💹Politics Money laundering

POLICY TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING

1. PURPOSE AND GOALS

The development and application, in day-to-day operations, of this Money Laundering Prevention Policy ("Policy"), aims to establish, by Code Tech Enterprise Ltda, its full and complete commitment to the adoption of best practices and effective action in combating and preventing money laundering and terrorist financing, establishing, to this end, guidelines, procedures and responsibilities (including limitations due to its practical activities, as well as the existence of Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers in the service provision chain), to be adopted in registration operations and their updates, in financial operations, especially in relation to foreign exchange, payments and remittances, and in contract management.

The Policy is also intended to promote proper guidance and the establishment of mechanisms, including technological ones, that enable all employees, collaborators, directors, partners and third parties who may have access to and analyze potential clients to be referred to the financial institutions that hold the banking instruments sought by the potential clients (financial operations) to comply with and adapt to all operational processes and forms.

As mentioned in the preamble to this Policy, the limits and procedures adopted aim to comply with the provisions contained in Law No. 9,613/1998, Law No. 12,683/2012, as well as Bacen Circular No. 3,978/2020, without prejudice to attention to other legislation not explained in this document, but which has a direct or indirect relationship with the obligation to Prevent Money Laundering and Terrorist Financing. Likewise, since Code Tech Enterprise Ltda. is an entity acting indirectly through a partner entity duly authorized by its Regulatory Body (Central Bank of Brazil) to carry out financial/exchange activities, i.e. it does not directly carry out financial/exchange operations for potential clients, but only intermediates/refer them to partner Financial Institutions and/or Brokerage Houses, it is clear that all the procedures adopted with regard to the Prevention of Money Laundering and Terrorist Financing are only one of the stages in the analysis of potential clients, since, due to the same legal/regulatory requirements, the partner Financial Institutions, Payment Institutions, Securitization Companies and Brokerage Houses, which own the financial products and which will eventually be directly responsible for said transactions with the end clients, will carry out and adopt their own procedures in relation to the analysis aimed at Preventing Money Laundering and Terrorist Financing. In this regard, it should be noted that Code Tech Enterprise Ltda is aware of the Anti-Money Laundering Policies established by its partner Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers, and is committed to their proper and full application in the daily lives of potential clients to be referred for financial transactions. No less importantly, it should be noted that decisions to accept and carry out financial transactions by Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers with potential clients indicated/approached by Code Tech Enterprise Ltda. After carrying out the appropriate analyses (credit and money laundering prevention), they will be sovereign, as will the assumption of the responsibilities and risks of the business, and Code Tech Enterprise Ltda. will not be jointly responsible for the strategic/business decisions of the third-party partners.

2. IDENTIFICATIONS

Money Laundering: According to the law, money laundering consists of concealing or disguising the origin of the movement of values, assets or rights, arising from crimes such as trafficking, kidnapping, extortion or crimes against the Public Administration, committed by individuals (private individuals) or criminal organizations, with the following stages in this process:

(1) Placement: the stage in which criminals remove possession/ownership of illicitly obtained funds by depositing them in places/establishments that handle large volumes of money or even financial institutions;

(2) Concealment: this stage consists of hindering and/or making it difficult to trace the illicit funds. To do this, criminals make financial transactions, including and especially electronically, to ghost accounts or third-party accounts, investments in funds, cryptocurrencies, etc., in order to make it difficult to analyze the financial backing of the origin of the funds;

(3) Integration: the stage in which the money has, in theory, a financial backing far removed from the initial crimes committed, in other words, it is covered up, at which point it is transformed and invested in legal businesses, such as the purchase of real estate, investments in financial institutions, etc.

Terrorism

Terrorist Financing: obtaining and contributing financial resources to carry out and promote terrorist activities, whether in the country or abroad.

Exposed Person (PEP)

Politically Exposed Person (PEP): a public official, or other persons duly listed in the legislation on the subject, who has held (or has a relationship with someone who has held), in the last five (5) years, in Brazil or abroad, a relevant public job, position or function, under the terms of the law.

COAF

COAF: The federal public body responsible for analyzing and investigating financial transactions that may be related to money laundering and/or terrorist financing.

Employees

Collaborators: People who have any employment/service relationship with Code Tech Enterprise, such as partners, employees, service providers, directors, partners, etc.

3. PROCEDURAL PROVISIONS Code Tech Enterprise Ltda stipulates as minimum procedural provisions for the purposes of this Policy:

Pay attention to and comply with all legal/regulatory provisions and other rules on the subject, adopting all the necessary practices to prevent money laundering and terrorist financing;

Obtain technological tools and develop monitoring procedures to identify potential clients or suspicious atypical transactions that could be evidence of money laundering and terrorist financing;

Establishing and defining the day-to-day activities of its employees and the procedures to be adopted on a regular basis with a view to combating money laundering and not referring suspicious potential clients to partner Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers;

To disseminate and awaken, with due attention, among its employees, specific knowledge about the prevention of money laundering and terrorist financing, in order to instill in the company's culture the harm and damage that such illicit operations can bring and the related responsibilities,

Promote, whenever necessary, the appropriate communications to the regulatory/supervisory bodies about suspicious or atypical situations/operations, in addition to, of course, responding to letters, questions and other queries from said bodies about compliance with legislation and procedures, as well as any financial operations already carried out.

4. SCOPE

This Policy for the Prevention of Money Laundering and the Financing of Terrorism must be observed and applied in all cases of potential clients wishing to carry out financial transactions with Code Tech Enterprise Ltda's partner Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers.

It is the responsibility of all areas and employees of Code Tech Enterprise Ltda to adopt and propagate all comprehensive procedures for compliance with legal and internal rules aimed at preventing money laundering and combating the financing of terrorism.

5. UNIVERSALITY OF THE MONEY LAUNDERING PREVENTION POLICY

In view of the legal/regulatory obligation to combat money laundering, it has been determined that the application of this Policy will extend to all areas, units, business partners, contractors, consultants, among others, who have a relationship with Code Tech Enterprise Ltda.

6. RESPONSIBILITIES

It will be the responsibility of each and every employee of Code Tech Enterprise Ltda. to duly and promptly notify the internal area responsible of atypical or suspicious situations involving potential clients with signs of money laundering or terrorist financing crimes, in order to avoid referral to partner Financial Institutions, Payment Institutions, Securitization Companies and Brokerage Houses and, consequently, the non-conclusion of financial transactions tainted by irregularities.

7. PROCEDURES

Code Tech Enterprise Ltda undertakes to adopt all operational procedures in relation to the prevention of money laundering and the fight against terrorist financing, in all potential financial operations to be intermediated and/or referred to partner Financial Institutions, Payment Institutions, Securitization Companies and Brokerage Houses, in addition to ensuring that all its employees have the knowledge and training to regularly identify operations or situations that may be indicative of money laundering or terrorist financing.

In the event of identifying an atypical or suspicious situation/operation on the part of a potential client, in addition to not forwarding it to Financial Institutions, Payment Institutions, Securitization Companies and Brokerage Houses, Code Tech Enterprise Ltda will adopt and communicate it to the competent bodies for the appropriate regulatory/legal investigations.

7.1. Registration

Code Tech Enterprise Ltda will always complete and require potential clients to complete identification forms and obtain up-to-date documentation, in order to ensure the regularity and credibility of attracting potential clients, and undertakes to keep and update registration information whenever necessary. No relationship or referral of potential clients to Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers may be initiated until the identification of the potential client has been completed.

8. COMMUNICATION

Any financial operations and/or situations identified by Code Tech Enterprise Ltda that may indicate or present characteristics and suspicions of money laundering will be duly and immediately communicated to the regulatory/supervisory bodies.

9. POLITICALLY EXPOSED PERSONS (PEP)

Code Tech Enterprise Ltda, through its employees, partners, directors, service providers, partners, etc., will devote special attention and control to the identification of Politically Exposed Persons, in order to carry out a careful examination of this special class, as well as to inform partner Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers in advance of the condition of the potential client who falls into this category, with a view to the partner also being aware of and controlling it.

All politically exposed people, in legal and regulatory terms, are considered to be at high risk and, consequently, should be monitored with greater diligence and discretion.

10. TRAINING

Code Tech Enterprise Ltda will constantly provide its employees and service providers with extensive training on the legal concepts of money laundering and terrorist financing, ways of identifying and reporting them, etc., as well as encouraging them not to carry out operations and to refer potential suspicious clients to partner Financial Institutions, Payment Institutions, Securitization Companies and Securities Brokers.

11. VALIDITY AND UPDATING OF THE POLICY

This Policy will initially be in force for 24 (twenty-four) months, at which time it should be reviewed and updated if necessary. In the event of legal, normative and/or regulatory changes on the subject, the Policy must be duly updated, regardless of the length of its validity.