Code of Conduct

1Message

• MAGMA’s purpose is to provide financial advisory services and to be recognized for its competence, the quality it brings to its processes, its technical knowledge and its ethical conduct in the market.
• To this end, the tireless practice of ethical behavior is essential, not only by MAGMA’s partners, officers, leaders and direct employees, but also by everyone who deals with it.
• Accordingly, MAGMA’s Code of Conduct serves as a guide for ethical and professional behavior aimed at preserving its values: “Integrity”, “Human-Centered Relationships” and “Commitment”.
• We ask everyone to read and become familiar with this Code, on the basis of which we will work and cooperate so that MAGMA is recognized not only for its excellence but also for cultivating its integrity.

2Introduction

2.1 Purpose of the Code

• This Code of Conduct sets out guidelines and rules of behavior to guide conduct and decision-making in MAGMA’s day-to-day activities.

2.2 Responsibilities

• This Code of Conduct applies without restriction to everyone involved with MAGMA: partners, directors, leaders, managers and direct or indirect employees, members of partner companies or organizations, government representatives, or any other individuals and/or legal entities and their representatives who deal with MAGMA.
• MAGMA’s partners, directors and leaders must ensure that its content is widely disseminated, especially to the company’s direct employees, who in turn must follow the expected standards of conduct. Everyone must work to build an environment that supports the conduct set out here, including the proper handling of behavior that violates the guidelines of this Code of Conduct.

3Compliance with the Law

3.1 Compliance with the Law

• MAGMA’s activities must be aligned with compliance with and respect for the laws in force in Brazil, our corporate documents and all conventions, regulations and practices applicable to our sector.
• We live by and adhere to the principles and values set out in this Code of Conduct.

3.2 Prevention of Corruption and Bribery

• Our interactions with public officials must be conducted with integrity, observing the highest ethical and moral standards, and must comply with all applicable laws.
• We do not offer, provide, promise, request or accept, directly or indirectly, any unlawful payment, benefits, favors, gifts or items of value intended to improperly influence decisions or actions related to our activities.
• We firmly combat all forms of corruption, fraud or undue advantage.
• We do not sponsor, support or finance any activities or projects that originate from or aim at unlawful acts, or that go against MAGMA’s ethical standards.

3.3 Financial and Information Management

• We believe that financial transparency and integrity are essential to the sustainability and continuity of our activities, ensuring that we meet our objectives and achieve future success, and reinforcing the trust placed in MAGMA by our clients, partners and employees.
• We do not share privileged information, whether ours, our partners’ or related parties’, that could dishonestly influence any decision, financial or otherwise, generating benefits for ourselves or third parties or causing harm of any kind.
• We apply strict standards of ethics and confidentiality in collecting, using, managing and protecting personal and registration data, intellectual property and/or confidential information, whether ours or provided by third parties, using such information exclusively for its intended purpose.
• We must preserve the confidentiality of information belonging to MAGMA and to third parties, refraining from using it for our own benefit or that of others or in any way that causes harm, and maintaining this commitment even after the relationship with MAGMA ends.
• We agree that all assets protected by intellectual property and/or copyright rules that are produced and/or created during and/or within the scope of our professional activities at Magma, whether or not with resources provided by it, shall be the exclusive property of Magma.
• All partners, associates, interns and/or employees assign to Magma, free of charge, the use of all economic copyright they hold over the creations, works, inventions or any other form of intellectual property or copyright arising from and/or produced in the performance of the contracts between them and Magma.

4Integrity in Relationships

4.1 Relationships with Suppliers

• We understand that our clients, suppliers and partners play an important role in successfully fulfilling our purpose, which is why we seek relationships with those who share our commitment to preserving reputation and ethics.
• We do not unilaterally favor any supplier or service provider without technical justification, avoiding any conflict of interest.

4.2 Conflicts of Interest

• We do not allow any individual or organization to improperly benefit from MAGMA, whether through a relationship with one of our employees or otherwise, and none of our employees may personally benefit improperly from a relationship with another individual or organization.
• We identify and act to prevent and curb situations that create conflicts of interest and could compromise or improperly influence our activities and, where applicable, we adopt conflict mitigation measures.
• Conflicts of interest arise, for example, when a party related to the matter at hand lacks independence and could improperly influence decisions or actions related to our activities.
• In addition, actions contrary to our Purpose and Values may also be considered conflicts of interest.

4.3 Contracts

• We vigorously pursue the fulfillment of our contractual obligations and the accurate and timely documentation of our activities, in accordance with legal requirements and applicable accounting standards.
• We must engage organizations and/or individuals who respect the law, meet their tax, labor and environmental obligations and expressly adhere to this Code of Conduct.
• Our hiring and engagement decisions must be based exclusively on technical, behavioral, professional and ethical criteria.
• Supplier selection must consider the best cost-benefit ratio, ideally favoring companies that contribute positively to environmental, economic and social sustainability and fit this profile, with no undue favoritism of any kind.
• Our partners, officers and employees are prohibited from entering into contracts on behalf of MAGMA that are unrelated to its corporate purpose, or that exceed the authority and/or approval limits granted to them.

4.4 Political Activities and Advocacy¹

• MAGMA may take an institutional position, through its legal representatives, in public or private political debates relevant to its activities and on matters that improve the environment in which it operates and are of institutional interest to it.
• We strictly control advocacy activities and carry them out in full compliance with the law, ethically, with integrity and transparency.
• We value MAGMA’s political non-partisanship.
• We respect each employee’s individual right to express opinions, engage in civic matters and activities and take part in political processes or organizations, provided such participation takes place outside the workplace and with their own resources.
• Employees and related parties must always make clear that their individual, personal, political and/or partisan statements are their own and not the company’s, in order to preserve MAGMA’s values and independence.

¹ Advocacy means acting in an organized way to influence decision-makers and public opinion in order to change or maintain a given public policy of broad interest. Such advocacy efforts seek to influence public policies that will have a positive impact on civil society as a whole.

5Behavior

5.1 Workplace and Conduct

• We must foster respectful and cordial relationships between people, based on freedom of expression, dignity, fairness and equality.
• Any discriminatory action or expression is prohibited, whether based on religion, belief, age, color, physical condition, ethnicity, nationality, gender, sexual orientation, social origin or status, political position and/or any other characteristic.
• Any form of workplace or sexual harassment is prohibited, as is any form of threat or intimidation.
• We must cultivate, respect and value social, cultural and political diversity.
• We must distinguish between personal and professional relationships, so that relationships in the workplace and in our activities remain professional and in MAGMA’s interest.
• Each person must protect their own privacy and take responsibility for their appearance and actions, avoiding behavior that is inconsistent with this Code or that could harm MAGMA and/or third parties.
• Everyone has a duty to protect our confidential information and comply with confidentiality obligations, maintaining this commitment even after their relationship with MAGMA ends.
• Possessing or using illegal substances in the workplace is not permitted. Moderate alcohol consumption is permitted at social events.
• Everyone must help maintain a safe workplace and contribute to its cleanliness and organization.

5.2 Human and Material Resources

• We must strive to give employees access to all information relevant to their work.
• We must cultivate a collaborative and supportive environment, promoting integration and sharing knowledge, learning and good practices.
• The appointment, hiring or favoring of relatives, spouses or partners, whether direct or collateral, by blood or by marriage, by virtue of a position of power or influence, will not be tolerated.
• We must protect MAGMA’s assets, using equipment, machinery, materials and other available resources, including and especially financial resources, with care and in a sustainable way, avoiding damage, misuse, waste, fraud, theft or robbery.
• We must work with excellence and responsibility, managing our working time with autonomy and efficiency, aiming to increase productivity, complete daily tasks and achieve individual and collective goals and objectives.

5.3 Professional Etiquette

• We value organization, punctuality and meeting deadlines. We must give advance notice if we are unable to attend a commitment or deliver a piece of work, explaining the reasons and proposing alternatives.
• We respect each person’s personal taste and style, but we encourage discretion, restraint and neutrality in personal appearance, as well as adherence to the level of formality, including in language, normally required by our work environment and by the profile of our clients.
• Maintaining a good appearance and personal hygiene shows commitment and respect for everyone in the professional environment.
• Good posture can have a positive influence on those around you. When talking with people, we should maintain eye contact, keep a neutral tone of voice and stay in control of our emotions – avoid speaking too loudly and/or laughing uncontrollably.
• We should keep a pleasant, cheerful and relaxed atmosphere, while observing certain limits. We must be mindful of the diversity in our environment, where people of different cultures, beliefs and generations, among others, work together, so that certain jokes and/or teasing can easily cause discomfort or even offense.
• We must be careful about how we address people. It is not advisable to use nicknames or shortened versions of people’s names, especially in more formal settings. To avoid missteps, address people by the name they use to introduce themselves.
• We should cultivate courtesy and the habit of saying “excuse me” and “thank you”.

6Society

6.1 Communities

• MAGMA provides quality services that contribute to the advancement of economic activity and the generation of liquidity for clients and companies.
• We seek to create economic, social and educational benefits for society.
• We are willing to listen and respond to requests from clients, partners and suppliers within our sphere of activity.

6.2 Sustainability

• We are committed to minimizing the environmental impact of our operations through environmentally sustainable practices within our scope of activity and by working with suppliers who share our environmental commitments.
• We act in a socially responsible manner in the areas where we operate, aiming to contribute positively to environmental, economic and social sustainability.

6.3 Institutional Relations

• We seek to earn the trust and understanding of all parties that deal with MAGMA, including officers, employees, partners, suppliers, clients and governmental and non-governmental organizations.
• Relationships with governmental organizations and representatives of the executive, legislative and judicial branches, at all levels, will be conducted independently.
• Relationships with the media will be restricted to the communications area or to spokespersons designated and approved by MAGMA’s officers.
• Personal opinions expressed publicly by our employees, through social networks or media or in any other way, must be identified as that individual’s own opinions, making clear that they do not represent MAGMA’s position. On professional social networks where the individual identifies as an active MAGMA employee, all statements must follow the guidelines of this Code of Conduct.

7Handling of Misconduct and Improvement

• Failure to comply with the Code of Conduct may cause problems not only for MAGMA but also for our employees and other parties who deal with us. Adherence to this Code of Conduct is therefore mandatory.
• Violations of the guidelines of this Code and/or other ethical breaches not expressly provided for will be duly analyzed and appropriate consequences will be applied. Depending on the violation, measures provided for in labor law may be taken, and compensation or criminal sanctions may be sought.
• In case of questions or uncertainty about appropriate behavior, conflicts of interest, fraud or complaints, employees and other related parties may and should contact any member of MAGMA’s Leadership².
• MAGMA encourages direct communication with its senior leadership (signatories below), but also provides on its website a form for submitting reports, which may be made anonymously whenever the reporter prefers not to be identified.

• The confidentiality of reports received is guaranteed, and any retaliation against anyone who reports misconduct and/or concerns in good faith or provides information related to an investigation is strictly prohibited, without prejudice to action being taken if a report is found to be false and made in bad faith.
• Persons or parties involved in a report or investigation are presumed innocent until the misconduct is duly verified and proven.
• Questions and suggestions for continuous improvement that are not related to ethical misconduct and/or do not affect the integrity sought by this Code of Conduct may be sent to our administrative department at: adm@magmabr.com.

São Paulo, March 2026.

Magma Brasil Consultoria Ltda.

² MAGMA’s Leadership consists of its senior partners: Ernani Ponce, Marcos Magnani and Marlos Nogueira.