Code of Ethics and Professional Conduct

This is an English translation provided for reference. In case of any discrepancy, the original Portuguese version prevails.

1. Guiding Principles

Our conduct is based on truth, technical competence and mutual respect. This code guides our day-to-day work and ensures that the Foco na Solução brand is synonymous with trust.

2. Conflict of Interest

A conflict of interest is any situation in which a member's private interest may influence impartial judgment in the performance of their duties.

• No employee may take part in decisions involving companies owned by relatives or close friends.

• Any potential conflict must be reported to management immediately so that the appropriate recusal measures can be taken.

3. Gifts, Presents and Hospitality

To avoid any perception of undue favoritism, we adopt the following rules:

• Offering and receiving: It is forbidden to accept or offer gifts, money, loans or favors in exchange for preferential treatment.

• Exceptions: Only institutional giveaways (pens, calendars, planners) of symbolic market value that create no future obligation are allowed.

• Hospitality: Business meals or invitations to events are allowed only if there is a clear professional purpose and the value is consistent with market practices.

4. Training and Awareness

Foco na Solução holds annual ethics training for its team and leadership. The goal is to keep everyone up to date on internal anti-corruption procedures, ensuring that everyone knows how to act when facing ethical dilemmas.

5. Sanctions and Corrective Measures

Failure to comply with this code subjects the offender to disciplinary measures proportional to the seriousness of the offense, ranging from a verbal warning to termination of employment for cause or the end of business partnerships.