Given the particularity of operating in a collaborative network, the search for ethics and good conduct is fundamental and its maintenance is extremely necessary to ensure that the organization has the confidence of its partners, employees, suppliers, as well as public authorities and society in general. We have developed this material called the Compliance Policy that includes the Code of Ethics and Conduct, Anti-bribery and Anti-corruption Policy.

The purpose of formalizing conduct and ethics standards and defining which actions are intolerant within NEKI, by its members, third parties and other related parties, is to meet and ensure that our operations are in compliance with important standards issued in recent years that have an impact on the governance of civil society organizations. The objective of this policy is to consolidate the principles and good practices carried out by NEKI and take an important step in implementing internal procedures that guarantee compliance with transparency and good resource management, with a focus on preventing irregularities, and identifying and solving problems preventively. It is expected that this policy will be a useful and effective instrument, observed by all those who relate directly or indirectly with NEKI.

The NEKI Official Complaint Channel is established as the official communication channel for complaints, complaints and questions about the topics covered in this document, which can be accessed through the website, Convenia and link: https://bit.ly/canaloficialdenuncianeki The channel is open to all NEKI employees and stakeholders, so they can anonymously report conduct or behavior that is not in accordance with the Compliance Policy.

In the technology area, new tools are presented to the market at all times. Our mission is to bring optimized results to our clients, with the ambition of being a reference in the market in excellence and innovation for the development of Software, Web and mission-critical solutions. For greater understanding, the entire document uses the trade name of the company CARIUS INFORMÁTICA LTDA.

With this code of ethics, NEKI commits to a set of guidelines that guide the behavior of all managers, employees and service providers. These principles of action and behavior are based on our values, focused on customer service, quality in the services offered, agility and results. It commits to respecting these principles and motivating all partners to practice them. By presenting a behavior of commitment and example, we reinforce our position of trust.

COMMITMENT TO ATTENTION

It directs us to improve our internal training, so that we can engage our entire team to offer the best support to our clients and partners with agile and fast actions.

COMMITMENT TO QUALITY

It consists of delivering value with innovative processes and methodologies, supported by tools. Our ambition is to be recognized and recommended nationally and internationally due to our products and services.

COMMITMENT TO AGILITY

It leads us to seek continuous improvement of our products and processes, in order to simplify solutions and reduce efforts so that we can deliver to our clients the best experience they have ever had in service.

COMMITMENT TO RESULTS

It involves dedication and dynamism. Our team engages to satisfy our clients' expectations, presenting solutions that are appropriate to their needs.

Formalize a reference for personal and professional conduct for all NEKI employees, in order to become a standard for the company's internal relationship with its stakeholders: partners, employees, clients, competitors, suppliers, service providers, unions, society and government;

Ensure that care for efficiency, competitiveness and profitability includes ethical behavior;

Reduce the subjectivity of personal interpretations about ethical principles.

Our objectives direct us to practice ethical principles which apply to all NEKI managers, employees and service providers.

With our clients: NEKI considers that its success in offering quality products and services is, in addition to a market differential, one of its strengths. Always attentive to needs and expectations, we maintain a posture of honesty, integrity, courtesy, respect, loyalty, efficiency, transparency and impartiality. Acting within the Law, the client's policies and standards, complying with contracts, agreements and accords signed with third parties.

With our employees: We believe in the integrity, responsibility and initiative capacity of our employees. We favor the development of skills, as well as the well-being of all, without prejudice of any nature.

With our competitors: We adopt fair competition practices and combat piracy, tax evasion, fraud and corruption.

With society and the environment: We prioritize issues of health, safety, environmental preservation and sustainable development standards in the regions where we operate, as well as support for social actions of public interest.

With our suppliers: We do not accept forced, compulsory, child labor or any other form of exploitation that attacks human dignity, seeking reputable suppliers in their process of supplying goods and services.

Maintain confidentiality regarding information and activities related to work, except with express authorization to the contrary given by the Board.

Ensure the veracity of information disseminated internally or externally by the company.

Do not use the power inherent to the position or function in obtaining personal favors or services from subordinates.

Do not participate in transactions and activities that may compromise your professional integrity or discredit your public image, as well as the company's image.

Exercise your professional activities with competence and diligence, seeking technical improvement and permanent updating, and should encourage everyone involved to adopt such conduct.

Do not accept any task that you are not qualified to fulfill in the way that best serves the company's interests.

Do not take positions or make statements that may harm the interests, technical competence or reputation of your co-workers or the company.

Do not accept from suppliers, clients, partners and competitors any type of financial assistance, gratuity, commission, donation or advantages for yourself, your family or anyone else.

Preserve NEKI's and its clients' Assets with regard to facilities, equipment, materials, technological, strategic information and operational facilities.

Do not use company resources (materials, work time, equipment, etc.) to serve particular interests.

Use electronic mail and the Internet for work-related matters, always taking care of Information security and not disseminating messages that contain illegal, pornographic, racist and religious, political and fake news content.

All NEKI employees, when starting their activities at the company and signing the "agreement" term, assign and transfer to the company rights to edit and/or reproduce their image, voice, testimonials, etc., and authorize the fixation in any type of media now existing or that may be created, on the company's website and any product or event linked to NEKI, in an educational or commercial capacity, for the dissemination of activities or services, for commercial, educational and promotional purposes, unlimited times, in closed and open circuits, in Brazil and abroad. This authorization is granted free of charge, non-onerous, irrevocable and irrevocable, and heirs and successors may not argue any right regarding the authorized work(s). The use of the assigned image right is done respecting all the policies presented here, as well as Human Rights and the guidelines required by LGPD. The grantor is protected from any exposure that harms their image or associates them with any ideology prohibited by law.

Employees must use social networks responsibly and respectfully, avoiding publications that could harm the company's image or that of their co-workers. Opinions expressed must be clearly identified as personal and not representative of the company, unless expressly authorized. All posts must respect the confidentiality of information from work developed, never exposing images of computer screens or any other electronic device used as a work instrument that contains confidential information and protecting the image, name and any other information linked to NEKI clients, third parties and service providers.

Technological resources provided by the company, such as computers, systems and equipment, must be used exclusively for professional purposes and in accordance with established internal policies. Access to confidential or sensitive information must be restricted only to authorized employees. Employees must adopt adequate security and data protection measures when using the company's technological resources, avoiding sharing passwords or confidential information with unauthorized third parties. The use of the company's technological resources for the dissemination of illegal, offensive, discriminatory, pornographic content or any other activity that violates current legislation is prohibited.

Considering that to carry out the work, the employee will have access to information from NEKI clients and their businesses, the employee accepts that all information revealed, communicated and/or accessed must be maintained in total and unrestricted confidentiality, and cannot disclose, explore or make them accessible to third parties outside this relationship;

The employee, during the execution of work, commits and is obliged to:

Use Confidential Information exclusively for work development, inside or outside NEKI facilities;

Maintain Confidential Information in absolute secrecy and secrecy, as well as not use or exploit such information for the benefit of themselves or third parties, for any purpose;

Maintain the most absolute secrecy about any data, materials, details, information, documents, technical and commercial specifications of NEKI or third-party products, which they may become aware of or have access to, or which may be entrusted to them, whether related or not to their work at the company;

Limit the disclosure of Confidential Information received, related to the services in which they are working, to people within their organization who, in the development of their functions, need to know the Confidential Information, it being agreed that such people will be properly instructed to protect and maintain the confidentiality of the information received;

Not produce copies, or back-up, by any means or form, nor allow third parties to copy or use any of the documents provided to them or documents that have come to their knowledge by virtue of the position they hold in the company, in addition to those essential for the development of their work, considering that all are confidential information.

Employees must adopt adequate security and data protection measures when using the company's technological resources, avoiding sharing passwords or confidential information with unauthorized third parties. The use of the company's technological resources for the dissemination of illegal, offensive, discriminatory, pornographic content or any other activity that violates current legislation is prohibited.

The employee agrees that NEKI, or its clients as appropriate, is and will continue to be the exclusive owner of its confidential information and all patents, copyrights, trade secrets, trademarks and other intellectual property rights. No license or transfer of any of these rights to the employee is granted or implied under the terms of this commitment;

This commitment, or any disclosure of information made in accordance with its terms and conditions, with the exception of the express provisions contained in this policy, does not confer, under any title, any type of license or any other right of any nature for the use of Confidential Information, patent, trademark, trade name, copyright or other type of intellectual property of the employee.

"Conflicts of interest" can arise when an individual or their close relatives, friends or professional contacts can influence or exploit their own professional position inappropriately, with the aim of personal or professional benefits. All NEKI employees must avoid situations in which their personal interests conflict, or may conflict, with NEKI's interests. If an employee encounters a situation where there is or appears to be a conflict of interest, they must disclose the conflict of interest to their leader. The leader will evaluate the situation and determine the measures to be taken, after consulting the Compliance Committee. The leader will decide whether the employee should be part of the decision-making process or not.

The employee or any third party interested in NEKI must immediately communicate to the company's Compliance Committee through the NEKI Official Complaint Channel, available on the website, Convenia or through the link https://bit.ly/canaloficialdenuncianeki, any conflict of interest of which they become aware or situations contrary to ethical principles, or that are irregular or doubtful, with confidentiality guaranteed regarding the source of information.

This code of ethics reflects the commitment of the company CARIUS INFORMÁTICA LTDA/NEKI to act ethically, transparently and responsibly in all its activities. All employees commit, through digital signature of the Agreement of Consent with NEKI Policies, to adhere to these principles and contribute to the development of a work environment that is integral, respectful and that promotes the highest standards of professional conduct.

NEKI has a zero tolerance attitude towards bribery and corruption. Even the suggestion of corruption can damage the organization's reputation and affect its ability to do business, as well as the reputation of its employees. Therefore, the organization is committed to doing business ethically, even if this means not obtaining new business, not using the services of specific business partners or incurring delays in carrying out our existing business. We expect everyone to maintain commitment to this guideline and report any evidence of inappropriate conduct.

Queries, suspicions or suggestions should be directed to the NEKI Official Complaint Channel presented in items 1.2 and 2.8 of this document.

The Anti-bribery and Anti-corruption Policy explains our responsibility to comply with anti-bribery and anti-corruption laws worldwide and ensure that any third parties we hire to act on our behalf do the same.

It aims to establish guidelines and parameters that guide the application, dissemination and improvement of NEKI's Compliance. That is, to provide for a set of activities, procedures and monitoring oriented to reduce the risk of occurrence of bribery events in the organization.

This Policy applies to NEKI employees, suppliers, business partners, representatives, service providers and/or class entities/associations that act on behalf of or for the benefit of the organization. Everyone must respect the guidelines defined in this document.

This NEKI Policy uses the following laws and guidelines as reference:

ABNT NBR ISO 37001:2017 - Anti-bribery Management Systems. ABNT NBR ISO 37301:2021 - Compliance Management System. Anti-corruption Law or Clean Company Law, law no. 12.846/2013

According to most legislation, bribery, whether in the public or private sector, is prohibited and constitutes a crime, although the rules for interaction with government officials are usually more severe.

This policy cannot cover all situations or provide information about all laws that may be applied, nor does it intend to be a complete statement of anti-bribery legislation in any jurisdiction.

It is fundamentally the responsibility of any person within NEKI to assess what is permitted and what is not within the scope of their activities, using available resources. NEKI makes itself available to guide its employees and third parties interested in the company where they can find relevant information.

Bribery is: offering, promising or giving (active), or requesting, demanding, agreeing to receive or receiving (passive) anything of value with the aim of obtaining a specific advantage in return or to induce improper behavior.

"Anything of value" includes: money, cash equivalents (for example, gift vouchers) or loans; payments for travel, accommodation or entertainment; favors, including job or internship offers; gifts (for example: perfume, jewelry, use of club titles, a cruise and other advantages); charitable donations; offer of better or beneficial terms for NEKI products or services; Political contributions or facilitated payments.

Examples of bribery in the private sector include: paying or giving something of value to a purchasing agent so that he chooses NEKI products and not the competition; providing anything of value to an executive or director of a business partner so that the partner does business with NEKI; paying an equipment supplier employee with the aim of obtaining preferential treatment when supplies are in short supply; or promising the use of a vacation home to an employee's family of another company with the intention of inducing the employee to offer a contract to NEKI that would otherwise go to the competition.

Employees cannot offer gifts, meals or entertainment to third parties, as well as accept gifts, meals or entertainment from third parties, except in cases permitted in this policy. This policy describes when gifts, meals or entertainment can be offered or accepted without prior approval, when they can be offered or accepted only after approval and when they cannot be offered or accepted in any way. All gifts, meals or entertainment that are received in accordance with this policy must be registered in the form available at the link: https://bit.ly/itensrecebidos

Gifts, meals or entertainment can never be offered or accepted if: they are illegal within applicable laws; they are not permitted within the applicable policy or code of conduct in the organization that is offering or receiving; they are offered with the intention of obtaining or maintaining business in return or to obtain any type of commercial advantage; the gift, meal or entertainment can be interpreted as intention to affect the outcome of a commercial transaction; it consists of money or can be converted into money.

Employees cannot ask for gifts, meals or entertainment from third parties.

Gifts can only be offered or accepted freely, as a courtesy or sign of respect, when the nature of the gift is appropriate to the relationship and follows local customs and general business practices. All gifts must be registered at the link above even following the characteristics described above.

Within this policy, employees can offer and accept a gift without prior authorization if the gift is in accordance with the principles established in items 3.5.1 and 3.5.2 and: if the gift is corporate, with the "NEKI" brand, of nominal value (for example, pens, notebooks);

OR

the value of the single gift (or set of gifts) does not exceed the value of R$50.00 (fifty reais); the intended recipient has not received more than two gifts in the last 12 months from NEKI; the gift is offered on an occasion when it is common to offer gifts according to local business practices; the gift is offered on behalf of NEKI and not on behalf of the employee. Regardless of the case above, the employee must register the gift received at the link referred to in item 3.5.1.

Meals and entertainment can be offered or accepted as part of business meetings, for the promotion of NEKI products or services in general or for the discussion of a specific project, opportunity or contract. The same principles set out in item 3.5.1 and those set out in item 3.5.2.1 apply to meals and entertainment by analogy, disregarding the need to register any meals and entertainment received when the rules mentioned above are followed and do not exceed the value of R$400.00 (four hundred reais).

If the volume of meals received exceeds 4 per month, registration is required at the link referred to in item 3.5.1.

If the employee has offered or received entertainment in the last 10 months, it is necessary to register at the link referred to in item 3.5.1

The employee who violates the rules and neglects the guidelines contained in the Code of Ethics and Conduct, Anti-bribery Policy and Compliance Policy, or in any provision imposed by the company, will be subject to the following penalties:

NEKI is not obligated to follow the order in which the penalties were previously stated. The penalties will be applied according to the severity of the fault committed, according to the evaluation of the legal department and NEKI's Compliance Committee.

Version 1.0 - October 2023