Anti-Corruption and Fraud

Last updated: August 2026 1. Purpose To reinforce FCX's commitment to ethics and integrity in business, establishing guidelines for the prevention of and fight against corruption, bribery and fraud. 2. Scope All partners, officers, employees at any level, service providers, suppliers and business partners. 3. Definitions (a) Public Administration: bodies, services and entities of the direct or indirect administration and their agents, at federal, state and municipal level and across the Legislative, Judicial and Executive branches. (b) Public Agent: anyone who performs a public function, even temporarily or without remuneration. (c) Foreign Public Agent: anyone who performs a public function in a foreign country or in its entities and representations. (d) Harmful Act: an act or omission that damages public assets or contravenes the principles of Public Administration. (e) Conflict of Interest: where personal interests influence decisions to the detriment of FCX's interests. (f) Undue Advantage: any benefit, economic or otherwise. (g) Corruption: offering something to a public or private party in order to obtain an undue advantage. (h) Bribery or kickback: promising, offering or paying an amount or advantage in order to commit corruption. (i) Fraud: a deceitful, misleading or bad-faith act intended to harm another party. 4. Guidelines FCX neither tolerates nor endorses practices of corruption, bribery or fraud, whether with the Public or Private Administration, domestic or foreign. 4.1 Anti-Corruption Law: repudiation of harmful acts under Brazilian Law No. 12,846/2013. 4.2 Contact with public authorities: in accordance with the internal rules governing the relationship with the Public Administration. 4.3 Political contributions: FCX does not contribute, directly or indirectly, to campaigns, parties, candidates or party-political organizations. 4.4 Suppliers, partners and third parties: they must act with ethics and integrity; their engagement is preceded by an analysis of qualification and reputation (red flags), with a decision by the Compliance Area or the officers. 4.5 Gifts, presents and hospitality: it is prohibited to offer or accept them with the aim of influencing decisions or obtaining a benefit. 4.6 Conflict of interest: everyone must act in the best interest of the institution, avoiding the influence of personal interests. 4.7 Corporate restructuring: in mergers, acquisitions and incorporations, due diligence is carried out and an anti-corruption clause is included in the contracts. 4.8 Anti-money laundering: any evidence or suspicion must be reported immediately to the Compliance Area (see the Anti-Money Laundering Policy). 4.9 Disclosure: the Policy is made known to everyone, with a term of adherence, and is available on FCX's official website. 4.10 Continuous improvement: permanent monitoring of internal procedures. 5. Internal investigations Periodic investigations verify compliance with the rules; irregularities are taken to the Compliance Area and may result in a report to the authorities or in internal sanctions (warning, suspension, dismissal, termination of contract). 6. Reporting suspicious situations and red flags Everyone must report situations suspected of fraud, bribery or corruption, with confidentiality assured. Examples of red flags include: a counterparty with a poor reputation regarding bribery; remuneration inconsistent with the services rendered; payments in cash or to manually altered payees; a counterparty controlled by or nominated by a Public Agent; requests for payment into atypical accounts or countries; donations requested by a Public Agent; and access to suspicious files or websites. Red flags are not proof of corruption, but they must be investigated. 7. Responsibility Compliance with this Policy is mandatory for everyone, with adherence formalized through a term of commitment. 8. Reporting channel Situations potentially at odds with this Policy must be recorded and reported to the Compliance Area at antifraude@fcxsolutions.com.br.