1. OBJECTIVE

This Code of Ethics aims to establish standards of behavior and determine issues related to (i) compliance with rules of coexistence in the workplace, without distinction of hierarchy, areas or functions exercised; (ii) the transparency of operations in general; (iii) the safety of the activities of the professionals involved; and (iv) the security and secrecy of information that must be protected by confidentiality.

In addition, it provides LOGIKS employees with an understanding of the anti-corruption law (Law No. 12.846/2013) and its regulations. It also serves as an effective tool for compliance and prevention, in order to guide employees, staff and third parties who have dealings with the company in identifying conflicts and infractions that could be considered illegal practices. In this sense, this document helps to identify irregularities and/or infractions that could compromise the organization's integrity. For this reason, some procedures will be listed that should be adopted in order to ensure ethical conduct and commitment to the ethical guidelines imposed by the anti-corruption law.

2. INTRODUCTION

LOGIKS CONSULTING AND SERVICES IN INFORMATION TECHNOLOGY LTDA.

("LOGIKS") is a company that operates in the Information Technology segment, aware that the success and continuity of its business is directly related to the guidance of ethical standards and the sustainable management of its business, so that the impact of its actions results in a balance between the social, economic, environmental and corporate governance aspects with all its stakeholders.

The Code of Ethics is aligned with passion, the spirit of building something new and transforming actions, always considering the human factor, in order to reinforce the commitment through equal and non-discriminatory treatment based on the principles:

Dignified and respectful, recognizing, accepting and not discriminating against gender, social class, ethnicity, divergent opinions and beliefs and always preserving physical, moral and psychological integrity;
Repudiating any abuse or harassment, whether moral or sexual;
Repudiation of any action to exploit labor, whether slave labor, labor analogous to slavery or child labor;
Compliance with internal policies and all applicable legislation and regulations.

The guideline is given by the corporate foundations, based on social and corporate responsibility, so it is a formal reference that even guides the internal and external professional conduct of all the Institution's Employees.

3. SCOPE

The Code of Ethics includes guidelines for conduct based on ethical and moral standards that will serve as a benchmark for the behavior of all employees, both internal and external, i.e. members of the LOGIKS staff in the performance of their duties, including service providers, suppliers and business partners who are linked to the Institution.

Training, refresher courses and certifications in compliance are carried out annually throughout the company, keeping all the concepts and regulations on the subject up to date.

4. WORKING ENVIRONMENT

A Instituição fomenta um ambiente de trabalho com respeito e dignidade, bem como não permite entre seus Funcionários / Colaboradores qualquer tipo de discriminação e está comprometida com ações e políticas para assegurar oportunidades de trabalho justas, incluindo tratamento igual na contratação, promoção, treinamento, compensação, rescisão e ação corretiva, e não tolerará atitudes de discriminação por parte de seus Funcionários / Colaboradores.

Cooperation and teamwork are the great allies of our culture and reinforce LOGIKS's concern for a healthy and harmonious environment in which to work. The relationship with our members is welcoming, based on respect, equality and equal rights. It is everyone's duty to ensure this environment.

Our work environment is pleasant and fosters courteous relationships between people. That's why we respect individual freedom and treat each person with dignity, providing everyone with opportunities for professional and personal growth.

Respect for human rights is a constant in our daily lives. Our relationships are based on freedom of thought and expression and equal rights. Any mention of institutions and people is made in a trustworthy, affectionate manner and free of prejudice or malicious intent.

We encourage everyone to go beyond expectations and their performance, which contributes to an innovative environment, reflected in differentiated products and services that are recognized by our clients. In the interaction between teams, leaders are oriented towards encouraging professional development in all positions, providing for the evolution of the individual and aiming for excellence in our activities.

5. WHISTLEBLOWING CHANNEL

Complaints can be made via the website www.logiks.com.br/ouvidoria/They can be made anonymously or duly identified.

The Conduct, Risks and Compliance Committee must ensure the secrecy and confidentiality of information received and decisions made. Confidentiality can only be broken if there is a need to notify public authorities or regulatory bodies, or by court order.

LOGIKS prohibits retaliation against anyone who reports, participates or collaborates in any investigation. If you believe that you are being retaliated against, please contact the Compliance team or report it through our channel.

No detrimental action will be taken against anyone who complains, reports, participates or assists in the investigation of a suspected violation of the Code of Conduct.

Todas as denúncias recebidas serão investigadas, e se confirmadas, darão ensejo a medidas de ajustes ou punitivas. Nenhuma conclusão será tomada precipitadamente, sem que os fatos e as circunstâncias tenham sido objetivamente investigados e avaliados.

Todas as investigações são sigilosas e todos devem cooperar.

6. ETHICAL PRINCIPLES

6.1 Abuse, Harassment and Discrimination

O respeito ao próximo é uma premissa levada a sério na Instituição e, por isso, não toleramos assédio moral ou sexual, discriminação de cor, raça, credo, gênero, orientação sexual ou idade – ou qualquer outro tipo de abuso.

We consider moral harassment to be any abusive conduct (gestures, words, writings, behavior, attitudes, etc.) that intentionally hurts a person's physical or psychological dignity, threatens their job, embarrasses them or degrades the atmosphere in the workplace.

Sexual harassment is when someone in a privileged position uses this advantage with the intention of obtaining sexual favours from members of their team, hurting people's psychological and professional integrity.

All types of harassment, discrimination and abuse must be curbed and immediately reported to the Human Resources team or the Whistleblowing Channel, so that it can be dealt with appropriately.

6.2 Use of Alcohol, Drugs, Weapons and Violence

We encourage physical, emotional, intellectual and social balance and strongly encourage the adoption and maintenance of healthy habits for the well-being and safety of our teams.

Alcohol consumption is permitted in our work environments, on special and/or celebratory occasions, but use common sense and never drink in a way that affects your performance, conflicts with your routine or leads to inappropriate behavior, endangers the safety of others or violates the law.

The possession or use of illegal drugs is forbidden in our offices or at sponsored events, where we also do not allow the possession of any type of weapon and do not tolerate violent acts, whether physical or verbal.

6.3 Corruption prevention

De acordo com o Código Penal em vigor, pratica o crime de corrupção ativa o particular que “oferecer ou prometer vantagem indevida a funcionário público, para determiná-lo a praticar, omitir ou retardar ato de ofício”. A legislação penal também prevê como crime a corrupção ativa em transação comercial internacional, definindo a prática criminosa como “prometer, oferecer ou dar, direta ou indiretamente, vantagem indevida a funcionário público estrangeiro, ou a terceira pessoa, para determiná-lo a praticar, omitir ou retardar ato de ofício relacionado à transação comercial internacional”.

Since 2013, Law 12.846, known as the "Anti-Corruption Law", has also provided for administrative sanctions for legal entities that commit acts against the national or foreign public administration.

The conducts listed there are much broader, and are considered punishable acts under the law:

“"Art. 5 - For the purposes of this Law, all those acts committed by the legal entities mentioned in the sole paragraph of art. 1, which violate national or foreign public assets, public administration principles or international commitments assumed by Brazil, as defined herein, constitute acts harmful to the national or foreign public administration.

prometer, oferecer ou dar, direta ou indiretamente, vantagem indevida a agente público, ou a terceira pessoa a ele relacionada;
comprovadamente, financiar, custear, patrocinar ou de qualquer modo subvencionar a prática dos atos ilícitos previstos nesta Lei;
comprovadamente, utilizar-se de interposta pessoa física ou jurídica para ocultar ou dissimular seus reais interesses ou a identidade dos beneficiários dos atos praticados;
no tocante a licitações e contratos:

frustrate or defraud, by means of an arrangement, combination or any other expedient, the competitive nature of a public bidding procedure;
impede, disturb or defraud the performance of any act of a public bidding procedure;
remove or seek to remove a bidder, by means of fraud or offering an advantage of any kind;
fraudulently bidding on a public tender or contract arising from it;
create, in a fraudulent or irregular manner, a legal entity in order to participate in a public bidding process or enter into an administrative contract;
obtaining undue advantage or benefit, fraudulently, from modifications or extensions of contracts entered into with the public administration, without authorization by law, in the public bid invitation or in the respective contractual instruments; or
manipulating or defrauding the economic-financial balance of contracts entered into with the public administration;
- - hinder the investigation or inspection activities of public bodies, entities or agents, or intervene in their activities, including within the scope of regulatory agencies and national financial system inspection bodies.
- 1º Foreign public administrations are considered to be state bodies and entities or diplomatic representations of a foreign country, at any level or sphere of government, as well as legal entities controlled, directly or indirectly, by the public authorities of a foreign country.
- 2º For the purposes of this Law, public international organizations are considered to be a foreign public administration.
- 3º For the purposes of this Law, a foreign public official is anyone who, even temporarily or without remuneration, holds a position, job or public function in state bodies, entities or diplomatic representations of a foreign country, as well as in legal entities controlled, directly or indirectly, by the public authorities of a foreign country or in international public organizations.".”

Such conduct is prohibited and not tolerated by the institution. If someone requests this type of advantage from an Employee/Collaborator, they must immediately inform the responsible area via the Whistleblowing Channel of the incident.

6.4 Money Laundering Prevention

The crime of money laundering or concealment of assets, rights and values occurs when there is concealment or disguise of the nature, origin, location, disposition, movement or ownership of assets, rights or values derived, directly or indirectly, from a criminal offense.

Therefore, the crime is characterized when the agent conceals or hides amounts obtained through illicit activities, so that they appear as the result of legal commercial operations and can be absorbed by the financial system.

In view of this, in absolutely all day-to-day tasks, the employee/co-worker involved in financial transactions with third parties must be diligent in paying attention to the origin of any funds received or transacted with third parties. If they suspect any irregularity, they must immediately notify Compliance,so that it can analyze the suspicion and refer the matter to the competent authorities.

6.5 Ethics

The Institution is committed to high standards of conduct and behavior adopted by its board of directors, managers, employees, collaborators and others involved in the performance of its functional activities, which are expected to be fully complied with, because in our understanding, ethics at work guides not only the content of decisions (what should be done), but also the decision-making process (how it should be done).

We respect the personal dignity, privacy and individual rights of everyone, and we work and collaborate with people from diverse ethnic and cultural backgrounds, religions, ages, races, sexual identities and worldviews.

Consistent with our business principles; and with local laws, we do not tolerate any discrimination against anyone based on these characteristics, nor any harassment or offensive behavior, of a moral or sexual nature.

Para maximizar o alinhamento com esta visão adotamos o padrão ético instituído neste Código como referência, formal e institucional para a conduta pessoal e profissional de todos os Funcionários / Colaboradores, independentemente da função que ocupem, de forma a tornar-se um padrão de relacionamento interno e externo com os seus públicos de interesse: sócios, clientes, fornecedores, outros parceiros comerciais, entidades governamentais e o público em geral.

In addition to the duties laid down by law, Employees / Collaborators must observe the following duties:

Act with prudence, diligence, integrity, responsibility, honesty, loyalty and transparency;
Be aware that their work is governed by ethical principles;
Strive for cooperation, courtesy, mutual respect and trust in relationships with other professionals, without any kind of prejudice or discrimination;
Manter-se isento e com uma postura profissional no relacionamento com Clientes; Manter sigilo absoluto sobre as operações e informações da Instituição, seus Clientes, Prestadores de serviços e Fornecedores, das quais tenham conhecimento por sua atuação;
Do not give in to pressure or intimidation from Clients, beneficiaries, interested parties or any others seeking undue favors or advantages;
Informar seu Gestor ou o Compliance, sobre quaisquer atividades irregulares antiéticas, corruptas ou ilegais ocorridas dentro da Instituição de que tenham conhecimento, devendo o informado preservar o anonimato do informante;
Respect co-workers, regardless of race, age, gender, physical appearance, sexual option, religious option, geographical origin or political option;

In addition to the obligations and prohibitions laid down by law, Employees / Collaborators must observe that the following conduct is strictly forbidden:

Requesting, suggesting or receiving any advantages using the name of the Institution, their position or function, to obtain personal benefits or for third parties;
Using any privileged or confidential information obtained in the course of their professional practice, for their own benefit or that of third parties, in business outside that of the Institution;
Treating other employees, clients or suppliers differently for personal reasons;
Carrying out any professional activities that conflict with their job or position, or are incompatible with their working hours;
Exposing any Collaborator or co-worker to vexatious situations, using tricks intended to discredit or humiliate them;
Complying with irregularities or any conduct classified as a crime or illicit.

7. INTERNAL AND EXTERNAL RELATIONS

Relationship with the environment

LOGIKS is committed to respecting and preserving the environment and water resources, acting in a legal, preventive and educational manner, with a view to environmental sustainability, health and the population's quality of life. It adopts measures such as minimizing the use of plastic cups on its premises, providing mugs/bottles for the daily use of its employees. It also encourages the unnecessary use of paper, among other measures to reduce the negative impact on the environment.

7.2 Internal Relations

Carry out their activities in accordance with this Code and follow internal policies and manuals, as well as legislation and rules issued by regulatory bodies, encouraging and guiding their colleagues in this regard;
Maintaining a positive, dignified, loyal, honest professional attitude of mutual respect, trust and collaboration with other work colleagues;
Act and treat everyone with respect in the corporate environment;
Repudiate and curb any act of discrimination, whether related to race, religion, color, social class, gender, age or any other;
Not using the position held to request personal favors or services from subordinates;
Tratar a todos com igualdade e cortesia, oferecendo oportunidades de desenvolvimento e crescimento profissional;
Os gestores devem constituir modelo de conduta para sua equipe.

7.3 Relations with employees and collaborators

LOGIKS' relationship with its employees is based on participatory management, respect for and compliance with legislation, contracts, collective bargaining agreements and internal rules.

In addition, it encourages its employees to adopt a healthy quality of life, promoting meetings for sports activities, as well as encouraging its employees to eat healthily by providing a kitchen/cupboard with appliances in its premises for employees to use in order to store lunch, fruit, snacks, i.e. healthy food.

It also encourages its employees to take care of their mental and physical health through the Human Resources department's weekly tips on well-being at work.

7.4 Customer relations

To serve clients with efficiency, respect and courtesy, seeking to offer products and services that meet their needs;
Ensure transparency in the operations carried out;
Providing Clients with clear, precise and appropriate information, warning them of the risks inherent in each type of operation and application in which they are involved;
Inform Compliance of any suspicion of money laundering or terrorist financing;
Avoid situations of conflict of interest;
Never favor one client over another;
O relacionamento com o Cliente deve ser pautado nos princípios emanados do Código de Defesa do Consumidor.

7.5 Relationship with Competitors

For competition to be healthy, it must be based on fairness and mutual respect;
Practices such as any kind of manipulation, espionage and omission of relevant facts, among others, are prohibited.

7.6 Relations with suppliers

Suppliers and Service Providers hired by the Institution must observe ethical standards compatible with those set out in this Code of Conduct when carrying out their activities;

The choice and contracting of Suppliers and Service Providers must be based on technical, impartial criteria and in accordance with institutional needs;
The hiring of any company in which one or more employees have some kind of direct or indirect stake or interest must be submitted for analysis to the Compliance and Legal areas, which must submit it to the Conduct, Risks and Compliance Committee for approval;
In the case of the purchase of goods and/or equipment, at least three quotes must be requested in order to find the best price and quality of the goods;
In order to guarantee the premises set out in this Code, all Employees/Collaborators are expressly prohibited from / Employees are expressly forbidden to:

Maintaining a business relationship, as a representative of the institution, with a company in which they or their family members have a direct or indirect interest or stake, without prior authorization from the Compliance and Legal areas;
Aceitar benefício pessoal, como pagamento em dinheiro ou mercadoria, viagem, almoço, jantar ou qualquer vantagem advinda de relacionamento com fornecedor.
Despesas com viagem, hospedagem e refeições devem sempre ser pagas pela Instituição, mesmo que o convite parta do Fornecedor.

7.7 Relations with Government and Regulatory Bodies

Requests from public authorities or regulatory bodies must be received and dealt with promptly and transparently;
The Institution must not express opinions of a political nature;
The institution strictly complies with anti-corruption legislation and therefore prohibits offering privileges or personal advantages to public officials as a result of their position.

8. GENERAL RULES OF CONDUCT

8.1 Os dirigentes e colaboradores da LOGIKS, devem pautar seu comportamento por este Código de Ética nos seguintes termos:

Preserve and cultivate the positive image of the Company;
Develop conditions conducive to the establishment of a productive, respectful and pleasant working environment;
Treat people and their ideas with dignity and respect;
To act loyally, fairly and openly in working relationships;
Preserving the well-being of the community, respecting the personal characteristics, freedom of opinion and privacy of each individual;
Act clearly in defense of LOGIKS` interests;
Present themselves in an appropriate manner for the performance of their duties and activities at LOGIKS;
Refrain from using internal or external influence to obtain personal or functional advantages;
Refrain from using their position, the position of trust they hold or their status as a LOGIKS employee to gain advantages for themselves or for third parties;
Use LOGIKS resources only for purposes in the interests of the Company;
Contribute to the smooth running of the whole company, refraining from acts and attitudes that prevent, hinder or disrupt the provision of services;
Refuse or refrain from offering gifts and/or presents worth more than R$100.00 (one hundred reais) to individuals and/or companies that maintain commercial relations with LOGIKS ;
Failure to prepare and/or present information that reflects actual economic, financial, operational, logistical and any other positions and results that affect the Company's performance;
Prioritizing and preserving the interests of LOGIKS with clients, government bodies, financial institutions, entities and other companies with which it has a commercial relationship;
Always be accompanied by another employee, the manager or a peer, when maintaining any relationship (meetings) with a partner supplier, which results or may result in contracting that meets the interests or needs of LOGIKS;
Strictly agreeing to the company's guidelines and strategic conduct when taking on a position of trust in the company;
Resign from the position of trust to which they have been appointed, when there is dissonance with the company's strategic guidelines and orientations;
É inaceitável que qualquer dirigente ou colaborador da LOGIKS reivindique benefícios ou vantagens pessoais para si próprio ou para terceiros, em decorrência de relacionamento comercial ou financeiro firmado em nome da LOGIKS, com clientes, órgãos governamentais, instituições financeiras, fornecedores, entidades e outras empresas com as quais a LOGIKS mantenha esse relacionamento;
Officers or employees are not allowed to carry out other professional activities during working hours, whether for profit or not, or, regardless of the compatibility of fees, to carry out activities that constitute damage to or direct or indirect competition with LOGIKS` activities.
Discrimination of any kind against people on the grounds of economic, social, political, religious, color, race or sex is prohibited;
Documents, works, methodologies, products, tools, services and information owned by LOGIKS or its customers and suppliers may not be used for their own benefit or for the benefit of third parties, except by legal or judicial order;
It is not permitted to speak on behalf of the company by any means of public disclosure without the authorization of the LOGIKS Board of Directors or manager in charge;
It is forbidden to make donations to political parties, as well as to generate any kind of asset confusion between the company's assets and its own assets, regardless of whether any pecuniary advantages arise from this confusion.
If in doubt about the correct course of action, the employee or manager should seek help from their superior or the LOGIKS Compliance Committee.

9. VALUES

Respeito às pessoas.
Responsabilidade social e cidadania.
Integridade profissional e Pessoas.
Transparência nos processos.
Proud to work at LOGIKS.
Gosto por desafios.
Equidade de Gênero, Raça, Credo, Orientação Sexual etc.
Compromisso com resultados.
Technical competence
Confiança e credibilidade.
Confidentiality and security of information.

This Code of Ethics takes effect from the date it is signed.

This Code of Ethics must be reviewed and/or updated annually, in order to show that it has been assessed, discussed and reformulated in accordance with the latest compliance precepts.

Any evidence of irregularities in compliance with the provisions of this Code will be the subject of an internal investigation and must be reported immediately to the Compliance area.

Brasília/DF, November 10, 2022.

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Code of Conduct and Ethics