Code of Ethics and ESG

ABC Group ensures its clients strict confidentiality.

Employees must keep client related financial, commercial and personal subjects secret and protected from third parties access, unless:

• the client has given prior written consent for the disclosure;
• disclosure is required by a court order or competent authority;
• disclosure is required by law;
• disclosure is necessary to protect the assets of ABC Group, such as disclosure to the police in case of suspected fraud (this case is subject to the Executive Board’s instructions).

In the aforementioned cases, the confidential information shall never be released without the Executive Board’s prior authorization.

Information related to negotiations and systems of the Bank, its subsidiaries and associated companies, must be kept under strict confidentiality.

All care shall be taken in respect of what is said and with whom you speak, write or communicate electronically and you must protect information related to the activities of ABC Group, limiting the access to any confidential or secret document, which shall be carefully stored in the Bank’s facilities.

Such confidentially commitment is undertaken not only during your employment with the Bank, and will remain in force on a permanent basis after employment termination.

All employment agreements are made in writing and incorporate a Non-Disclosure Agreement applicable to all business matters related to ABC Group and its clients.

All employees are under obligation to avoid conflicts between their personal interests and the interests of ABC Group or its clients and must not promote / disclose any commercial relations or existing interests that may have potential conflict or commitment.

You must not get involved in any operation, negotiation or agreement representing ABC Group before a client or any entity in which you or a relative of yours have a direct or indirect interest, or which is under conditions to compete with ABC Group, unless you have:

a) made a full statement of facts in writing;

b) obtained written authorization from the head of your Department, as well as from the Executive Board of the Company.

Except the permissions set forth in your employment agreement with ABC Group, you must nor participate or engage in any other commercial enterprise.

You must decline secondary jobs, invitation to provide advisory or to be a Director or partner, except as permitted by your employment agreement or expressly approved in writing by the Vice Presidency and Human Resources.

A conflict of interest may occur between an operating unit and its client or between clients or prospective clients. In this case, there must be greater concern to ensure equal treatment for the involved parties. Guidance may be obtained from your manager or Human Resources.

Guidance or authorization to Heads of Department will be given by the immediate superior or by the Executive Board or by Human Resources.

Transactions of private nature in any securities/investment carried out by ABC Group’s employees are subject to specific rules that must be permanently and strictly observed.

All members of the staff, including recently engaged employees receive a copy of this Policy at the start of their activities.

Certain restrictions apply, particularly in case you have inside information.

In no circumstances it is permitted to obtain personal benefits resulting from access to confidential information.

You may not trade securities based on inside information. This implies not to trade, not to offer instructions, neither cause any person to trade listed stocks or securities in case you have information you believe that is not publicly known and which may affect the prices of those securities or the companies involved.

This applies irrespective of the source or how this information was obtained, and includes:

a) purchase and sale for yourself, your relatives, friends and third parties;

b) advisory or information to third parties to sell or buy.

Note: information with price implications is defined as information that could affect the price of securities if it was publicly known.

Examples:

• Stake control or amalgamation proposals;
• Potential insolvency;
• Changes in management;
• New product or discovery.

It is your obligation to report any infringement to the law, requirements of regulatory bodies or this Policy to the Compliance Reporting Channel (4020.ORG).

If you have reasons to believe that those requirements are about to be infringed, such reasons must also be reported.

Non-compliance with this Policy or failure to report known infringement by a third party may result in application disciplinary measures and depending on the nature of the infringement, may lead to:

1. Written warning;

2. Suspension

3. Dismissal for cause

The banking activities are based on existing mutual confidence and on the general public confidence. Therefore, it is essential that every employee of Banco ABC BRASIL S.A. (referred to as the “Bank”) and its affiliates (ABC Group) behave in compliance with the highest and appropriate standards of conduct.

This set of Rules of Conduct describes the expected basic standards needed in our behavior both inside and outside the Bank.

Each member of ABC Group’s staff must receive a copy of this Policy and each employee, within his/her area of responsibility, is required to ensure its compliance so that the values and integrity of ABC Group are maintained.

The Policy must be read together with the Employees’ Internal Regulations, their employment agreement and all and any laws applicable to each operational unit.

In case local laws or standards determine rules of conduct stricter than those set forth herein, such local laws or rules must be observed and given priority.

Thus, stricter local laws or standards shall prevail wherever not conflicting with this Policy.

Clients expect that ABC Group demonstrates a high standard of legality and ethical values. Each employee undertakes the obligation to comply with either expressed content or implied spirit of this Policy and legal requirements.

As an employee or officer of ABC Group, you must guide yourself by the principles set forth in this Policy.

In case any officer or employee has any questions about the concepts and criteria set forth herein, he/she must seek advice from his/her immediate superior, who will consult the Human Resources Department, if necessary.

You may not ask or accept for yourself or for a relative of yours, neither offer to a client or prospective client, a party to a negotiation, supplier or contractor of any company of ABC Group, any favor, gift, service, entertainment or other benefit which value or frequency exceeds normal business relationship, namely cash or easy liquidity gifts.

You must not receive anything that may influence (or that other parties believe may influence) your independent and commercial judgment, the reputation of ABC Group or the compliance with your obligations.

Normal mutual business entertainment or acceptance of gifts with monetary value below or equivalent to US$ 100.00 (one hundred North-American dollars) (frequently with promotional or public relations purposes or by occasion of traditional celebrations) are permitted, however, in case of doubt, contact the Head of your Department for guidance.

In case of unsolicited gift or benefit which violates this Policy and which you believe a return may cause a harmful effect on a commercial relationship, request written guidance to the Head of your Department, to the Vice President or to Human Resources.

Guidance or approval to Heads of Department must be obtained from their immediate superiors, the Vice President and Human Resources.

All of us must demonstrate a high standard of professional integrity in our work.

Integrity implies that we fully deserve the confidence placed in us by our clients and employers and this is achieved when we are honest and impartial.

This means that:

• we must always act honestly in our professional or personal affairs, so that neither one of our actions cause or may cause damage to the Bank’s reputation;
• we must comply with the laws and regulations of all countries where we operate;
• we must abstain from illegal, fraudulent or unethical behavior, mainly in relation to financial and/or commercial business, as well as in respect of laws and standards applicable to us;
• we must not engage in activities that may in any way be related to or which supposedly collude with illegal or criminal activities, both inside and outside the Bank;
• we must keep the Bank’s files and systems in such a way that all operations are promptly and accurately recorded. Do not falsify records or make them unclear. Do not omit facts or inaccurately represent them in records or communications;
• we must give good example in managing our private business, avoiding behaviors that can make us vulnerable to financial difficulties or which may lead us to improper behaviors, such as gambling;
• in the Bank, we must promote a policy of equal treatment of workmates without favoritism or harassment.

ABC Group is committed to the obligation of identifying money laundering transactions and requires all of its employees to comply with the detailed provided instructions. It is essential that all employees are familiar with these instructions, as well as with the additional obligations imposed by local applicable laws.

Further information may be obtained in the Anti-Money Laundering Policy.

We must be fully open and honest and cooperate and promptly respond to regulatory agents and internal or external auditors, keeping them fully informed of whatever may be deemed reasonable.

It is essential we demonstrate and strictly comply with the applicable laws and requirements from regulatory bodies and that Banco ABC Brasil is seen as a professionally managed enterprise.

The purpose of this policy is to establish and disclose the desired personal and professional ethics, as well as the behavioral parameters that must guide the conduct of associates and employees.