Code of Ethics and Conduct

Introduction

For MADEINWEB TECNOLOGIA LTDA ("Made"), product and/or service suppliers and their contractors are strategic partners in conducting business and constitute a fundamental link in sustaining the company's value chain. The quality of the established relationship is based on the supplier's negotiation autonomy, respect, transparency of information, support for improving their processes, and compliance with established contracts – resulting in quality products and services, exceeding customer expectations and bringing them the brand's value.

This document also addresses the procedures of the Third-Party Risk Management (GRT) program, under the terms of Law No. 12,846/2013, which provides for the administrative and civil liability of legal entities for acts committed against the public administration, national or foreign.

The criteria for establishing a relationship with product and/or service suppliers go beyond price, product, and delivery time, as the conditions under which they are produced and the impacts they generate in economic, social, environmental, and corporate governance dimensions must also be considered when choosing a supplier.

The following behaviors are mutual commitments established between the company and its suppliers, seeking to guide professional practices or clarify situations that may generate conflicts in the relationship with Made.

Furthermore, they are responsible for disseminating the Code of Conduct to their contractors involved in Made's supply and requiring them to follow its content. Believing that through transparent and collaborative partnerships it is possible to build a socially just world, Made requires its suppliers to effectively adhere to the principles related to the following topics.

Definitions

• Due diligence: due diligence is the prior investigation of risks that a partnership may bring in the future and is part of the supplier qualification process.
• Contract analysis: current contracts must be carefully evaluated to avoid cross-liability and potential reputational damage to the contracting company.
• Legality assessment: new contracts must undergo a legality assessment to avoid errors in their drafting, which can become a risk for both parties in the future.
• Liability clauses: essential for protection in every business partnership, and it is important to create specific contractual clauses to define each party's responsibility.
• Corporate governance review: corporate governance needs to be reviewed and updated if necessary, considering that it defines the guidelines for internal policies and is part of compliance best practices.

Respect for legislation

The product and/or service supplier must comply with applicable legislation in the countries where it operates, fulfilling its financial, fiscal, social, and environmental obligations relevant to its line of business, as well as knowing and applying all Made internal procedures that apply to it. In cases where legislation and the Code of Conduct address the same issue, the supplier must consider whichever offers the greatest advantage to the worker.

Combat against child labor and slave labor exploitation

National or international product and/or service suppliers must not use labor from minors under 16 years of age, except as apprentices from 14 years of age. Workers under 18 years of age, including apprentices, must not be exposed to night work or dangerous, unsafe, or unhealthy conditions. Forced labor or labor analogous to slavery is not accepted. Workers cannot have their documents retained or be forced to make deposits as a condition of admission. Made does not allow the use of prison labor or debt bondage.

Combat against child sexual exploitation

Made considers any type of involvement of its suppliers in child sexual exploitation unacceptable, whether inside or outside their facilities.

Communication

The product and/or service supplier must ensure the communication and application of this Code of Conduct to its employees, as well as to all its contractors used in the production of our products.

Monitoring and compliance

The product and/or service supplier must authorize unannounced technical visits by Made to verify compliance with this Code of Conduct, granting full access to its facilities, health, safety, and environmental documentation, employee records, and private interviews with its employees, acting with transparency.

Media conduct

The product and/or service supplier may not use images, logos, or disclose information, whether for internal or external use, without prior authorization. This restriction extends to press interviews or the use of social media.

Anti-corruption

The product and/or service supplier must repudiate practices of any nature that characterize corruption, bribery, money laundering, and other illicit acts, seeking to promote ethical and transparent relationships, not admitting relationships with any interested party that is related to organized crime, illicit activities such as money laundering or terrorism.

The Supplier must comply with all anti-corruption, anti-bribery, and anti-fraud laws. Made prohibits any act of corruption committed by suppliers in the course of their activities for the company, even if it generates benefits for the company.

Confidentiality and information secrecy

The Company's confidential information must be handled responsibly by all product and/or service suppliers, supported by the Confidentiality Agreement, ensuring its exclusive use in fulfilling the activities/obligations established in the commercial contract signed with Made.

Quality of products and services

Suppliers must ensure that they provide products and services with the highest quality standards, in compliance with legislation, including product safety requirements, and in accordance with the Company's Quality Manual.

Conflict of interest

Made's product and/or service suppliers commit to establishing an ethical, transparent relationship based on its guidelines and orientations, to ensure an environment free from any favoritism for themselves or others.

Made rejects unfair competition and only allows its employees to collect information through legal means. The use of illegal or unethical means to obtain information about other companies is strictly prohibited.

Receiving gifts and participating in events

The Company's product and/or service suppliers should not offer gifts, benefits, favors, or provide Made employees with the opportunity to participate in private social events, in order to avoid any conflict of interest in the business relationship. Only promotional items of insignificant commercial value to be used at work (notebooks, pens, notepads) will be accepted.

Prohibition of narcotics and weapons

Made does not allow employees of its goods and/or service suppliers to be under the influence of narcotic substances while serving the Company, including during trips, events, and training sessions. Weapons of any kind are not permitted on company premises, except for expressly authorized professionals.

Sanctions and penalties

Non-compliance with any item of this Code may lead to corrective measures, ranging from blocking the supplier from new orders or contracts to termination of existing contracts.

This code does not exhaust all possibilities related to supplier conduct. Therefore, it does not exempt Made from applying disciplinary measures, which will always be guided by common sense and applicable legislation.

Full compliance with this code is a fundamental condition for the company to remain as a Made supplier.

Conduct in case of questions or violations

In line with best corporate governance practices, Made has established procedures for confidential and anonymous complaints and reports from employees or people outside the organization who are aware of any improper or questionable situation.

The company has mechanisms to protect whistleblowers, in order to prevent retaliation for incidents that violate this Code, policies, legislation, and regulations applicable to the business. Investigations into reported facts will be conducted impartially and independently.

Phone: +55 11 3796-2875

Email: ouvidoria@madeinweb.com.br