Ethical Code

General Principles

Audaces is a company driven by the mission of “Promoting Customer Success,” striving to develop the market in which it operates. Its vision guides all actions toward “Becoming a global benchmark in innovative technology and reliable services that create value for the industry.”

To achieve this, Audaces upholds core values that shape its relationships with employees, customers, suppliers, and business partners, as well as competitors, public authorities, and the broader community.

This document formalizes the ethical principles and codes of conduct that govern these internal and external interactions, reinforcing Audaces’ reputation as an Ethical, Innovative, and Sustainable company.

The principles outlined in this Code of Ethics must be upheld across the entire value chain, regardless of location or country where Audaces or any of its representatives operate. This commitment ensures high standards of personal and professional integrity, compliance with applicable laws, regulations, and industry standards.

Audaces Values

Audacity – We are passionate about what we do. We are audacious, innovative, and thrive on overcoming challenges.

Collaboration – We value partnership, cooperation, and individual skills while respecting differences.

Results – We work to ensure that our profits are fair and reflect the value of our performance. We are committed to sustainability and creating value for our customers.

Core Competencies

• Be Audacious
• Prioritize the Customer
• Focus on results and operational efficiency
• Work as a team and for the team
• Leadership
• Self-development
• Strategic vision

Relationships Among Partners

All partners shall have their rights respected and be granted transparent access to company information, regardless of their ownership share.

Business relationships between Audaces and the family members of partners or employees are permitted, provided they adhere to the principles of impartiality, transparency, and ethics, and that no conflicts of interest exist. Such relationships must comply with market conditions and the company’s needs.

Relationships with Employees

Audaces treats its employees with dignity, respecting individual differences and values while fostering a work environment that promotes both professional and personal growth.

All relationships with employees shall be based on professionalism, trust, honesty, integrity, and fairness. No abusive practices shall be tolerated, and the health and physical well-being of employees shall always take precedence over any economic interests.

Audaces strictly prohibits any form of abuse, including sexual harassment, arrogance, intimidation, or threats, as well as any behavior that contradicts the company’s values.

Employees are expected to follow corporate procedures, act with honesty and integrity, and comply with legal and ethical standards in all their professional activities.

Additionally, all company matters, without exception, must be handled by employees with the utmost confidentiality and discretion.

Recruitment and Selection (R&S)

In all R&S processes, candidates must be carefully evaluated based on their competencies and the specific requirements of the position, without any form of discrimination.

Internal recruitment opportunities will always be considered, offering career growth prospects for current employees. The selection process for internal candidates follows the same criteria applied to external applicants.

Employees may participate in internal recruitment processes with prior authorization from their direct supervisor.

A key evaluation criterion in R&S is the candidate’s alignment with the company’s values, which is crucial for their progression in the selection process.

The hiring of immediate family members (up to the second degree of kinship) is not permitted. This includes parents, children, siblings, uncles/aunts, nephews/nieces, in-laws, and adopted children. Additionally, spouses cannot be employed in positions involving direct supervision.

Hierarchy Relationship

Everyone should be open to listening to and considering new ideas, differing opinions, and constructive feedback, as these contribute to learning and process improvement, regardless of hierarchical level.

Collaboration between departments must always be encouraged to foster overall company growth, knowledge-sharing, and dissemination while respecting confidentiality and privileged information.

All employees have the responsibility to identify and suggest process improvements to prevent errors and avoid their recurrence.

Mutual respect between leaders and employees is essential for the company’s success. Leadership must not be mistaken for authoritarianism.

Leaders are responsible for clearly communicating evaluation criteria to their teams, ensuring employees understand how their performance will be assessed.

Both leaders and employees share the responsibility of providing continuous feedback to guide and enhance individual and team performance.

Discrimination

Audaces does not tolerate any form of prejudice or discrimination based on religion, philosophical or political beliefs, nationality, gender, race, age, marital status, sexual orientation, physical condition, or any other factor.

All individuals must be treated with respect, fairness, and professionalism, regardless of their role or position within the company.

Harassment, Aggression, and Violence

Audaces strictly prohibits any form of aggression, violence, or harassment, whether sexual, economic, psychological, physical, or moral. Any behavior that constitutes intimidation, threats, or disrespect among employees, regardless of hierarchy, will not be tolerated.

Child and Forced Labor

Audaces does not tolerate forced labor or working conditions analogous to slavery, either within the company or among its suppliers and business partners. Similarly, the company strictly prohibits the use of child labor in any situation.

Weapons, Drugs, and Unauthorized Sales

Possession and consumption of illegal drugs and alcoholic beverages are strictly prohibited in the workplace. Employees are also not permitted to perform their duties under the influence of such substances, as this may impact their professional performance and workplace safety.

Carrying weapons of any kind within company premises is forbidden, except for employees who have been explicitly authorized to do so

The sale or exchange of personal goods during working hours, within company premises, or using company resources is also prohibited.

Employee Privacy and Data Protection

Audaces respects employee privacy and complies with the General Data Protection Law (LGPD). Access to employees’ personal information within company systems is strictly limited to those with legal authorization and only when necessary for work-related purposes.

Personal data will only be collected or processed for business-related reasons, compliance matters, or reports filed through official channels such as HR or compliance hotlines, always in accordance with applicable laws.

Employees must use any personal information they have access to solely for its intended purpose while ensuring confidentiality, in compliance with LGPD regulations.

As part of its legitimate business interests, Audaces may monitor its digital environment (including computers, emails, and servers). Employees should not expect privacy regarding company-provided assets.

Employees are responsible for ensuring their personal information remains up to date in the company’s records.

Company Property

The assets, equipment, and facilities of Audaces are intended solely for use in its operations and may not be used for personal purposes, except in specific situations defined by the company.

It is the employee’s responsibility to ensure the proper use and maintenance of the company property entrusted to their care.

Purchases, sales, write-offs, or transfers must be conducted in accordance with the company’s internal policies and in its best interest.

Employees are prohibited from using company assets, credit cards, money, advances, services, or credits for personal benefit or for the benefit of third parties, including intellectual and industrial property rights, as well as strategic and confidential information belonging to the company, which are considered the sole and exclusive property of Audaces.

External Activities and Services

Engaging in external activities, services, or even employment outside the company must not interfere with the work to be performed at Audaces, nor should internal work tools be used for personal gain.

Activities that present an immediate or future conflict with the activities and interests outlined in Audaces’ Strategic Planning are not permitted. This applies to employees, partners, family members of any degree, and business associates.

Any initiative in this regard, even if it does not currently conflict with the company’s interests, should be communicated to the Human Resources department to avoid future conflicts.

External activities should never harm the company’s image. Employees must act with caution and care, ensuring that neither the company nor their professional career is put at risk.

Use of Electronic Information Systems

Electronic systems and Information Technology resources are provided to employees to support the effective performance of their duties.

All files and information related to professional activities, whether created, received, or stored in electronic systems, are the property of Audaces and constitute commercial and legal assets.

Access passwords to systems and information are personal and non-transferable. They are for the exclusive use of each employee and may not be shared with third parties or colleagues.

Employees must adhere to all internal regulations regarding Information Security and Personal Data Protection, contacting the Information Security department in case of any doubts.

Intellectual Property and Confidentiality

Intellectual property is a strategic asset for Audaces and a key competitive advantage for the company. All patents, trademarks, know-how, intellectual work results, technical data, process, market, or strategic information belong exclusively to Audaces.

Every employee is responsible for handling intellectual property information with confidentiality and discretion. They must use such information carefully and are prohibited from disclosing it without explicit authorization from the company.

Likewise, Audaces respects the intellectual property rights of third parties and business partners.

Customer Relations

Audaces values the continuous pursuit of customer satisfaction, generating value by meeting expectations and developing innovative, high-quality solutions and technologies.

The company does not discriminate against customers based on origin, economic status, or location. However, Audaces reserves the right to end any commercial relationship if its interests are not being met or if the relationship poses legal, social, or environmental risks.

All information about our products and services must be clear and truthful. Each product strictly adheres to the legal requirements of its target market.

Employees are strictly prohibited from making or accepting any improper, questionable, or illegal payments, as well as from granting or receiving undue privileges and benefits outside standard business practices. This prohibition applies even if it means losing business opportunities.

All Audaces customers must be treated with courtesy and efficiency, receiving clear, accurate, and transparent information within the agreed timelines and formats.

Customer relationships must be conducted with mutual respect and honesty, in full compliance with local and international laws.

Any attempt at bribery, favoritism, or violation of this code must be reported to the Human Resources team, with confidentiality assured where applicable.

Supplier Relations

Audaces’ relationships with suppliers, including third-party companies providing services within company facilities, must be based on mutual respect and integrity.

The selection of suppliers must always be based on technical, professional, ethical, and economic criteria, aligned with Audaces’ core values and general guidelines.

Suppliers are expected to uphold the principles outlined in this Code. This includes transparency in defining products and services and maintaining confidentiality regarding shared information.

Audaces reserves the right to terminate business relationships with any supplier if its interests are compromised or if legal, tax, social, environmental, or occupational health and safety requirements are disregarded.

Employees (or legal representatives) are strictly prohibited from making or receiving payments, gratuities, or any form of advantage to or from suppliers with the intent of influencing company decisions.

Bribes, kickbacks, illicit commissions, and similar payments are strictly forbidden. Such actions not only violate ethical standards but may also expose Audaces and the individuals involved to legal penalties or criminal prosecution. Any attempts at undue influence must be immediately reported to the department manager or Human Resources.

Competitor Relations

Audaces maintains relationships with competitors based on respect for fair and open competition. Any legitimate and necessary market or competitor information must be obtained through transparent and ethical means. The use of illegal or morally unacceptable methods to access confidential information is strictly prohibited.

Employees must not make verbal or written statements that could damage a competitor’s reputation or contribute to the spread of rumors. Competitors should be treated with the same respect that Audaces expects to receive.

It is strictly forbidden to share any business or product information with competitors.

Additionally, no employee may engage in discussions or agreements with competitors regarding price setting, sales conditions, coordinated market behavior, market division, or tying the sale of one product to another.

Relations with Governments

Audaces strictly complies with all applicable laws and expects the same commitment from its employees in every location where it operates. The company’s interactions with government entities at any level should be open and constructive.

Any information provided to government authorities must be submitted in writing, properly documented, and guided by the company’s Legal Department, regardless of its content or purpose. All information shared must be accurate and sufficient to clarify the matter at hand, ensuring full compliance with applicable laws and regulations.

Employees and legal representatives are strictly prohibited from making payments or offering any form of gratuity or advantage to public officials or government authorities to influence decisions in favor of the company or for personal gain. Bribery, kickbacks, illicit commissions, and similar payments are expressly forbidden. Engaging in such activities not only violates ethical standards but also exposes Audaces and those involved to criminal prosecution and legal penalties.

All contracts related to supply, employment, financing, services, consulting, or advisory must be reviewed, guided, and approved by the Audaces Legal Department before execution.

Any attempts at undue influence or favoritism must be reported immediately to the department manager or Human Resources.

Environmental Responsibility

Audaces is committed to aligning its business operations with sustainable development, environmental preservation, and the health and safety of its employees.

All employees are expected to remain vigilant about workplace conditions and potential environmental risks—both within and beyond the company. Any concerns should be proactively addressed by notifying direct leadership when they involve the company or reporting external issues to the appropriate authorities so corrective actions can be taken.

Whenever necessary, Audaces will obtain environmental permits to assess potential risks before taking any action that could impact the environment. The company will always adhere to the established environmental regulations.

Community Engagement

Respect for individuals and civic institutions—whether governmental or non-governmental—guides Audaces’ interactions with the communities in which it operates.

The company encourages employee participation in volunteer programs.

Audaces invests in social, cultural, and environmental projects based on the real needs of the communities involved, aiming to drive meaningful social change.

As such, all donations, sponsorships, and other forms of support for social development and community well-being must align with the company’s principles of sustainability, engagement, and volunteerism.

Conclusion

All employees and stakeholders are expected to uphold the company’s values and adhere to the principles outlined in this Code. Failure to comply may result in appropriate disciplinary actions.