Code of Ethics and Conduct

Last updated: August 2026 1. Purpose This Code is a reference guide for FCX's partners, permanent and temporary employees, interns, suppliers and service providers, guiding their routines and their day-to-day relationships. It orients professional conduct through respect for the ethical and moral values that make up the mission, vision and values present in every relationship FCX takes part in. 2. Who it applies to It applies to partners, employees, temporary staff and interns. Companies and individuals that maintain business and service relationships with FCX are also bound to comply with the rules of this Code. 3. Policies and practices 3.1 Working environment FCX expects its employees to act cooperatively, with the aim of keeping the environment pleasant and harmonious. It is everyone's commitment to: cooperate towards good relationships between colleagues, customers and partners; respect human rights and differences, avoiding comments and actions of a prejudiced nature; care for the integrity of work equipment; act diligently, seeking the best interest of the institution and its customers; not conceal failures nor use false information to mislead third parties; and not speak on behalf of the company without prior authorization. 3.2 Conflict of interest In carrying out their activities, employees must always act in the best interest of the institution, preventing personal interests from influencing decisions or conduct. The following are prohibited, among others: obtaining personal advantage by reason of one's position; allowing personal relationships to interfere with decisions; using FCX resources (facilities, equipment, e-mail, software) for personal benefit; and sharing FCX confidential information in external activities. In case of doubt, contact the Ethics Channel. 3.3 Relationship with customers FCX acts in the customer's best interest, in compliance with applicable legislation. The platform delivers commercial intelligence supporting prioritization and approach, strictly informative in nature. ATTO's recommendations are a decision-support instrument and do not constitute legal, financial, accounting, credit or compliance advice; the decision to adopt, adapt or discard each recommendation belongs to the customer. Where the chain of evidence is insufficient, the guidance is to lower the confidence level, formulate a hypothesis or request validation — never to present a hypothesis as fact. The customer relationship must be conducted with respect, ethics, transparency and impartiality, free from prejudice of any kind. 3.4 Secrecy and confidentiality All confidential information to which an employee has access must be kept secret and may not be shared with third parties. Data and information of customers, employees, suppliers and providers held by FCX is treated confidentially and in compliance with Brazilian Law No. 13,709/2018 (LGPD). The data of each account or organization is isolated from the others. All employees are responsible for protecting the institution's confidential information. 3.5 Information security It is everyone's responsibility to protect the information recorded in the course of the company's activities and to minimize the risk of leaks by physical or digital means: not leaving workstations unlocked; keeping a "clean desk" policy; protecting equipment with a password; not clicking links in suspicious e-mails; and not sharing access credentials. In case of doubt about information exposure, consult your immediate manager. 3.6 Prevention of fraud, bribery and corruption Everyone must uphold ethics and integrity in their activities and relationships. FCX does not admit, under any circumstances, practices that are or appear to be kickbacks, bribery, corruption or fraud, and rejects business relationships that encourage the offering of undue benefits (see the Anti-Corruption and Fraud Policy). 3.7 Anti-money laundering FCX condemns the practice of money laundering. If misuse of its services is suspected, everyone must immediately notify the Ethics Channel so that the appropriate measures can be taken, including reporting to the competent authorities (see the Anti-Money Laundering Policy). 4. Ethics and Whistleblowing Channel Reports of transgressions of this Code must be sent to denuncias@fcxsolutions.com.br. Full secrecy and confidentiality are assured. Reporting violations is a duty of all employees, officers, contractors and partners of FCX. 5. Disclosure This Code is published publicly on FCX's official website, as a way of guaranteeing transparency about the standard of conduct required. 6. Final provision This Code enters into force upon approval by the Board, revoking previous rules on the matter, and will be reviewed annually or sooner if necessary. Approved by the FCX Board.