MESSAGE FROM THE BOARD OF DIRECTORS

Since its founding in 2017, 4kst has undergone rapid transformations. If the world was already dynamic at that time, the last few years have shown us that the ability to adapt is essential to continuing our journey.

The pandemic has not only changed where we work, but how we connect. The consolidation of remote work has challenged us to build a new model of trust, where collaboration, autonomy, and responsibility must go hand in hand. We have learned that 4kst's culture should not be limited to the walls of our headquarters, but should permeate the actions of each of our employees, wherever they may be.

In recent years, 4kst has experienced the arrival of a new generation of employees. A hyperconnected generation that brings a fresh and questioning perspective, perfect for our evolution as a company that must be fully integrated into the new social context.

That is why we have reissued our Code of Conduct, which in its third version will continue to be our compass. It reflects 4kst's commitment to ethics, respect, and the protection of its employees as a priority.

We invite everyone to read this third version of the 4kst Code of Conduct, so that you can use it as a guide to ensure an environment of integrity, safety, psychological health, and significant professional development for all.

Thank you,

 

Fabricio Enembreck | Riccardo Lanzuolo

 

GENERAL GUIDELINES

This Code of Conduct presents the most relevant values and rules adopted by 4kst Tecnologia da Informação S.A. (hereinafter referred to as "4kst" or "Company") for the development of its activities. The content of this material guides the personal and professional conduct of all those who work in or for the 4kst team, whether they are shareholders, directors, employees, interns, investors, partners, or service providers (hereinafter referred to as "Employee" or "Employees").

The guidelines of this Code permeate the entire Company and must be reflected in all of 4kst's internal rules, which must also be strictly observed by all 4kst Employees.

I. OBEDIENCE TO THE LAW

4kst does not authorize any of its Employees to violate or promote the violation of any applicable laws or regulations, wherever they conduct their activities, even if it is for the alleged benefit of the Company or its customers. 4kst is committed to fully complying with the requirements of public authorities and complying with any and all court orders.

II. WORKING CONDITIONS

4kst combats any type of work that violates current legislation and is committed to ensuring:

• Working conditions that are appropriate for the safety and health, including mental health, of its Employees;
• No use of child labor;
• The non-use of forced labor; and
• The rejection of any form of slave labor or labor analogous to slavery.

This commitment also covers any contracts that 4kst may enter into involving its chain of service providers and suppliers.

II.1. Diversity

4kst believes that a diverse work environment, where professionals from different ethnic backgrounds, religious beliefs, age groups, genders, and sexual orientations collaborate, contributes to greater creativity, innovation, and evolution of the Company and everyone involved. In this sense, 4kst demands that respect for differences be a virtue to be cultivated and that the promotion of diversity always be on the agenda for the human development of its team.

Adapting to the different needs of its Employees is also a commitment of the Company and its leadership. The different ways of processing information and social interactions must be respected and valued. In addition, the needs of Employees with disabilities must be on the Company's agenda in order to guarantee them full accessibility, both physical and digital.

II.2. Parenting

4kst also recognizes that parenting requires a harmonious balance between professional and family life. Therefore, we promote a culture of flexibility and support, ensuring that our employees have the necessary conditions to fully and safely perform their family roles, without prejudice to their development within the company.

II.3. Psychological Safety

The Company is committed to ensuring that its Employees feel safe to recognize learning needs, admit mistakes, and even question the status quo, free from judgment or retaliation.

III. PERSONAL CONDUCT

4kst employees embody the Company in their professional and public conduct. It is everyone's duty to know and respect the following rules of conduct:

• Reject any form of discrimination;
• Reject any type of harassment, whether moral or sexual;
• Reject any type of violence, whether physical, written, or verbal;
• Protect the image of 4kst by refraining from behavior that could tarnish the reputation of the Company, its professionals, or its clients;
• Exercise caution and common sense in public statements, including on social media;
• Not to engage in or promote any type of criminal or illegal activity;
• Not to use your position as a 4kst Employee, or information about the Company or its customers to which you have access, for personal gain or for the gain of third parties;
• Protect, without restriction, all information belonging to 4kst, its Employees, its customers, and individuals related to them, from disclosure to unauthorized third parties; and
• Respect and protect all Intellectual Property, as well as reject plagiarism or unauthorized use of third-party materials.

III.1. Communication

Observe the use of respectful language appropriate to the work environment in all interactions with colleagues and third parties, whether in person or via digital tools (online meetings ,, emails, messaging apps, etc.).

III.2. Psychoactive Substances

The consumption of alcoholic beverages or illegal drugs during working hours is prohibited, regardless of the work arrangement (in-person or remote). It is also prohibited to perform your activities under the influence of such substances.

Alcohol abuse and illicit drug use can severely impact an individual's physical health, mental clarity, and personal and professional relationships. In this regard, 4kst encourages moderation in the consumption of alcoholic beverages and advises abstinence from illicit substances.

III.3. Personal Introduction

The Employee's personal presentation should reflect respect for their interlocutors, the importance of the work they do at 4kst, and the care they take in everything they do. It is essential to emphasize that such diligence must be maintained in remote interactions and digital environments, ensuring that the professional image is preserved in any communication channel.

III.4. 4kst Identity

No 4kst Employee may use 4kst's visual identity, name, or brand without the Company's express prior authorization. The Marketing department is responsible for guiding all Employees on the guidelines for using the 4kst Identity.

IV. CONFLICTS OF INTEREST

Conflicts of interest arise throughout the development of an individual's professional relationships and occur when personal interests, corporate interests, and the interests of customers, partners, or suppliers diverge.

4kst is attentive to preventing conflicts of interest involving the Company and/or its Employees from arising and, in this regard, provides non-exhaustive guidance to each Employee to observe conflicting situations that may arise:

• Participation in associations that adopt guidelines, ideologies, or values that differ from those adopted by 4kst or that promote the defense of issues contrary to the understanding of the Company or its customers;

• Shareholding or development of external professional activities, even on a voluntary collaborative basis, that constitute competition with the activities of 4kst or any client under its care or about which it holds relevant internal information, or that in any way conflict with the activities performed at or for 4kst;
• Public office, whether temporary or permanent, that may interfere or appear to interfere with matters of interest to 4kst or its clients;
• Political party activities;
• Kinship, or close relationship by affinity, with an administrator, controller, or employee in a relevant position at a company competing with 4kst;
• Kinship, or close relationship by affinity, with another 4kst Employee;
• Kinship, or close relationship by affinity, with Authority (individual invested with public office, temporarily or permanently, remunerated or not, who has decision-making power in matters of interest to 4kst or its clients); or
• Kinship or close relationship by affinity with a customer, partner, or supplier of 4kst.

No 4kst Employee may conduct negotiations on behalf of Company     Company if there is any personal financial interest or the appearance of a personal financial interest, whether with suppliers, competing companies, or Authorities. In the commercial sphere, the Employee's financial interest must be strictly limited to the variable remuneration and bonus model established by the company. Under no circumstances may the pursuit of commercial results override ethics or the real benefit to the customer.

4kst requires that all Employees who identify any situation that may constitute or appear to constitute a Conflict of Interest formally report it to the Reporting and Communication Channel – 4kst.

IV.1. Political Participation

4kst supports and encourages the political participation of its Employees as a way of improving public management through civil society participation. However, in order to avoid any Conflict of Interest, each Employee is required to inform the Company whenever:

• join a political party;
• provide services to political campaigns;
• run for public office;
• run for office in a professional association or union;
• receive an offer of public office; or
• pass a public competitive examination.

V. WORK TOOLS

All tools provided by the Company, such as computers, software, corporate emails, and network access, are provided to its Employees exclusively for professional purposes. In this regard, everyone should be aware that their activities using such tools are subject to monitoring by 4kst, and that all access logs and monitoring reports constitute electronic evidence that may be used for internal investigations and even to support other investigations or inquiries conducted by public authorities.

V.1. No Expectation of Privacy

The 4kst Employee should not have any expectation of privacy when using any of the Company's technological resources.

V.2. Monitoring

Especially for monitoring remote activity, 4kst reserves the right to use monitoring mechanisms. This may include, but is not limited to, recording login/logout times. logins/logouts, monitoring network traffic, analyzing productivity through software  and auditing access to sensitive data. The purpose of such monitoring is to validate compliance with internal policies, ensure the development of projects, and guarantee the protection of internal information under the Company's control.

V.3. Equipment Protection

All Employees who use portable equipment at work must take continuous measures to prevent its loss, theft, or misplacement. It is the responsibility of each Employee, at the end of their daily work shift, to keep the laptop computer provided by the Company in their personal custody.

VI. CONFIDENTIALITY

VI.1. 4Kst technology

4kst's proprietary technology is its trade secret, an essential asset for the continuity and development of the Company, and therefore it must be subject to continuous protection.

Some 4kst Employees may have access to your trade secrets due to the activities they perform for 4kst. In this case, the Employee must be aware of their commitment not to disclose any sensitive information involving 4kst Technology, as well as make every effort to prevent access to it by unauthorized persons, who may even be other 4kst Employees.

VI.2. Internal Information 4kst

Internal information belonging to 4kst may only be disclosed by its management, or by anyone expressly designated by it for that purpose. Without limitation, Internal Information belonging to 4kst is considered to be that related to:

• Development of products and services;
• Source codes for programs or pipelines;
• Technical and commercial research;
• Partnerships and investments;
• Commercial conditions, plans, and/or projections;
• 4kst customer data;
• Results, profits, and other financial and sales data, including projections;
• Results of experiments involving or not involving customers;
• Contractual terms with suppliers; and
• Employee Data 4kst.

VI.3. Use of Inside Information (Insider Trading)

All 4kst Employees are prohibited from conducting any business or advising family members and/or third parties to conduct any business using Inside Information to obtain an advantage. Insider information is considered to be any and all material, relevant, and non-public information about 4kst, its customers, its partners, or its suppliers, obtained by any Employee as a result of their work at/for the Company, which could be used to gain a financial advantage.

4kst also requires its Employees to fully comply with all local and international laws governing insider trading. Insider Trading in the Securities Market. Reinforcing not to corroborate with the misuse of Inside Information.

VI.4. Third-Party Information

In all its relationships with third parties, 4kst receives confidential information for a variety of reasons. Confidentiality agreements are often entered into, even before the relationship begins, whether with a future partner, customer, investor, or supplier.

Under no circumstances may any 4kst Employee disclose confidential and non-public information about third parties with whom the Company has a relationship or is in negotiations to do so, even when such information has not been obtained from 4kst and/or as a result of the activity performed at 4kst.

It is also essential that 4kst Employees comply with the security and privacy rules of 4kst customers and partners, strictly observing all required internal procedures. It should be noted that it is prohibited to take and publish photographs of people, structures, and materials in third-party environments with which 4kst has a relationship, unless prior and express authorization has been obtained from them.

VI.5. Personal Data Protection

4kst is committed to fully complying with all local and international legal requirements related to personal data protection, especially Law 13.708/2018 (General Personal Data Protection Law). The right to privacy and protection of citizens' data involves the need for robust and transparent processes for the collection, storage, processing, and sharing of personal data.

It is 4kst's premise that all data-driven technological development requires legal certainty, and this will be the condition required in all of the Company's relationships with its customers, partners, and suppliers.

4kst will only accept the processing of personal data that has been obtained lawfully, for legitimate, non-abusive purposes, and with the knowledge of its owners (natural persons to whom the data refers).

VI.5.1. Internal Personal Data

4kst may retain personal data of shareholders, employees, interns, investors, partners, and service providers for the purpose of complying with all legal requirements involving such relationships. In addition to registration information, information related to employment, salaries, benefits, banking information, and occupational health issues may also be processed.

Because this is sensitive data, 4kst is committed to adopting robust procedures for the security of such data, ensuring limited access to it (only to professionals who need it to conduct their activities responsibly), and retaining only that which deals with mandatory information and within the time limits determined by law.

VI.5.2. Personal Data of Suppliers and Partners

Every due diligence process due diligence to be performed prior to contracting with suppliers and partners may require 4kst to access the personal data of individuals related to them, such as partners and administrators. The Company is committed to protecting such data and only retaining it during the evaluation period, disposing of it securely and anonymously, also in accordance with the aforementioned legal provisions.

VII. INTEGRITY

The highest standards of integrity in all relationships underpin 4kst's operations and reinforce the Company's commitment to conducting business based on ethics and good practices, always aiming to achieve the best results for society.

VII.1. Anti-corruption

4kst fully complies with all local and international legal requirements related to corruption prevention, especially Law 12.846/2013 (Brazilian Anti-Corruption Law), the FCPA (US Foreign Corrupt Practices Act), and the UK Anti-Bribery Act.

4kst prohibits any of its Employees from engaging in or allowing, through omission, any act that could enable corruption at any level, whether through bribery, kickbacks, extortion, or influence peddling, either directly or indirectly, in both the public and private spheres.

VII.2. Offering and Receiving Benefits

4kst adopts rules related to the offering and receiving of Benefits by its Employees, falling under the definition of Benefit:

• Gift: an item with no commercial value offered by an organization to promote its name, products, or services;
• Gift: object or service with commercial value;
• Hospitality: involves meals, lodging, and transportation; and
• Entertainment: corporate events (celebratory parties, conferences, courses, etc.), tickets (technical/professional, cultural, festive, sporting events, etc.).

The basis of the rules regarding the offer and receipt of Benefits is based not only on the need to prevent any taint in the impartiality of decisions made or to be made by those who receive them, but also on the appearance of any Conflict of Interest.

The offering of gifts to individuals working in the public sector is authorized by 4kst, provided that the code of ethics or internal regulations governing the matter within the agency to which the individual is linked are observed. No 4kst employee is authorized to give gifts, hospitality, and/or entertainment to any representative of the public sector, even if paying for such gifts personally.

The offer of benefits to individuals representing the private sector must always be reasonable, so as not to influence the recipient to make a decision favorable to 4kst, to not appear to be a reward for a decision made, or to appear to be a potential conflict of interest.

4kst employees may only accept gifts offered by third parties if they are suppliers, partners, or customers of the Company.

VII.3. Relationship with Authorities

All relationships with Authorities (individuals invested with public office, whether temporary or permanent, remunerated or not, who have decision-making power in matters of interest to 4kst or its clients) must be based on total transparency and full compliance with the relevant laws and internal rules of the body to which the Authority is linked.

To this end, it is essential that all 4kst Employees seek to familiarize themselves in advance with the rules governing this type of relationship and adopt mechanisms for formalizing such contacts, such as: (i) public scheduling; (ii) preparation of an agenda; and (iii) formalization of negotiations in minutes.

VII.4. Donations

4KST does not make and does not authorize any Employee to make, on its behalf, donations to political campaigns for public office, professional associations, or unions. This prohibition applies to donations of monetary value, goods, rights of use, or services.

4kst may make donations to charitable institutions or non-profit organizations, provided that such donations are completely unrelated to any consideration in favor of 4kst, either directly or indirectly.

VII.5. Sponsorship

4kst may use the sponsorship model to promote its brand and services; however, its name will only be associated with entities and events that share values consistent with those of 4kst.

All sponsorship by 4kst must be formalized through a contractual instrument that details the terms of the agreement.

VII.6. Protection of Free Competition

4kst is committed to defending free competition as a way of ensuring a fair market and greater economic development. Therefore, its relations with competitors observe ethical competitive practices and fully comply with Brazilian legislation on the defense of free competition, as well as other antitrust legislation in other countries where it conducts business.

4kst employees are prohibited from entering into or agreeing to any type of agreement or arrangement as a means of altering the balance of any competitive bidding process, whether for the public or private sector. This prohibition encompasses not only bidding processes in which 4kst is a participant, but also bidding processes that involve the interests of the Company's clients.

The company also prohibits any of its employees from participating in the drafting of public notices, terms of reference or any other type of document used in competitive tenders that are the exclusive responsibility of the Public Administration.

VII.7. Money Laundering Prevention

4kst is fully committed to complying with all local and international laws and practices relating to the prevention of money laundering, in particular Brazilian Law 9.613/98 and other related regulations. Therefore, it does not allow any of its Employees, under any circumstances, to promote or participate in activities that aim to conceal the nature, origin, location, movement, or ownership of assets, rights, or values derived, directly or indirectly, from crime.

It also requires its Employees to be attentive to any movements by customers, partners, or suppliers that raise suspicion of illegality regarding the origin of funds.

VIII. DUE DILIGENCE

4kst is committed to ensuring that all changes to its corporate structure and management model comply with the rules and principles set forth in this Code of Conduct. To this end, its management shall always promote the implementation of a due diligence process.due diligence) with a view to learning about the history of the new entrant and/or the business trajectory of the new partner, and to confirm that there is no conflict of interest under the terms of this Code of Conduct.

IX. REPORTING AND COMMUNICATION CHANNEL

4kst provides a Reporting and Communication Channel available on its Intranet and on its website, accessible to its internal and external audiences in general, which is provided by a third party in order to ensure the full recording of reports and the protection of absolute confidentiality. 

The rules governing the operation of the Whistleblowing and Communications Channel – 4kst are set out in its Policy published on the 4kst Intranet and on its website, which reinforces the commitment to fully protect users of the Channel.

The Company promotes the use of this Channel as a mechanism to protect 4kst's culture and values, as well as its guidelines set forth in this Code of Conduct.

X. VIOLATIONS AND PENALTIES

Any and all violations of the rules set forth in this Code of Conduct must be formally reported to the Reporting and Communication Channel – 4kst. It must be the commitment of every 4kst Employee to prevent violations from occurring and/or going unpunished.

Violations of the rules of this Code will result in penalties ranging from warnings to termination of the contractual relationship. 4kst will not refrain from reporting any legal violations to the competent authorities.