CODE OF CONDUCT

Last update: 23 Agosto 2022

Dear BBChainer,

We present the BBChain Code of Conduct, which was created to establish the standards of performance for all BBChainers, whether they are employees, directors, interns, apprentices, fellows, service providers, or third parties at the service of BBChain. This Code indicates how everyone should proceed in the various day-to-day situations in their work and relationships with leaders, colleagues, customers, and the external public. The terms included in the BBChain Code of Conduct are aligned with our mission, principles, and values, and our commitment to being a reference in the national software services market, recognized for our agile and flexible operating model and the quality of our products. Please read this document, understand it and refer to it. This material will serve not only to align our actions but mainly to unite our efforts and conduct commitments. In this way, we can constantly improve our coexistence and provide a climate of respect and well-being to everyone who collaborates with us. It clearly and simply sets out the principles that should underpin everything we do at BBChain, committing ourselves to the highest ethical standards. We count on each of you to experience and disseminate these good practices within our Organization.

A hug, Andre Carneiro, COO

Introduction

Code of Conduct is an instrument intended to guide the behavior of all BBChain BBChainers, whether employees, trainees, fellows, service providers, or third parties, from now on, generically all called 'BBChainers.' The norms established herein must be interpreted within the specific context of each group, respecting the specifics of their performance and the correlated hierarchical levels. This Code does not intend to exhaust all possibilities and situations in the daily life of BBChainers, but rather to highlight relevant points that will serve as a reference to guide the daily initiatives and decisions.

Objective

Guide, simply and directly, on the expected conduct of BBChainers and other members linked to BBChain, based on the company's mission, principles, and values, as well as applicable legislation, such as the Anti-Corruption Law (Federal Law No. 12.846/ 2013). Enforce honest and ethical conduct, including the ethical management of actual or perceived conflicts of interest between personal and professional relationships.

BBChain organizational identity

To be a reference in the national software services market, recognized for its agile and flexible operating model and the quality of its products.

Provide solutions and knowledge in Information and Communication Technology, enhancing the results for our customers.

Essential Commitment

All BBChainers assume the essential commitment of knowing and fully complying with the guidelines contained in this Code of Conduct and the other rules and procedures established by the company. Therefore, everyone must act appropriately, honestly, reasonably, and ethically in all situations, even when unfavorable circumstances appear. In addition, it is imperative that each BBChainer is aware of the importance of their role and the value their work has for BBChain, and should always be mindful of the impact that their decisions and actions can have on the Organization as a whole.

Below are guidelines regarding the central attitudes and initiatives expected from BBChainers and some behaviors that the company does not accept.

Relationship with society

Any act that may cause harm or be contrary to public or company interests should never be deliberately practiced, always striving for ethical and socially correct actions. Furthermore, everyone must be treated with equality, respect, cordiality, and commitment, without discrimination.

Relationship with BBChainers

BBChain has 'Diversity' as one of its values, as we believe that we can only build diverse, inclusive teams in a work environment free from constraints and prejudices. Everyone must always respect the differences, skills, experiences, and life stories that each of us brings to the company—treating other company members, its partners, or anyone with a relationship with BBChain with respect and cordiality. Any manifestation of discrimination or prejudice of any nature is forbidden, including age, gender identity or expression, race, religion, age, sex, political conviction, nationality, marital status, sexual orientation, physical condition, sports preferences, or any other. Everyone must be treated equally.

Health and safety

Everyone is expected to assume responsible attitudes in complying with laws and internal regulations regarding medicine and occupational safety to promote a healthy and quality work environment. As a way of helping the company maintain security at work, each BBChainer must report to the leaders any accidents, injuries, illnesses, or incidents that could threaten their safety or that of others.

Prohibition of child or enslaved person labor

The use of child labor is prohibited. No individual under age 15 (or under age 14, where permitted by local law) may be employed. Workers under 18 may not carry out work that could jeopardize their health or safety. BBChain also assumes the commitment not to allow the exploitation of slave labor and that in any of the situations, it reserves the right not to contract or have a commercial relationship with companies or institutions that adopt this practice.

Relationship with customers and suppliers

All business relationships with customers and suppliers must be guided by the guidelines in this Code of Conduct and follow the requirements of BBChain and the other parties involved in the negotiation. BBChainers must respect the policies outlined in commercial contracts, including the rights, duties, obligations, and responsibilities of the parties involved in the business, as well as provisions regarding the possession or commercialization of any confidential information, product, process, research, confidentiality, document or intellectual property developed in the project. Everyone must strive to meet customer requirements and expectations, providing quality products and services and seeking the best value for money. This same posture should be requested as a practice of suppliers.

Confidentiality agreement

All information from BBChain or our customers and partners must be kept strictly confidential unless there is guidance and express authorization from the Organization for disclosure. The confidentiality of information is vital for customers, given that any breach of confidentiality obligation can cause them immense damage. As a result, BBChainers must understand the magnitude of this information and commit to preserving and keeping it safe at all times, even when, for whatever reason, they cease to work with BBChain. For the protection of this information, all BBChainers must know and respect the confidentiality provisions contained in the employment contract signed with BBChain and the confidentiality agreements entered into between the Organization and its clients, which directly bind all BBChainers involved in the respective contracted projects. In addition, BBChainers must undertake, whenever required by a client, to sign a specific confidentiality agreement(s) for participation in a given project. The confidentiality commitment is general and unique. However, as each project has its peculiar characteristics, including the confidentiality of information, the Project Manager will be responsible for presenting the main points and guiding their respective team, being available to clarify any doubts. In addition, the Board of Directors or the Talent Development team will be available to BBChainers whenever further information and clarifications are necessary.

A breach of this section of the Code of Conduct or the confidentiality clauses contained in the employment contract or any other confidentiality agreement signed between BBChain and BBChainer or customers, as well as the confidentiality clauses contained in confidentiality agreements, is considered a severe breach. See our Data Protection Policy for more details.

Intelectual property

Any goods, material or immaterial, produced in the company are the intellectual property of BBChain, or of any client or partner with whom BBChain has signed an agreement for the assignment of the respective rights over the intellectual property of a given project, regardless of who created unless otherwise agreed in the contract. Copying, printing, or appropriating the individual material for personal use is not permitted. BBChainers are responsible for the protection and integrity of BBChain's intellectual property.

Conflict of interests

All business decisions and actions must be based solely on the company's interests and cannot be motivated by personal considerations or relationships. However, BBChainers are asked to disclose situations that could indicate a conflict of interest. The following are some of the cases that may cause a conflict of interest: It is forbidden for any BBChainer to use influence or privileged information for their benefit or that of others, to the detriment of the company's interests/business or causing possible damages and damage to it. Hiring direct relatives (from now on understood as father, mother, children, grandparents, grandchildren, and siblings) or spouse of BBChainer is allowed. However, such hiring will be prohibited for positions with a direct or indirect subordination relationship. Likewise, affective relationships established between BBChainers are admitted, provided that there is no direct or indirect subordination relationship between those involved. BBChainer must notify its immediate management and Talent Development if it has any side activities that conflict with BBChain's actions or its daily work schedule.

BBChainer is not permitted to carry out projects related to BBChain's business or activities for current or potential customers of the Organization.

Gifts and entertainment

Objects (gifts or prizes) received from customers, suppliers or any body/institution linked to BBChain must be sent to the Talent Development Management for a draw among the BBChainers of the Organization, except in the case of small promotional gifts that have the logo from another company (e.g., diaries, calendars, key rings, etc.). Gifts are all goods, meals, travel, entertainment packages, or any benefits, direct or indirect, suppliers or customers may offer that to BBChainers, their family members, or partners. However, invitations to events with expenses borne by suppliers that characterize personal advantages may only be accepted with the approval of the Board of Directors. When in doubt, one should seek immediate management or the Board of Directors.

Purchasing practices

Any purchasing decisions must be made solely and exclusively in the best interests of BBChain. All commercial purchase agreements must be documented appropriately, clearly identifying the services or products to be provided, the payment terms, the cost, and the application of fees. The payment amount must exactly match the services or products documented and provided.

Corruption is considered to be the act of promising, offering, or giving, directly or indirectly, an undue advantage to a public agent or private employee or a third party related to him. It is not necessary to provide a cash advantage; it is enough to offer a benefit, gift, trip, or some valuable object. Another essential item is to finance or pay for illegal acts provided for by law, as well as to defraud bidding processes or hinder the investigation or inspection activity of the competent bodies. Keeping in mind the principles and guidelines of the Anti-Corruption Law, nº 12.846/2013, we reassure you that BBChainers cannot offer, directly or indirectly, any undue payment that could characterize a practice of corruption, bribery, or kickbacks in their relations with clients. It is also not allowed to request, suggest or accept any financial compensation, commission, donation, or advantage, whether occasional or not, from customers, suppliers, partners, or third parties. Exceptional cases will be analyzed individually by the Board.

Workplace

It is the responsibility of all BBChainers to ensure the quality of the work environment, keeping it clean and in ideal conditions of use. Noises that could disturb the work environment or interfere with the performance of other BBChainers should be avoided (e.g., music, cell phone ringtones, side conversations, meetings in corridors and common areas, and others alike.).

Patrimony

All BBChain assets and facilities are solely for company-related professional activities; therefore, they must not be used for other purposes. Everyone is responsible for protecting the company's assets against loss, damage, or theft and ensuring their good use and conservation. Therefore, keep the BBChain Controllership informed of any asset movements of the company by providing contracts, invoices received and issued, or any other document that supports operations so that the records comply with Brazilian accounting rules.

Physical and logical access security

It is BBChainer's responsibility to ensure the security of physical and logical access (information) in the company. For this, some basic measures should always be adopted, such as:

• Respect BBChain's physical and logical access control rules and procedures;
• When leaving the workstation, keep the stall clean, without documents and with the computer screen locked;
• Never give passwords and/or access codes to others (e.g., badges, system passwords, and others).

These contents are restricted, personal, and non-transferable. BBChain will attribute responsibility for misuse to the BBChainer holder of these credentials.

See our Data Protection Policy for more details.

Use of electronic communication systems

BBChain allows the moderate use of the Internet and electronic communication systems (Chat, Hangout, Social Networks, Whatsapp, and other similar programs), provided that there is no restriction on the part of the customer. It is under internal rules and procedures and does not interfere with work progress. It is prohibited to use electronic communication systems to access illegal, pornographic, gambling, chain letters, spam, or any other type of message with pejorative or discriminatory content. The company reserves the right to monitor IT resources and make information and reports available for administrative and institutional management actions. Only BBChain-approved software is allowed. This rule applies to any software, platform, or service on any infrastructure, whether on-premises, cloud-based, or virtualized. In case of special needs, BBChainer should contact the Support area to analyze the request.

Not tolerated by BBChain

Violation of copyrights, patents, and license agreement terms, use, or copies of software that are obtained illegally. One should store only files related to projects and areas of the company on BBChain computers.

Any remote access to BBChain's internal network resources is prohibited by default. However, the company's Support team will rigorously analyze exceptions, and, when relevant, the Support team will grant access to the authorized user.

Data protection

At BBChain, access to any data (including, but not limited to, data from BBChainers, customers, or third parties) is allowed only in case of need for consultation. Any personal data should only be accessed by those who need access to fulfill a specific purpose. In addition, the data can only be used for previously informed and analyzed purposes, which means that any use of personal data must be previously evaluated. Important! Improper access to customer information may subject you and BBChain to a range of disciplinary and regulatory sanctions, including criminal penalties. See our Data Protection Policy for more details.

Communication guidelines for social networks

Personal blogs, websites, and discussions on social media such as Facebook, Google+, LinkedIn, and Twitter must not reveal confidential information or damage the image of BBChain, customers, partners, or prospects. BBChainers should also avoid engaging in internet activities that could bring BBChain into disrepute, as well as posting derogatory or offensive comments (in some way, BBChainer's name may be related to BBChain's). On social media, it is essential to differentiate between BBChain's presence and BBChainer's persona as an individual; in the latter case, the employee must speak in the first person and use their voice, bringing their personality to the fore. The use of notices such as 'Messages posted on this site are my own and do not necessarily represent the views of BBChain' is suggested. Please consult with your manager or contact the marketing department in case of doubts.

Harassment and abuse of power

No manifestation of moral, sexual harassment or other action that characterizes embarrassment or threat is allowed on BBChain. For this Code, sexual harassment is embarrassing someone to receive a sexual benefit or favors, as well as making unwanted sexual advances (verbal or physical) or jokes with sexual connotations. Sexual harassment is a crime and will be treated as such by BBChain. The company does not tolerate the misuse of the position or function, whether to mistreat, embarrass, intimidate or attack any individual. The BBChainer who feels harassed or assaulted should contact the Ombudsman or the Talent Development area so that BBChain can provide the necessary assistance.

Carrying arms

It is not allowed to carry weapons of any kind on BBChain premises except by duly trained and authorized professionals (e.g., guards, police, and others alike).

Political participation

BBChain has no political involvement and does not participate in partisan demonstrations. Therefore, any BBChainer is prohibited from participating in political actions and campaigns using or associating BBChain's image with any candidate or political party. BBChain respects everyone's political preferences; however, BBChainer who wish to participate in political actions must use their free time, outside working hours and premises, and clearly express that it is their personal choice, discarding any relationship with the company. Political speeches will also not be tolerated within BBChain premises – including messages on bulletin boards and murals, candidate and party T-shirts and buttons, or any other type of demonstration in this regard.

Trade within BBChain

Formal or informal trade on the company's premises is prohibited, except in situations previously authorized by the company.

The use of alcohol and illicit drugs during the working day is permanently prohibited, and access to the company's facilities carrying these substances or in an altered state due to their use will not be allowed. In addition, at BBChain-sponsored events, alcoholic beverages will only be permitted moderately.

Audits

All BBChainers are requested to cooperate with audits carried out at the company. All information provided must be correct and reliable. You must not hide or destroy any documentation and records in connection with an audit. These assumptions are also valid in the case of audits carried out by external bodies; however, in such cases, BBChainer should seek the advice of its immediate management or the Board of Directors before answering any questions.

BBChain's representation before the press or any other agency/institution

All contact with the press on behalf of BBChain, as well as taking pictures and filming, can only be done with prior knowledge of the Marketing area. Whenever a BBChainer speaks or presents any material on behalf of the company, they must seek advice from their immediate manager or the Marketing area to receive the necessary guidelines and materials unless there is already express authorization for the disclosure of the topic addressed. It is also worth mentioning the need for express approval from the Organization to use logos on any product or means of communication.

Ombudsman

Everyone must endeavor to ensure that anyone subject to their leadership or authority complies with applicable laws, rules, regulations, and this Code, informing BBChain of acts performed in violation of current legislation, this Code of Conduct. If you made a report in good faith, please be assured that your identity is strictly confidential and that you are protected from retaliation.

Violations and penalties

The Ethics Committee will carefully analyze violations of the principles and rules of this Code of Conduct. As a result, it may incur disciplinary measures provided for in the legislation and the applicable contractual relationships. In addition, failure to comply with the terms of this Code may subject BBChainers to corrective measures, which include warning, suspension, dismissal for cause, and other penalties provided for in labor legislation, regardless of other actions that the company may adopt, whether in the civil, criminal or labor. In the application of disciplinary penalties, the nature and severity of the infraction will be considered, always observing the rules issued by the Talent Development area and the applicable legislation.

Questions, reports and sugestions

Do you have questions about the BBChain Code of Conduct? Do you believe that another BBChainer, or even BBChain, is not following the expected standards of conduct? Do you want to report or deal with a problem? The first source of consultation should be your immediate manager or the Ethics Committee. If you do not feel comfortable discussing the matter or issue with your superior, please let us know through the Ombudsman, BBChain's whistleblower channel. The Ombudsman is confidential and handled by an independent institution specialized in the area. To access it, send an email to contato@bbchain.com.br.

Final dispositions

Always ask yourself: Are my actions in line with the Code of Conduct and BBChain's values? The control and amendment of the Code of Conduct is the responsibility of the BBChain Ethics Committee. Eventual contributions and alteration suggestions are very welcome. However, the Board will analyze them and, if approved, consider them in the document. This Code is also available for consultation at any time on the Intranet.