Anti-corruption and anti-bribery policies

2. Scope and Application

This policy applies to all employees, directors, executives, service providers, business partners and third parties acting on behalf of Conversys IT Solutions, covering all the company's operations and activities both in Brazil and abroad.

3. Principles and commitments

• Strict Compliance with Laws: Conversys IT Solutions strictly complies with all anti-corruption and anti-bribery laws, including the prohibition of any corrupt practices in interactions with both the public and private sectors.
• Integrity Standards: All employees must act in accordance with the highest standards of ethics, transparency and integrity. The company adopts a zero tolerance policy for acts of corruption, extortion, bribery and any conduct that compromises trust in its operations.
• Documentation and Records: All financial transactions and business operations must be accurately documented, transparent and subject to regular audits. False or misleading records that could cover up illicit activities will not be permitted.

4. Specific guidelines

• Conflicts of Interest: Employees must avoid situations that could lead to conflicts of interest and promptly report any potential conflict. Any activity or relationship that could compromise objectivity and impartiality must be disclosed and managed in accordance with company guidelines.
• Gifts, Presents and Hospitality: Gifts or hospitality offered or received must be reported to and approved by the Board of Directors, respecting the established limits. For public officials, any gift or hospitality may only be offered if it is part of a generalized campaign or offer, in an equitable and collective manner for clients or prospects in the public and private markets, respecting the individual limit of the equivalent in Reais of US$ 250.00 (two hundred and fifty American dollars); for private clients, the limitations indicated by the client's representative will be observed in accordance with the client's own internal policy, and in any case it is forbidden to offer or accept any item that could be interpreted as an attempt at bribery or undue influence.
• Facilitation payments: Facilitation payments, i.e. payments intended to speed up processes that the company is already entitled to, are strictly forbidden. All employees are instructed to refuse such requests and report them immediately to the Compliance department.
• Due Diligence and Partner Selection: The company carries out rigorous due diligence procedures to assess the integrity and compliance of all business partners and third parties, ensuring that all are in line with the company's anti-corruption practices.
• Interactions with Government Authorities: All interaction with public authorities must be transparent and conducted in accordance with legal regulations and the company's values. It is forbidden to offer or accept any undue advantage to influence decisions or secure benefits.

5. Responsibilities

• Senior Management: The leadership of Conversys IT Solutions is responsible for promoting a culture of compliance and integrity, ensuring that this policy is implemented and followed by all levels of the organization.
• Compliance Officer: The Compliance Officer has responsibility for monitoring and reviewing this policy, conducting investigations into any suspected violations and implementing corrective measures as necessary.
• Employees: All employees must strictly comply with this policy, participating in periodic training and reporting any suspicions of illicit practices through the whistleblowing channel.

6. Training and Awareness

The company offers regular training for all employees, ensuring that they are aware of their responsibilities in relation to preventing corruption and complying with this policy. Awareness programs are held periodically to reinforce the culture of integrity.

7. Complaints channel

Conversys IT Solutions provides a secure and confidential reporting channel via e-mail at denuncia@conversys.global. All reports will be investigated seriously and confidentially, ensuring that whistleblowers are not retaliated against.

8. Sanctions and consequences

Any violation of this policy will result in disciplinary sanctions, which may include dismissal for just cause, in addition to legal action, if applicable. The company will take steps to terminate business relationships with partners and suppliers who violate this policy.

9. Reviewing and Updating the Policy

This policy will be reviewed and updated periodically to reflect changes in legislation and best compliance practices. Senior management and the Compliance Officer are responsible for approving any necessary revisions.

10. Final Provisions

Conversys IT Solutions reaffirms its commitment to legal compliance, ethics and integrity in all its operations. All employees, partners and third parties must strictly adhere to this policy to ensure that the company's activities are conducted in a fair and responsible manner.