1. Values and Purposes of the Firm

The present code of conduct and professional ethics establishes some of the company’s principles and objectives and aims to guide its employees on values considered essential to execute services within the firm and externally with clients, suppliers, external communication channels and the community.

Guimarães IP is faithful to the fulfillment of all the items dealt with herein and understands that the continuity of its activities is strictly linked to the respect of minimum integrity standards and of mutual respect, where each employee must always use his/her best efforts to achieve the goals herein established.

2. Protection of Company and Third Party Assets, Resources and Data

All company assets must be used responsibly and with the view of fulfilling the business purposes. The use of any means and resources of the company for personal purposes should be avoided whenever such activity could compromise the integrity of the security of any data of the firm, its clients or suppliers. In case of any questions about what constitutes a business or personal use of the company’s assets, it is recommended that the employee contact the person responsible for this code of conduct and professional ethics program to clarify over the specific practical case.

Our business is fully linked to the protection of our client’s data and the complete commitment to confidentiality, under the terms of the law, of any and all information received must be respected. Discretion is always recommended when dealing with any matter related to topics of interest to our customers and confidential information that is entrusted to our company must be shared internally only when necessary for the fulfillment of the contracted services. Caution is recommended when discussing matters of interest to the clients, even with company employees, in public spaces such as elevators and restaurants, as well as with friends and family, even if at home on days of home office activities. If you become aware that any misuse of the firm’s data or of Third Parties that have a relationship with the company is taking place, you should immediately contact the person responsible for this code of conduct and professional ethics program.

During the execution of our services, personal data of employees, clients, suppliers and other persons may be collected and/or processed. This data must be requested, collected and/or processed only when necessary and within the strict fulfillment of our business activities, for which we have legal basis. Only people who need to be aware of such information should have access to personal information other than their own and whenever possible, the personal data collected should be anonymized. In case of requesting any personal data outside those that are within the legal bases of activity of the Firm, the data must only be obtained, collected and/or treated with prior consent of its owner or its legal representative. Whenever possible, personal data, materials and information of our customers should be properly discarded from the moment they have lost the need to be within the physical and/or virtual facilities of our company. It is the obligation of each employee to ensure that they are in strict compliance with the company’s privacy and data protection policy, as well as to ensure the adequacy of their activities and those of the company to the regulations related to the protection of personal data.

As already discussed here, our business is totally linked to the protection of our clients data and we must also act with a greater degree of attention whenever such information may constitute Intellectual Property of the Firm, our Clients or Third Parties that have a relationship with the Firm activities. It is hereby informed that any and all confidential information obtained through access to the Firm’s resources, means, data, materials, facilities or equipment belongs exclusively to the Firm, as well as any and all confidential information obtained through access to the resources, means, data, materials, facilities or equipment of the Client belongs exclusively to the Client. The utmost care is always recommended for such confidential information that may represent intellectual assets of the Firm and its Clients.

All employees must also ensure that the Firm’s books and records are always complete and accurate and that all business transactions are properly authorized.

3. Environmental, Social and Governance Management (“ESG”)

All employees must seek to carry out their activities in a way that preserves the environment and, whenever possible, promote good practices of social responsibility for other employees and third parties. Employees should also always seek to preserve the well-being and health of its colleagues and ensure the preservation of the personal safety of everyone who integrates the Firm.

It is highly recommended that all employees reflect on how their actions during the execution of their work can impact the communities in their neighborhood and reflect on ways to mitigate any impacts detected.

Employees must develop their activities and decision-making reflecting on how to increasingly develop a positive, diverse, inclusive work environment, free from discrimination, violence, harassment and always respecting the human rights of each individual.

Transparency in the conduct of our acts and services, whether with our own employees or with customers and government agencies, will always be encouraged and it is the duty of each employee to report any discrimination, violence and harassment that he or she is aware that is taking place in their surroundings. We must also incorporate ESG criteria (Environmental, Social, and Corporate Governance) in the conduct of our procedures, including anti-bribery and anti-corruption practices.

Our company is committed to always prioritizing its Client’s initiatives aimed at reducing the environmental impacts inherent to human activity, as well as initiatives of a social nature. The company is committed to assisting such initiatives whenever possible and acting, when applicable, in a pro bono service provision .

4. Internal and External Communications

All employees must commit to using the communication tools available in an appropriate manner and with the purpose of acting within the Firm’s activities, complying with the Firm’s Privacy and Data Protection Policy. Any and all communication of a personal nature must be limited and carried out in a way that does not compromise your work activities or the activities of other employees. Sending and/or storing confidential company information in personal emails or personal databases is strictly prohibited. The Firm does not authorize access of inappropriate or ilegal information within its facilities or in the use of its equipments such as computers and cell phones. Employees activities may be monitored and stored to ensure that these resources are properly used in accordance with applicable regulations.

All public communications that may be made by the Firm or its employees must be made completely, truthfully and objectively. For this purposes, it is recommended to exercise caution about the use and disclosure of any information on social medias, and not to speak on behalf of the Firm, unless authorized to do so. It is also recommended that whenever there is any communication that it reinforces a positive image of you and of the Firm.

The Firm is committed to, whenever possible, carry out training on the policy stipulated herein and to act in order to make the Firm’s intentions and goals increasingly clear to its employees. Whenever there is any doubt about any conduct to be carried out, the employee is encouraged to contact the person responsible for this policy.

5. Relationship with Business Partners

Business partners must always be treated respectfully and in good faith with clients, suppliers, competitors and other people who may interact with the Firm. All employees must use the utmost respect and responsibility when using our Clients information.

The company is guided by transparency in all its recommendations to our customers, presenting in a clear and objective way the options that the customer has and any risks (whether of a legal, financial commercial or reputational nature) that the employee sees on each option. All employees must always use their best efforts, within their expertise and experience, to ensure that the Client is always well oriented and attended.

It is forbidden to send any gifts to the company’s business partners, whether gifts, gifts, travel, accommodation, entertainment activities to any customer or public agent in order to obtain favours or advantage over any past or future act of any agent. The conduct of any policy for sending gifts must always be of a generic nature and of a merely institutional nature, of low relative value, and for the general dissemination of the Firm’s services.

6. Compliance with Laws, Rules, Regulations and Policies

All Firm’s activity must be carried out within the limits established by law and it is the duty of all employees to be up-to-date in the knowledge of all laws, rules, regulations and policies applicable to their functions.

All employees must recognize their individual obligations and act to understand and comply with the laws, rules, regulations and policies that apply to the performance of their duties and functions. The acquisition or use of inside information and other forms of market abuse is strictly prohibited, especially in dealing with public companies, asset managers and investment advisers.

The Company also expects all of its Employees to conduct their activities in strict compliance with laws that prohibit corrupt practices, including the Brazilian Penal Code, Law No. of Administrative Misconduct”), Law No. 12,529/2011 (“Competition Defense Law”), Law No. 14,133/2021 (“Bidding Law”); Law No. 9,613/1998 (Law on crimes of laundering and concealment of assets); Law No. 12,529/2011 (Antitrust Law); Law No. 7716/89 (Crimes of racial or color prejudice); Law No. 13,146/2015 (Statute of Persons with Disabilities).

The Firm informs of the repeated monitoring of its code of conduct and professional ethics and reserves the right to update this policy whenever it deems necessary or due to new legal requirements for the conduct of its activities.

7. Conflicts of Interest

All employees must avoid situations in which their personal interests enter or may conflict with the interests of the Firm, its customers, suppliers or third parties that have a relationship with the company.

8. Legal and disciplinary measures

The Firm informs that it is entitled to take the appropriate disciplinary and legal measures regarding any violation of this code of conduct and professional ethics, and may, for such purposes, issue warnings, suspension of the activities of certain employees, termination of the employment relationship, request restitution of damages that may be caused to the Firm’s assets or image and reputation; and reporting facts considered illegal to the competent authorities.

It is therefore recommended that all employees be aware of the guiding principles of this code and that they act in order to preserve the Firm’s assets and reputation, being attentive to warning signs that may represent improper conduct. Whenever appropriate to report suspicious activities. or inappropriate conducts to the Firm’s compliance channels.