1. Introduction and Scope of the Code

Introduction: This Code of Ethics and Conduct was approved by the Administration Board of KAPAZI Indústria e Comércio de Capachos Ltda., on March 18, 2024. It is a document that summarizes the main policies and guidelines defining the guiding rules for the conduct and organizational practices of Kapazi employees across its different units, factories, and stores, regardless of their regional location. It reflects the company's commitment to ethical behavior in its relationships with various stakeholders and reaffirms one of its most important objectives: maintaining and consolidating its reputation within society.

The vision, mission, and values (described in specific material) define the organizational identity and guide the company's business conduct. The Code provides clear and non-negotiable guidelines regarding commitments to conduct and ethics, is mandatory, and may be updated over time. Employees who fail to comply with the rules set forth in this document will be subject to disciplinary actions, including the possibility of termination of their employment contract.

2. The Code aims to:

2.1 Formalize and institutionalize professional conduct standards, becoming a benchmark for the internal and external relationships of the company and its employees with its various stakeholders;

2.2 Guide the actions and decision-making of professionals and reduce the risks of subjective personal interpretations regarding moral and ethical aspects; 2.3 Promote ethical behavior in the business environment.

3. Scope: The Code applies to all Management members and Employees, including interns and apprentices of Kapazi.

4. Conduct in Relationships with Various Stakeholders

4.1 Relationships with Clients and Consumers: Kapazi seeks to identify the needs and meet the expectations of clients and consumers in accordance with its Quality Policy. To this end, it regularly conducts technical studies and research. Based on these studies and research, employees are expected to provide receptive service through its communication channels and strive to effectively resolve the individual demands and concerns of clients and consumers. They must also act strictly in accordance with consumer protection legislation and observe competitive practices, not condoning coercive and unfair commercial practices, or those that abuse their power in specific situations. In relationships with clients and consumers, employees must not use inappropriate means to gain undue advantages.

4.2 Relationships with the Community: Kapazi respects the local customs and cultures of the communities in which it operates and adopts a responsible stance of involvement through its Human Resources team or through groups or committees developed for this purpose. Kapazi adopts transparent processes to identify, select, and support social projects, encouraging employees to volunteer and develop projects and initiatives aimed at contributing to a more just and supportive society.

4.3 Relationships with Employees: Workplace relationships must be guided by respect and impartiality, with no form of discrimination or retaliation being permitted. All employees must receive fair treatment and evaluation. No favoritism or prejudice will be tolerated under any circumstances. All employees have the right to freedom of union association, religious choice, political and gender positioning.

4.3.1 Conflict of Interest: In order to prevent potential conflicts of interest, it is mandatory for the employee to notify DHO in writing if any of their relatives, of any degree, or close friends work or come to work in companies in the same sector. Failure to communicate may result in appropriate disciplinary measures (Article 3, item I and Article 4 of Law 8.213/13).

a) A conflict of interest is characterized when an employee acts to achieve private interests that conflict with Kapazi's interests or may cause any damage to the company.

b) Employees and their direct family members must not have corporate ties with suppliers, clients, or competitors if their position grants them privileged information or the power to influence company transactions.

c) Every position held by employees in any other entities or companies must be communicated to their superior for evaluation of possible conflicts of interest.

d) Unless expressly authorized, employees may not sell products or services on company premises or during working hours.

e) All employees have the duty to inform the Board or Management about any situation that could be characterized as a conflict of interest.

4.3.2 Use of Kapazi Property Resources and Confidential Information:

a) Employees must protect and make good use of company assets.

b) Employees are not permitted to use company assets and resources for their own benefit, unless duly authorized (in writing) by their hierarchical superiors.

c) The Information Security Policy is disseminated to all employees during their onboarding process at the company.

d) It is the employee's duty to follow the rules regarding the use of IT equipment and virtual information. Confidential company information, such as commercial strategies or expansion planning, as well as other secret data, cannot be used or disclosed by employees for their own benefit or for the benefit of third parties.

e) Employee data may not be disclosed inside or outside the company, except when required by legal or judicial provisions.

f) Employees responsible for maintaining and storing information must observe the form and deadlines provided in the applicable regulations and the appropriate manner, in order to preserve the integrity of documents and data.

4.3.3 Relationships (Family and Affective) between Company Professionals:

a) Kapazi accepts the hiring of employees' relatives, but without privileges in terms of positions, salaries, and benefits, and all must have competed on equal terms with other candidates.

b) Employees who are married or in a committed relationship must treat the professional environment with the utmost respect and ethics, not publicizing their intimacy, thus respecting all other employees.

4.3.4 Respect for the Individual (prejudice, discrimination, and harassment): Kapazi's policies and practices do not permit prejudice or discrimination of any nature, whether in selection, evaluation, promotion, or dismissal processes. Opportunities are offered to individuals regardless of sex, race, age, origin, sexual orientation, political or religious conviction, or physical disability. Positions must be filled by individuals who meet the technical requirements for the role. Kapazi does not tolerate:

a) Abusive or embarrassing conduct, harassment of any kind, and arbitrary situations such as intimidation, coercion, or threats in relationships between employees, regardless of their hierarchical level;

b) Child labor and does not condone any situations that potentially involve the irregular employment of adolescents under 16 years of age (except as apprentices, from 14 years of age);

c) Consumption of alcoholic beverages and illicit drugs, as well as being under the influence of these during working hours or while rendering service to the company;

d) In accordance with the previous item, the consumption of tobacco and all its derivatives on company premises will not be tolerated.

e) Retaliation against any employee who reports possibly inappropriate behavior or who feels embarrassed or intimidated by abusive conduct. Kapazi is committed to the rights of children and adolescents. It is against any form of negligence, discrimination, cruelty, violence, sexual exploitation of children or adolescents, and pornography in the company's activities, in the use of its products and services, and in its value chain. Kapazi is against slave, forced, or compulsory labor and situations that potentially involve coercion, punishment under any pretext, degrading disciplinary measures, and punishment for exercising any fundamental right.

4.3.5 Rehiring of Employees: Former employees may be rehired by the company, provided that the analyses or policies of the Human Resources department and top management are observed.

5. Relationships with Suppliers, Service Providers, and Third Parties in General

5.1 Evaluation of Suppliers and Service Providers: Kapazi evaluates its suppliers using clear criteria, established technically and economically by the competent departments, and no form of discrimination or favoritism of any nature is permitted. Thus, all employees must act impartially, always observing technical and economic criteria and aiming for the company's interests. The evaluation of contracting companies of former employees must respect the criteria established by the Supply department, in addition to special care not to expose the company to labor risks.

5.2 Receiving Gifts:

a) Gifts and presents offered by suppliers and service providers will only be accepted with the approval of the board of directors. Presents given to employees or their family members must be returned with thank-you letters;

b) No Kapazi employee or family member may accept cash from Kapazi suppliers, clients, banks, or service providers.

c) Employees must inform suppliers and service providers about the company's policy regarding gift-giving.

d) Kapazi employees may offer gifts and presents to suppliers and service providers only with the approval of their immediate superior and in accordance with company practices;

e) Representatives from areas such as Sales or Marketing, with the objective of maintaining good commercial relations, may offer gifts to clients and suppliers always in accordance with the current policy and practice for this purpose.

5.3 Corruption: Kapazi does not tolerate any form of corruption, nor does it accept the offer of undue advantages, whether for the benefit of the employee or the company.

6. Relationships with the Public Sector

6.1 Use of Kapazi's Name:

a) Kapazi values integrity and honesty in its relationship with public bodies. When defending the company's interests, employees must always observe ethical principles and respect current norms and laws.

b) Employees are prohibited from addressing and discussing issues related to partisan or governmental politics on behalf of Kapazi and its suppliers or service providers.

c) Employees must not involve the company's name in personal matters of any nature in their relationship with public bodies.

d) All contact with public bodies, except those related to participation in public tenders, must be communicated to the Board of Directors.

6.1.1 Request for Information: All information sent to public bodies must be submitted in writing, containing complete, truthful, and accurate information, in a timely manner, always observing the confidentiality policy and existing laws. All information provided to a public body must be formally registered.

6.1.2 Gifts and Presents: Kapazi employees may not offer courtesies, presents, or gifts to public sector employees. Furthermore, Kapazi does not allow improper payments in order to obtain advantages or expedite administrative actions. Representatives of the commercial area, with the objective of maintaining good commercial relations, may offer gifts to clients always in accordance with the current policy and practice for this purpose.

6.1.3 Contributions to Political Parties: Kapazi encourages its employees to practice citizenship through voting, seeking rights, among other means, but employees may not use company resources for political activities.

7. Relationships with the Press

7.1 The department responsible for relationships with the press is Institutional Marketing:

a) Contacts with the press will only be promoted by authorized employees. No employee may disclose any information about the company, clients, suppliers, or service providers, without authorization from the Institutional Marketing department, which is responsible for reviewing and, if necessary, mediating the relationship between employees and the general media.

b) In case of identification of incorrect or negative information being disseminated about Kapazi and its products, it is the employee's duty to pass on the information to their immediate superior or to the Institutional Marketing department.

8. Intellectual Property and Privileged Information

8.1 It is the duty of all employees to protect the intellectual property and confidential information of the company where they work, recognizing the following obligations and norms:

a) Protecting the company's intellectual property, including technology, know-how, trademarks, patents, industrial processes, etc., is the duty of all Kapazi employees.

b) Any and all intellectual property developed by company employees, resulting from the nature of the employment contract, the use of resources and equipment, or on company premises, will be attributed to Kapazi, being its property.

c) The use of confidential or privileged information of Kapazi for one's own benefit or for the benefit of third parties is prohibited. Any company member who possesses relevant and undisclosed information to the public is not authorized to disclose such information to third parties.

d) The confidentiality of privileged information and intellectual property must be maintained even after the termination of the employment contract.

e) The disclosure of personal records is not permitted, unless authorized or required by law, regulation, or court order. The interception of emails and telephone conversations carried out by employees regarding other employees or company executives constitutes a serious ethical violation liable to criminal action.

9. Use of Communication Devices

9.1 a) Kapazi may assign computers and email addresses to employees, as well as any other communication devices for the performance of their work. Such devices must be used exclusively for their intended purpose, unless expressly authorized by their immediate superior.

b) All information contained in the communication devices assigned to employees is the property of Kapazi and may, subject to company guidelines, be accessed at any time.

10. Accounting, Financial, and Contract Records

10.1 Contract Registration: All contracts in which Kapazi participates must be written precisely and adequately, not allowing for double interpretations. The Administrative/Legal department designated by the company must analyze and authorize all issued contracts, safeguarding the rights and duties provided for in the document.

11. Health, Safety, and Environment

11.1 Responsibility for Compliance with Norms and Policies:

a) Kapazi periodically conducts training related to health, safety, and the environment, so that everyone understands work routines and can act responsibly and safely.

b) All employees must be aware of and strictly comply with health, safety, and environmental norms and policies, as well as communicate to their immediate superior whenever they observe any event that could threaten the physical or moral integrity of employees.

11.2 Sustainability and Environment: Sustainability has always been present in Kapazi's operations, whether in conducting business transparently, ethically, and responsibly, in valuing its employees, or in innovating for the development of solutions.

a) Kapazi does not tolerate practices that could lead to potential environmental violations or that are not in line with the company's commitment to sustainable development.

11.3 Safety: The health and physical integrity of employees are priorities for Kapazi.

a) The company operates in all its businesses in accordance with applicable health and safety at work laws, seeking to provide an increasingly safe working environment.

b) Potential emergencies and their proportions are recognized and evaluated, and procedures are adopted to reduce or eliminate potential risks.

c) Kapazi analyzes and investigates incidents and accidents, documents results, and the procedures adopted for health and safety protection.

d) Minors under 14 years of age are not allowed to enter or remain on Kapazi premises.

11.4 Health and Quality of Life: Kapazi believes that a healthy work environment begins with the health and quality of life of its employees. Therefore, it acts transparently, providing:

a) healthy food: with its own cafeteria, where food is balanced under the supervision of a nutritionist;

b) use of personal protective equipment (PPE): the company provides PPE for all industrial employees, and its use is mandatory in manufacturing facilities, aiming for a better quality of life in the workplace.

12. Fair and Ethical Competition

12.1 a) To surpass the competition through innovative and quality products and services, Kapazi constantly invests in new technologies;

b) The company respects its competitors and does not accept any kind of manifestation that might harm their image in the market.

13. Responsibilities

All company employees must comply with the provisions of the Code of Ethics and Conduct while performing their duties, being accountable for their actions and demonstrating integrity consistent with Kapazi's values and ethical principles. Any employee who acts contrary to the provisions of the Code or withholds information during an eventual investigation may be subject to applicable disciplinary measures.

14. Violation of the Code of Ethics and Conduct

Infractions to this Code will be subject to disciplinary measures or penalties based on applicable legislation. Each employee must formally notify their immediate supervisor whenever they become aware of a possible violation of the terms of this Code. 

Repeated non-compliance with the provisions of this Code may lead to the progressive application of penalties, considering the severity of the infraction and current legislation, in the following order:

1) Conduct Adjustment Term (TAC) with recorded verbal warning;

2) written warning;

3) second written warning;

4) suspension; and

5) dismissal for just cause.

15. When in doubt, what to do?

If an employee is unsure about a particular type of conduct, they should ask themselves:

a) Does this align with the Company's Code of Ethics and Conduct?

b) Is this ethical?

c) Is this act legal?

d) Is this conduct impartial and honest?

e) Would I like to read about this in the newspaper?

f) Would I advise my children to act this way? Employees should not refrain from addressing these situations of doubt. If the answer is "No" to any of the questions, the conduct should not be adopted.

Almirante Tamandaré, October 29, 2025

KAPAZI Indústria e Comércio de Capachos Ltda.

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