Anti-Money Laundering

Last updated: August 2026 Scope FCX Solutions Inteligência de Negócios Ltda. is a commercial intelligence technology company — it is not a financial institution and is not regulated by the Central Bank of Brazil, and it does not process customer financial transactions on its platform. This is a voluntary corporate integrity policy: it sets out FCX's commitment and controls, as a company, against money laundering and terrorist financing in its own commercial relationships (receipts, payments to suppliers and engagements). 1. Purpose To establish guidelines, orientation and procedures for the prevention, detection and combating of money laundering, terrorist financing and other practices that conceal funds of unlawful origin. 2. Scope of application All partners, officers, employees at any level, service providers, suppliers and business partners. 3. Definitions (a) Terrorist financing: financial support, by any means, to acts, perpetrators or promoters of terrorism, whether from lawful or criminal sources. (b) Politically Exposed Person (PEP): anyone who, in the last 5 years, has held relevant public office, employment or functions in Brazil or abroad, as well as their family members and close associates. (c) Money laundering: a set of operations that seek to introduce funds of unlawful origin into the economy, typically in three stages (placement, layering and integration). 4. Guidelines 4.1 Commitment. FCX repudiates any act of money laundering or criminal activity involving the simulation or concealment of funds. 4.2 Assessment of services. FCX permanently assesses its commercial intelligence services from the perspective of the risk of misuse for terrorist financing or money laundering, adopting appropriate mitigation measures, in line with the legislation and considering customer, geographic and new-technology risk profiles. 4.3 Monitoring. It maintains processes to detect atypical and/or suspicious situations that may indicate such practices, reporting them to the competent authorities where applicable. 4.4 Culture of prevention. It permanently disseminates knowledge and a culture of prevention and combating among employees and officers. 4.5 Due diligence ("Know Your Customer/Partner/Employee"). It adopts KYC/KYP/KYE procedures to mitigate risks, according to the activity, the jurisdiction and the parties involved, which may involve collecting, validating and updating registration information. 4.6 Transaction records. FCX keeps records of its own financial and commercial transactions (receipts from customers, processed by its payment provider, and payments to suppliers) for the applicable legal period, so as to comply with the legislation in force. 4.7 Politically Exposed Persons (PEP). It adopts procedures to identify customers, partners and providers who may qualify as PEPs, assessing whether to maintain the relationship and what mitigation measures are necessary. 4.8 Suspicious activity. On detecting evidence of money laundering, it investigates the situation confidentially and reports voluntarily to the competent authorities — including COAF (the Brazilian Financial Intelligence Unit), the channel for reporting suspicious operations — cooperating with investigations where applicable. 5. Responsibilities Compliance with this Policy is the responsibility of all partners, officers, employees, providers, suppliers and partners. Adherence by employees is mandatory and formalized through a term of commitment. 6. Control and monitoring Periodic internal investigations are carried out to verify compliance with the rules, in addition to training. Any irregularity identified is taken to the Compliance Area for the appropriate measures. 7. Reporting suspicious situations Everyone must report suspicious situations to their leaders or directly to the Compliance Area, with confidentiality assured. 8. Reporting channel Situations potentially at odds with this Policy must be recorded and reported to the Compliance Area at antifraude@fcxsolutions.com.br. 9. Legal basis Brazilian Law No. 9,613/1998 (Anti-Money Laundering Law); Brazilian Law No. 12,846/2013 (Anti-Corruption Law); FCX's Code of Ethics and Conduct and Anti-Corruption and Fraud Policy. 10. General provisions This Policy is reviewed at least annually, approved by the Board, and is available on FCX's official website.