to integrity, professional ethics, transparency, and compliance with laws and regulations applicable to Brazil's National Financial System. It applies to employees, officers, shareholders, providers, business partners, and others acting for PraQuitar.

2. Principles and Values

• Integrity: ethical and responsible conduct.
• Transparency: clear information to clients, partners, and authorities.
• Legality: strict observance of law and regulation.
• Fiduciary responsibility: diligence with third-party resources and information.
• Sustainability: balance between operational efficiency and social and environmental responsibility.

3. Regulatory Compliance

PraQuitar operates under the CORBAN model with authorized financial institutions and QI Tech infrastructure, observing CMN and BACEN rules, Brazil's AML Law, Anti-Corruption Law, LGPD, Consumer Protection Code, Internet Civil Rights Framework, and other applicable standards.

4. Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT)

Controls include customer, partner, and supplier identification; risk-based assessments; monitoring of unusual transactions; reporting to COAF where required; statutory record retention; and screening against UN, OFAC, Brazilian, and international sanctions lists.

5. KYC and Due Diligence

Relationships are preceded by risk-proportionate identification and qualification. PraQuitar may request additional documents, conduct bureau, adverse media, and sanctions checks, refuse or terminate relationships on reasonable grounds, and periodically reassess risk.

6. Anti-Corruption and Anti-Bribery

PraQuitar rejects corruption, bribery, fraud, and improper advantages under Brazilian law, the FCPA, UK Bribery Act, and other applicable rules. Offering or receiving improper advantages, facilitation payments, and using third parties for unlawful acts are prohibited.

7. Conflicts of Interest

Covered Parties must act in the best interests of PraQuitar and its clients. Actual or apparent conflicts involving personal, family, or economic interests must be formally disclosed to Compliance.

8. Third-Party and Supply Chain Management

Third parties undergo risk-based due diligence covering reputation, legal, tax, labor, and AML/CFT matters. Contracts include integrity, anti-corruption, data protection, and audit clauses.

9. Training and Culture

PraQuitar provides onboarding and periodic training on Compliance, Ethics, AML/CFT, LGPD, Anti-Corruption, and Information Security.

10. Monitoring, Internal Controls, and Audit

The program is continuously monitored through policy reviews, effectiveness metrics, risk indicators, and internal audits. Independent audits may occur as required by regulators or management.

11. Reporting Channel

PraQuitar maintains a channel for reports, concerns, and questions, including anonymous reports. Confidentiality, protection of good-faith reporters, non-retaliation, and diligent impartial investigation are ensured. Contact edgard.melo@praquitar.com.br with subject “Reporting Channel.”

12. Internal Sanctions

Violations may lead to warnings, suspension, termination for cause, notification to authorities, and judicial measures, depending on severity.

13. Updates

This Policy may be revised due to regulatory developments, operational changes, or improved controls. The current version and update date will remain available online.