Precedes Code of Ethics and Conduct

Effective: April 2025

The Code of Ethics for Precedes establishes principles and guidelines that define how we behave as a company, as collaborators, and as partners. It reflects our core values of integrity, transparency, responsibility, and respect for people, data, and the communities we serve.

1. Purpose

This Code promotes a shared understanding of what is expected from everyone acting in the name of Precedes — executives, employees, contractors, and engineers. It ensures a common commitment to conduct business ethically and in alignment with applicable laws, technical excellence, and societal responsibility.

2. Compliance with Laws and Standards

2.1 Respect for Laws and Regulations: Precedes adheres to all applicable laws and internal controls including auditing, securities trading, and anti-corruption practices.

2.2 Compliance: Employees must follow all relevant legal, ethical, and regulatory standards, including those required by market exchanges and regulatory bodies.

3. Clients and Investors

3.1 Corporate Governance: Communications with customers and investors must be ethical, timely, and transparent.

3.2 Alignment of Interests: Our policies ensure interests of stakeholders, clients, and administrators are aligned through responsible governance.

4. Our Team and Workplace Conduct

4.1 Working Conditions: Precedes promotes healthy, safe, and dignified workplaces.

4.2 Work Environment: No form of degrading or unsafe work will be tolerated.

4.3 Development: We encourage meritocracy, mutual respect, and team spirit.

4.4 Use of Resources: Employees must use assets responsibly and only for professional purposes.

4.5 Conduct: Harassment, discrimination, and unethical behavior are not tolerated under any circumstance.

5. Business Partners

5.1 Selection: Partners are chosen fairly based on merit, transparency, and value.

5.2 Compliance: All partners must adhere to this Code.

6. Relationship with Customers

6.1 Satisfaction: Precedes constantly works to improve customer experiences through ethical services.

6.2 Information: We ensure accuracy and transparency in marketing and communication.

7. Assets, Resources, and Security

7.1 Use of Assets: Company assets must be used solely for official business.

7.2 Data Security: Precedes implements safeguards to protect all data.

7.3 LGPD Compliance: We respect Brazil’s General Data Protection Law (Law 13.709/2018).

8. Social and Environmental Responsibility

Precedes promotes sustainability and social impact through its services and partnerships.

9. Human Rights

9.1 Protection: We ensure a workplace free from discrimination and harassment.

9.2 Child and Forced Labor: No individual under 18 may work, except as apprentices from 14; forced labor is prohibited.

9.3 Harassment: All forms of harassment are prohibited and reportable.

10. Anti-Corruption

Bribery, fraud, collusion, and unethical business practices are forbidden in both public and private interactions.

11. Gifts and Entertainment

11.1 Gifts: Items over R$100.00 must not be accepted unless authorized.

11.2 Invitations: Any business-related meals or events must be pre-approved and justified.

12. Financial Records

12.1 Accuracy: All economic transactions must be documented properly.

12.2 Documentation: Supporting documents must be archived per legal standards.

13. Ethics Channel

13.1 Reporting: Anyone may report issues at www.precedes.io.

13.2 Confidentiality: All reports are anonymous and protected from retaliation.

14. Anti-Retaliation

Anyone who reports in good faith is protected. Any retaliation will be sanctioned by Precedes.

15. Violations

All employees and users are subject to this Code. Any breach may result in disciplinary or legal action.

16. Final Provisions

This Code complements applicable laws and reflects Precedes’ ongoing commitment to ethics, compliance, and transparency.

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