CODE OF ETHICS AND CONDUCT

1. Objective

This Code of Ethics and Conduct aims to establish the principles, values, rules, and standards of behavior that must guide the activities of DFY, a technological platform operated by D Empreendimentos LTDA, as well as all its employees, administrators, directors, partners, suppliers, service providers, and users who interact directly or indirectly with the platform.

This Code aims to promote ethical, integral, responsible, and transparent conduct, preserving DFY's institutional reputation, user trust, compliance with current legislation, good governance practices, and commitments assumed within the scope of its operation as a BaaS platform for collection accounts management.

2. Scope

The provisions of this Code apply to all those who act on behalf of DFY or who have any type of institutional, contractual, or operational relationship with the platform, including employees, administrators, directors, users, operational partners, technology partners, suppliers, service providers, and any third parties who have access to DFY information, systems, or infrastructure.

Compliance with this Code is mandatory and integrates the institutional and contractual relationships maintained by DFY.

3. Principles and Values

DFY's activities are guided by the following principles and values:

Ethics and integrity, with honest, responsible, and consistent conduct in all relationships;

Legality, with strict compliance with applicable legislation and internal rules;

Transparency, with the provision of clear and adequate information, respecting legal and contractual limits;

Responsibility, assuming the consequences of actions taken;

Respect for people, with dignified, fair, and professional treatment;

Information security, with the protection of data, systems, and information as strategic assets;

Compliance, observing internal policies and integrity controls.

4. Conduct in Relations with Users

DFY undertakes to act with clarity regarding the nature and limitations of its role as a technological platform, offering secure and adequate infrastructure for the management of collection accounts.

It is the duty of all involved to preserve the confidentiality of the information handled, to act with respect, courtesy, and professionalism in customer service, and not to assume, under any circumstances, responsibilities that go beyond the scope of the platform's operation.

5. Conduct in Internal Relations

Relationships between employees, administrators, and representatives must be based on mutual respect, cooperation, professionalism, and integrity.

Practices of discrimination, harassment, abuse of power, intimidation, or any behavior that violates human dignity or compromises the work environment will not be tolerated.

Everyone must comply with internal policies, information security standards, and DFY compliance guidelines.

6. Conduct in Relations with Partners and Suppliers

The selection, hiring, and maintenance of partners and suppliers must observe technical, legal, and ethical criteria, prohibiting practices that constitute undue favoritism, conflict of interest, or damage to DFY's integrity and reputation.

Signed contracts must contain clauses ensuring ethical compliance, confidentiality, information security, and adherence to applicable standards.

7. Relationship with Public Authorities

DFY adopts a stance of absolute legality and transparency in its interactions with public authorities.

It is expressly strictly forbidden to offer, promise, authorize, or grant payments, undue advantages, or benefits, as well as to practice acts that may constitute corruption, fraud, or any irregularity before public authorities.

8. Conflict of Interest

All involved must avoid situations that may characterize a conflict between personal interests and DFY's institutional interests.

Any potential or actual conflict of interest situation must be communicated immediately to the responsible area for analysis and appropriate guidance.

9. Use of Platform, Systems, and Information

It is the duty of all to use the DFY platform, its systems, and information exclusively for lawful purposes compatible with its purpose of managing collection accounts.

Access credentials, personal data, confidential information, and technological assets must be protected, prohibiting the disclosure or misuse of information without authorization.

10. Prevention of Illicit Acts

DFY adopts a zero-tolerance stance regarding fraud, money laundering, financing of terrorism, and misuse of the platform for illicit purposes.

Everyone must cooperate with internal prevention, investigation, and reporting procedures to competent authorities, when applicable, in accordance with internal policies and current legislation.

11. Communication and Reporting Channel

DFY provides adequate channels for receiving doubts, communications, and reports related to conduct incompatible with this Code, ensuring confidentiality, protection for good-faith whistleblowers, and appropriate treatment of received information.

12. Disciplinary Measures

Failure to comply with the provisions of this Code may result in the adoption of applicable administrative, contractual, and legal measures, depending on the severity of the infraction, without prejudice to other measures provided for in DFY's internal regulations.

13. Final Provisions

This Code enters into force on the date of its approval and must be widely disseminated to all covered audiences, being reviewed periodically or whenever there are relevant changes in DFY's operational, technological, or regulatory environment.

D Empreendimentos LTDA

DFY

2025

Last update 01/10/2026

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