Code of Conduct & Compliance

LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS, for the purpose of complying with existing ethical and legal principles, through this Code of Conduct & Compliance (“Code”), hereby presents a clear understanding of the conducts that guide the firm’s business and relationships with its employees.

LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS strives for conducts that are in accordance with the Statute of the Law Practice, with the Code of Ethics and Discipline of the Brazilian Bar Association, as well as with the applicable legislation, including, but not limited to, Law No. 12,846/13 (“Anti-Corruption Law”) in relation to all contracted professionals, including suppliers.

LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS not only seeks action in accordance with the norms, policies and guidelines that govern its business, but also seeks to prevent, detect and punish any misconduct, and the consequent commitment of nonconformity actions.

Accordingly, all employees of LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS undertake to act against

(i) the use of forced or inadequate labor, or child labor;

(ii) activities that may cause damage to the environment and to public or foreign property;

(iii) the practice of any acts that may be harmful to the national or foreign public administration;

(iv) the practice of any act that may expose the business of LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS, including any confidential internal matter and information related to its clients;

(v) any discriminatory conduct of any kind;

(vi) any unethical conduct in the event of a conflict of interest between personal and professional relationships;

(vii) any conduct that may violate the relationship with clients, suppliers and partners who work with LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS; And

(viii) any conduct aimed at concealing any proven violation of this Code or any other rule applicable to the business carried out by LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS.

The list conveyed above comprises in summary the conducts reprehensible by LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS, considering that this Code does not include all the situations that could eventually occur in business relations and in the daily lives of employees. LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS seeks, through this Code, to guide its employees on how they should behave while exercising their activities.

In case of any act contrary to the applicable rules or this Code, LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS may apply any punitive measure it deems necessary, such as verbal or written warnings, suspension, dismissal with just cause, immediate termination of the service contract and/or partnership. The application of punitive measures by LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS, shall not affect any eventual sanctions provided by law.

In the event any employee becomes aware of any fact that could jeopardize the integrity of LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS or has strong suspicion of the existence of any illegal or unethical act, they should immediately communicate such matter to the Compliance area.

The full understanding of this Code is essential for the professional development of all employees of LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS, and any queries related to the content hereof must be submitted to the Department of Human Resources. In addition, if any employee has doubts on how to act on behalf of LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS, they should contact their superior.

Finally, we emphasize that the commitment of every employee is vital in order to maintain the integrity of this Code and the business of LEITE, TOSTO E BARROS ADVOGADOS ASSOCIADOS. Employees are the main responsible for the ethical conduct in the firm’s daily activities, including the transfer of this information to clients, suppliers or partners.