Code of Ethics and Conduct

1. Message from leadership

At Netbiis, we transform challenges into digital opportunities — and we do so with ethics, transparency and respect. The trust of our clients, employees, partners and the public sector is our most valuable asset. This Code gathers the principles that guide the behavior of everyone acting on behalf of Netbiis. Compliance with it is a non-negotiable condition for being part of our story.

2. Who it applies to

This Code applies to all directors, partners, employees and interns of Netbiis, regardless of position or role. It also applies, as appropriate, to suppliers, service providers and other business partners acting on behalf of or for the benefit of Netbiis.

3. Our principles

Integrity and honesty in all relationships.
Zero tolerance for corruption, fraud and undue advantages.
Respect for people, diversity and human rights.
Responsibility toward society and the environment.
Transparency and truthfulness of information.
Compliance with the laws of the countries where we operate.

4. Anti-corruption and anti-fraud

Netbiis rejects all forms of corruption, bribery and fraud, in the public or private sector.

It is prohibited to offer, promise, pay, authorize or receive any undue advantage, financial or otherwise, directly or indirectly — especially to a public official — in order to obtain or retain business or to influence any act or decision.
Gifts and hospitality are acceptable only when of symbolic value, with a legitimate purpose and in compliance with the law — never as an undue consideration, particularly toward public officials.
We do not tolerate facilitation payments under any form or justification.

5. Relationship with the public sector and bidding

Netbiis values an honest and transparent relationship with the Public Administration.

We participate in public tenders and contracts truthfully, providing accurate information and documents.
It is prohibited to arrange prices or conditions with competitors or to engage in any conduct that resembles or constitutes collusion or bid-rigging.
Interactions with public officials regarding contracts (payments, amendments, extensions) must be conducted by designated representatives and duly recorded.

6. Conflicts of interest

We must avoid situations in which personal interests could influence — or appear to influence — decisions made on behalf of Netbiis. Potential conflicts must be reported to the responsible manager or to Compliance.

7. Respect for people

We prohibit all forms of harassment (moral and sexual) and discrimination, on any grounds, including origin, race, color, gender, sexual orientation, age, religion, disability or social condition.
We foster a safe, welcoming and respectful workplace that values diversity.

8. Human rights and labor

We respect internationally recognized human rights.
We expressly prohibit child labor and labor in conditions analogous to slavery, in our operations and across our partner chain.

9. Environment

We act with environmental responsibility, comply with applicable law and pursue sustainable business practices.

10. Information, data and assets

We keep truthful and accurate records and communications; we do not falsify or omit information.
We protect confidential information and personal data, processing it in accordance with our Privacy Policy and the Brazilian Data Protection Law (LGPD, Law No. 13,709/2018).
We use company assets responsibly and for legitimate purposes.

11. Whistleblower Channel and non-retaliation

We encourage good-faith reporting of any violation of this Code or the law through our Whistleblower Channel.

We ensure confidentiality and protection for good-faith reporters.
We prohibit any retaliation against those who report in good faith.

12. Non-compliance

Violations of this Code subject the offender to disciplinary measures proportionate to the seriousness of the conduct, applied with due process and in accordance with applicable labor and contractual law, regardless of position or role. For partners and third parties, a violation may lead to contractual sanctions, including termination.

13. Approval and effectiveness

This Code was approved by the Netbiis Executive Board on 26 June 2026 and takes effect on that date. It will be reviewed periodically. In case of any divergence between the Portuguese and English versions, the Portuguese version prevails.

Netbiis Serviços de Internet Ltda. — São Paulo, 26 June 2026.