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Code of Conduct

Current as of November 23st, 2023.

1. Management Message

It is with great satisfaction that we present the Code of Conduct of Diazero Technologies. We seek with this document to reflect the principles desired by the Company that must be developed and practiced by all employees, suppliers, business partners and service providers.

Thus, our main goal is to preserve the commitment to act with professionalism and responsibility and to protect the company's brand, which is what connects the customer to our products and services, focusing on interpersonal relationships, ethical conduct, examples of participatory leadership in development processes in the fields of competitiveness, sustainability, innovation and valuing people.

This document reflects the posture desired by the Company, and thus the transparency and respect that must be observed in the daily routine of work in all activities performed should prevail.

Thus, the reading of all the content of the Code of Conduct is MANDATORY and should serve as a valuable reference in your professional activity at Diazero Technologies.

2. Presentation

Diazero Technologies is a company providing comprehensive cybersecurity solutions, with a high standard of quality and performance, aiming at the application of security solutions.

This Code of Conduct is based on the essential values of the company, as an instrument of information, consultation and awareness, aiming to concretize and guide the principles of the company with mission, vision, values and practices for ethical behavior, based on the pillars of integrity, respect, dignity and social responsibility.

In order to protect and elevate its brand of commitment and professionalism, Diazero Technologies and its employees must responsibly comply with the best practices of professional and social ethical conduct.

We address, in general, the values that guide and must be observed in the personal and professional conduct of all who maintain professional relations with Diazero Technologies, whether as an employee, business partner or supplier, a formal statement of Diazero Technologies' commitment to the principles of equality, human dignity, loyalty, integrity and professional transparency, in order to promote a productive and healthy work environment.

We invite you to read and understand our Code of Conduct.

3. Goal

Its main objective is to guide the most diverse audiences that maintain professional relations with the Company, outlining guidelines and conduct expected by the Company, in addition to providing sanctions for non-compliance with them.

It is expected that this document does not contemplate all situations of ethical conflicts that may arise on a daily basis. The objective of Diazero Technologies is to define basic principles that should guide the relations and activities in the Company, in addition to reinforcing the need to comply with current legislation.

Diazero Technologies counts on the collaboration of all so that the guidelines provided for in this Code are practiced every day, since a document of this nature only gains legitimacy with time and constant practice.

4. Coverage

The ethical principles defined in this code of conduct cover all locations in which Diazero Technologies has professional relationships, whether through employees, service providers, business partners, suppliers or any other type of public, who must observe this document in whatever the organizational process of the company.

5. Definition of Code of Conduct

The Code of Conduct is a document that provides guidelines for professional behavior and relationships. This document seeks to provide transparency in the processes and standardization of conduct, supporting decision-making and parameters for the resolution of conflicts or nonconformities that do not follow the conducts represented herein.

6. Mission, Vision and Values

Our Mission is to meet the needs of our customers with quality, speed and efficiency, bringing to the information security market what is most innovative in terms of process automation.

Our Vision is to be a reference in the information security segment, always innovating in terms of automating processes that guarantee the satisfaction of our customers, thus being recognized by our customers, employees and partners for the quality of the services provided.

Our values are team work, innovation and leadership, results, commitment to continuous improvement, ethics and respect for others.

TEAMWORK: It is in teamwork that we improve our knowledge, intelligence and skill, which leads us to deliver to our client efficiency and accuracy.

INNOVATION AND LEADERSHIP: We invest in research and development of solutions, supporting and encouraging a climate of thinking beyond today always seeking to meet the needs of our customers.

RESULTS: to offer the most innovative to our customers.

COMMITMENT TO CONTINUOUS IMPROVEMENT: Excellence is only achieved through continuous process improvement.

ETHICS AND RESPECT FOR OTHERS: Ethics and respect for employees, customers, suppliers, partners and society is a fundamental condition for success.

7. Interpersonal relationships and work environment

a) Diazero Technologies does not tolerate any form of prejudice, discrimination and harassment, especially situations that constitute intimidation, hostility, embarrassment or threats, regardless of hierarchical level;

b) Contribute to the creation and maintenance of a productive environment, collaborating and cooperating between teams. Respect the space of each employee, not acting in a way that harms the performance of peers and subordinates;

c) Do not promote actions prioritizing the personal relationship with other employees. Do not use and/or benefit from your position and/or position to impose actions and methodologies that are outside the company's standards, as well as to promote discomfort in the relationship with others;

d) Promote cordiality, solidarity, urbanity and good relationship with respect to cultural, religious and political values, not practicing any act of personal, professional and social discrimination in the workplace;

e) Behaviors, verbalizations, gestures or physical contact of a sexual nature, coercive or not, threatening or abusive, are not allowed, as well as the use of alcoholic beverages or toxic substances (drugs), during the work period, inside the company or in service stations;

f) Each and every person who maintains professional relations with Diazero Technologies has full autonomy to report anonymously if so desired, any practice or evidence that points to harmful practices that do not comply with the good conduct practices of the company, which may be done through the e-mail: [email protected] It is important to emphasize that communications made through this channel will be protected by secrecy and confidentiality;

g) Every employee, regardless of their hierarchical position, must be treated fairly and courteously by their superiors, subordinates, co-workers and any other type of public that maintains professional relations with Diazero Technologies.

8. Prevention of Fraud, Corruption, Money Laundering and Terrorist Financing

Diazero technologies is absolutely committed to the promotion of integrity in the public and private business environment, acts in full respect of the applicable national and international legislation, mainly the Law for the Defense of Administrative Probity (Brazil), the Corporate Anti-Corruption Law (Brazil), the FCPA – Foreign Corrupt Practices Act (USA), UK Anti-Bribery Act and the SOX – Sarbanes-Oxley Act (USA), among other legal norms in the fight against corruption.

In this sense, Diazero Technologies repudiates any and all forms of fraud and corruption, including bribery, money laundering or trading with privileged information, in all its hierarchical levels, being, therefore, absolutely forbidden to all its employees and the public of interest that maintains professional relations with the Company, in the course of such relations:

a) Request, obtain, receive, promise, offer or give undue advantages of any kind to itself or to third parties, including facilitation payments due to the public function performed;

b) Induce or persuade colleagues to act improperly or illegally on behalf of or on behalf of the Company;

c) Omit to face situations of fraud and corruption (national or transnational), in any form, directly or indirectly, actively or passively, involving or not monetary values;

d) To finance, cost, sponsor or, in any way, subsidize the practice of unlawful acts;

e) Adopt, with respect to the public sector, national or foreign, any initiative that can be interpreted as influence peddling and as an act harmful to the Public Administration, described in Article 5 of Federal Law No. 12,846, of 2013.

9. Privacy and Data Protection

It is the duty of Diazero Technologies to guarantee the right to privacy of its employees, customers, suppliers, business partners and all types of public that maintain professional relations with the Company, as well as the confidentiality of the personal data to which it has access, giving wide accessibility to its respective holder and making use of them only for appropriate and legally permitted purposes.

Diazero Technologies will observe in all professional relationships the applicable data protection legislation, aiming at a greater protection of personal data.

To this end, it is the duty of all those who maintain professional relations with Diazero Technologies:

a) Have the exact understanding that the processing of personal data is permitted only for specific, defined and legitimate purposes;

b) Observe and comply with the rules and guidelines of privacy and protection of personal data;

c) Verify which personal data are really necessary for the development of its activity before collecting, accessing, using, storing it, disclosing it or carrying out any other type of treatment;

d) Not to share access passwords with third parties or use third party passwords to access corporate systems or computers;

e) In the use of the Company's equipment and resources, there should be no expectation of privacy, and the Company may have access to the content produced or transited by them.

10. Protection of Corporate Information

Considering that all elements of information entrusted to employees and all other stakeholders in their professional relations are the property of Diazero Technologies, it is the duty of all to act in the protection of information that is in their possession or that obtained during meetings or negotiations, especially those of a privileged nature, which must always be treated with adequate security, in accordance with the applicable internal rules.

It is the duty of all stakeholders who maintain professional relations with Diazero Technologies in the performance of such relationships:

a) Comply with Diazero Technologies' Information Security standards and guidelines regarding the protection of corporate information and information processing;

b) Use corporate information exclusively for the performance of their respective professional activities;

c) Adopt, especially in non-corporate environments, the necessary precautions when dealing with Diazero Technologies information, especially those that are relevant to the decision process, with economic, financial, image and reputation repercussions;

d) Respect professional secrecy, keep secret and not divide, transmit or share the information to which they have access due to the exercise of their activities, which have not been previously authorized by the competent authority or that are in disagreement with the rules and guidelines of Information Security;

e) Ensure that the information entered in documents and communications is true and compatible with the standards and guidelines of Information Security of Diazero Technologies;

f) Not to use information to which they have access, due to the exercise of their activities, to trade securities or to obtain personal advantages or for third parties, nor to share information of this nature with third parties for such purposes;

g) Immediately report to Diazero Technologies any non-compliance with Information Security, disappearance or suspected loss of information and/or equipment containing sensitive information;

h) Do not voluntarily alter or destroy original documents of probative value, keeping them on file, preferably in digital format, in the form and for the deadlines defined by law.

11. Relationship With Stakeholders

It is Diazero Technologies' duty to maintain adequate, diversified and continuous practices of communication and relationship with different stakeholders, including business partners, customers, suppliers, communities, public agents, political agents, press professionals and representatives of the third sector, among others.

These practices should be based on respect, dialogue, transparency, integrity and compliance with the rules for the protection of free competition. Diazero Technologies also assumes the duty to refuse support and contributions to political parties or political campaigns of candidates for elective office.

In the relationship with stakeholders, it is the duty of all its employees and all types of public that maintain professional relations with Diazero Technologies with regard to such relations:

a) Develop the activities related to its functions with integrity and loyalty;

b) Not to practice or condone anticompetitive conduct, and must comply with competition legislation and the specific guidelines of the applicable internal rules;

c) Not to make public declarations on behalf of the company without the express and formal authorization;

d) Not to use digital channels and external social networks to express aggressive, disrespectful opinions that infringe on the values of the company or that cause damage to the image and reputation of the company;

e) Ensure that the confidentiality of the information will be preserved and that the disclosure will only occur in a timely manner and in accordance with the legal provisions and the rules of the company;

f) Not to request, receive, offer or grant gifts, gifts, hospitality or sponsorship counterparts in disagreement with the internal rules of the company and with the applicable legislation;

g) Formally report on inappropriate conduct or behavior by stakeholders;

h) Establish strategic and business partnerships that seek to contribute effectively to the mutual growth and development of the company;

i) Seek solutions that meet the interests of the company with the different stakeholders, in case of crisis or situations of conflict between the interested parties, respecting their constituted rights;

j) Adopt formal and documented means to manifest the company's position in the relationship with the public power, regulatory bodies and authorities constituted by the executive, legislative and judicial branches;

k) To carry out a transparent, truthful and correct communication, easily understandable and accessible to all interested parties, and a publicity based on the values and principles established in this Code;

l) Not to produce or disseminate false news or unverified facts, which must always be checked in the official channels of the company, by reliable media and responsible institutions;

m) To require companies providing services that their employees respect the commitments of conduct defined in this Code.

12. Prevention of Conflicts of Interest

The conflict of interest is characterized when any of the types of publics that maintain professional relations with Diazero Technologies, in the course of such relationships act to achieve particular interests, contrary to the interests of the company or that may cause any type of damage to DiazeroTechnologies.

It is the duty of Diazero Technologies to prevent and avoid any and all situations, actual or potential, generated by the confrontation between public and private interests, which may compromise the interest of the company, damage its reputation or influence, in an improper way, the performance of the respective professional activity. The duties of all the publics affected by this code are:

a) Know and avoid the hypotheses of conflict of interest provided for in the legislation in force, either during or after the termination of the professional relationship;

b) Not to engage directly or indirectly in any activity that is in conflict with the interests of Diazero Technologies;

c) Seek impartiality, exercising its activities in an exempt manner, without using its condition to obtain advantages for Diazero Technologies;

d) Immediately and formally report the occurrence of any conflict of interest, or the appearance of its existence, to Diazero Technologies through the available channels;

e) Declare itself prevented from deciding or from carrying out certain activities where the respective act is capable of generating an actual or potential conflict of interest.

13. Protection of Company Assets

It is Diazero Technologies' duty to ensure the integrity of all its assets, whether material or immaterial, including information, technology developed or acquired, software, hardware, facilities, vehicles, equipment, materials, financial assets, immaterial property rights, reputation and image and credits.

To this end, it is the duty of all stakeholders during professional relations with Diazero Technologies and when applicable:

a) Properly use, in accordance with good industry practice, the company's assets for purposes directly related to the activities and business of Diazero Technologies, including intervening or reporting in case of identification of improper use or evident waste;

b) To take care of Diazero Technologies' shared assets in order to protect them against loss, damage or abuse;

c) Not to associate its brands with other businesses, except in cases authorized by the company;

d) Not to use the brand or name of Diazero Technologies or any of its products to promote any personal or private activity or associate with brands of other companies or entities, without due and prior authorization;

e) Ensure the reputation and image of the company, in all environments, including the online environment;

f) Not to use the company's assets for personal or private activities of buying and selling, offering services or advertising, as well as not inducing or encouraging colleagues to do so.