1. INTRODUCTION

The BANCO LUSO BRASILEIRO Code of Ethics and Conduct establishes the principles that guide our conduct, both as an institution and on the part of our employees, business partners, and service providers.

The Bank upholds ethics and sound business practices and, to reinforce this belief, we have developed this Code of Ethics and Conduct, providing transparency to what we value and making these principles our commitment.

Our main purpose is to collaborate with the development of companies in the transportation sector, international trade, and other mid-market segments by offering financial products and services.

The relationship with our customers and partners will be one of the pillars that will sustain our activities. The Code of Ethics and Conduct of BANCO LUSO BRASILEIRO seeks to make clear to everyone involved in our production chain the rules that will guide and limit this relationship.

We fully endorse the content of this Code of Ethics and Conduct as our guide for achieving our strategic objectives, without forgetting our socioeconomic responsibilities.

2. OBJECTIVE

All relationships must be guided by the same standard of conduct and behavior,, whether between coworkers, the public sector, customers, shareholders, the market, suppliers, competitors, regulatory agencies, society, or family.

3. SCOPE

The content of this Code of Ethics and Conduct is comprehensive and applicable to all employees, business partners, and service providers of the Bank.

4. SENIOR MANAGEMENT

Our team is aligned with this Code, but above all, seeks to respect commercial, professional, and human relationships and the precepts contained therein, observing the values, mission, and vision of the Bank.

Integrity, respect, commitment, and consistency reflect what we value and preach in our Code of Ethics and Conduct.

“In the end, our greatest achievement will always be to hear someone say with pride: BLB is my bank.”

Francisco Ribeiro President of BLB

5. MISSION, VISION, AND CORPORATE VALUES

5.1. Our Mission

“To offer tailored financial solutions for the public transportation sector, companies operating in international trade, and other mid-market segments, always with excellence in execution, ethics, and transparency in relationships, generating value for shareholders and society.”

5.2. Our Vision

“To be the bank of choice for our customers, with strong and sustainable growth.”

5.3. Corporate Values

5.3.1. SOCIAL RESPONSIBILITY AND RESPECT

Act transparently, with attitudes and procedures that generate credibility and trust.

5.3.2. ETHICS

Commitment to integrity, honesty, and conduct, adopting high ethical standards in all business and relationships.

5.3.3. COMMITMENT

Act in a planned and integrated manner, encourage teamwork, and promote the sharing of responsibilities, attitudes that ensure business sustainability.

5.3.4. HIGH PERFORMANCE

Achieve extraordinary results through a culture of simplicity and meritocracy, in order to attract and retain talented people who act as owners.

5.3.5. WELL-BEING

Ensure safe working conditions, recognition, appreciation, a pleasant environment, and mutual cooperation.

6. RULES OF CONDUCT

6.1. Integrity

To guide the conduct of those who represent our Bank, we have identified possible relationships and established certain premises for conducting such interactions.

6.2. Unacceptable Conduct

• Corruption, extortion, or fraud;
• Illegal incentives in the form of kickbacks and bribes;
• Falsifying information, documentation, reports, financial records, and structuring of operations and transactions;
• Misappropriation of funds, ideological falsehood, tax evasion, or other unfair and illegal practices;
• Indiscriminately receiving gifts, gratuities, and entertainment without observing internal rules and limits; and
• Participating in bids, contracts, and interactions with the public or private sector that are contrary to the guidelines of this Code.

6.3. Conflicts of Interest

A conflict of interest occurs when any employee, administrator, sales representative, supplier, or service provider of the Bank, due to their influence, position, or access inherent to the activities performed, makes decisions in which their private interests prevail or conflict with the Bank’s interests, resulting in personal benefits of any nature, direct or indirect, for themselves, their family members, or friends, regardless of whether such decision causes damage or loss to the Bank.

As a preventive control, the Bank adopts decision-making criteria, definition of authority levels, duties, and responsibilities, mainly using the principle of segregation of duties.

Any type of conflict must be promptly reported to the Compliance area or the Reporting Channel, and those involved must refrain from making decisions related to the conflict.

6.4. Bribes, Facilitation Payments, and Gifts

Certain forms of external relationships or business practices may be labeled as means of enticement or as ways of influencing decision makers, both in relations with the public sector and with the private sector.

We disapprove of any actions that characterize bribes or facilitation payments for our processes.

You must not accept or offer any form of courtesy that aims to facilitate negotiations or any other type of favoritism, whether gifts, presents, hospitality, gratuities, awards, invitations to meals, favors, discounts on personal transactions, business or leisure trips, invitations to participate in events, or any other courtesies.

We emphasize that in our relationship with the public sector, it is prohibited to offer or receive courtesies to or from public officials or political office holders and their parties.

We encourage any practice that is not in accordance with the above guidelines to be reported to the Reporting Channel or the Bank’s PLD-FT area.

6.5. Information Security and Confidentiality

The Bank reaffirms its commitment to transparency in the processing of personal data of its customers, partners, and employees, guided by laws, regulations, and best practices dealing with banking secrecy.

The Information Security, Data Privacy, and Terms of Use Policy reflect the provisions of the General Data Protection Law (LGPD) on the processing of personal data and must be strictly observed by employees when collecting, recording, processing, handling, using, and maintaining the confidentiality of the data collected and stored.

Do not use social networks or software not provided by the Bank to carry out your professional activities.

All information is classified and segregated by subject and restricted to duly authorized employees.

It is essential to adhere to the following behaviors regarding Information Security:

• Do not share passwords, avoid writing them down, and if you do, record them in a place that only you have access to;
• Never leave your computer and/or printer “logged in” when you are away, even for a few seconds;
• Always use the shredder to destroy documents that are to be discarded;
• At the end of the working day and, especially, during prolonged absences, store documents, notebooks, and diaries, and lock drawers and cabinets;
• Notes, messages, and reminders should not be left on display or placed on walls, partitions, or computer monitors; and
• Do not spread information or negotiate based on rumors or unreliable data.

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

Banco Luso Brasileiro has a corporate policy on “Prevention of Money Laundering and Combating the Financing of Terrorism,” which establishes guidelines, principles, and responsibilities that must be followed to guide the conduct adopted in the conduct of any and all transactions carried out by the Bank.

We do not condone any conduct that violates current rules and regulations. Therefore, all employees, business partners, and service providers must undergo specific training for this purpose, provided by Banco Luso Brasileiro.

We adopt business and operational rules to prevent the Bank from being used to commit illegal or criminal acts (corruption, bribery, money laundering, fraud, among others).

6.7. Customer Relations

The Bank establishes that all dealings with customers and users must be guided by the principles of Ethics, Responsibility, Diligence, Legality, Ongoing Improvement, and Transparency in all phases of the relationship.

In customer relations, it is strictly prohibited to make false claims, engage in tied selling, omit information, or impose difficulties in fully and comprehensively understanding the products and services offered, as well as their conditions.

The products offered must be consistent with the profiles, financial condition, and needs of customers, following internal definitions and always clarifying any questions that may arise.

In case of doubt about how to act with the customer, the employee should consult their superior for guidance in conjunction with the Compliance and Internal Controls areas.

The Bank has a Client and Partner Onboarding Policy that covers employees, business partners, suppliers, and service providers, which establishes the practices to be followed.

6.8. Relationship with Third Parties

Our suppliers, service providers, and business partners must, in the exercise of their activities, adopt honest and ethical conduct, complying with applicable laws and regulations, as well as the provisions of this Code and the contractual obligations contained in the respective instruments throughout the contractual period.

We believe that transparency is fundamental in any type of relationship, so we expect our suppliers, service providers, and partners to act with dignity, transparency, loyalty, courtesy, mutual respect, and collaboration. We also expect commitment to the accuracy of the information provided, such as their professional training, information regarding the company’s economic, tax, and financial situation, and compliance with sustainable practices, among others.

Third parties are prohibited from promising, offering, authorizing, or giving, directly or indirectly, any payment or undue advantage to public, private, or third sector agents, Bank employees, or third parties related to them, in order to influence any act or decision to promote their own interests. Fraud of any kind is conduct repudiated by the Bank.

Intellectual property laws must also be observed when carrying out activities.

No conduct that favors or discriminates against any supplier, service provider, or business partner is permitted.

6.9. Use of Image and Press Relations

Do not participate in conventional or virtual media programs or give interviews, make public statements or statements to the press, disclosing any information about the Bank, without prior, formal and express authorization from the Executive Board and the Marketing department.

Any statement linked to the name of Banco Luso Brasileiro must be communicated in advance to your superior.

The use of any of the Bank’s trademarks is the sole responsibility of the Marketing Department and may only be used with the prior and formal authorization of the Executive Board.

If you are aware of any misuse of the trademark, please report it by sending an email to: comunicacao@lusobank.com.br

6.10. Precepts

All assumptions and guidelines regarding the Bank’s image are contained in the social media conduct manual.

In the exercise of professional activities, whether internal or external, conduct must be guided by high ethical standards and must comply with at least the following rules:

A. Comply with established rules, policies, processes, and procedures.

B. Cultivate cordiality in relationships and seek to resolve disagreements or misunderstandings with caution, respect, and acceptance.

C. Practice dialogue rather than imposing a point of view. Listen attentively and respectfully to the opinions of others, even if you disagree with them.

D. Help colleagues do a good job and guide those who seek your help with patience and interest.

E. Do not mislead coworkers or cause them any harm.

F. Do not present personal ideas, opinions, and preferences as if they were those of the Bank, its administrators, or employees.

G. Do not engage in offensive verbal, physical, or gestural conduct.

H. Do not initiate, reproduce, participate in, and/or encourage any rumors or slander about coworkers.

I. Respect the privacy of coworkers.

J. Communicate your mistakes and do not hide them, but be transparent, truthful, and strive to mitigate their consequences by learning from them.

K. Participate punctually, with dedication and responsibility in the education and training activities offered by the Bank.

L. Take care of safety in the workplace, facilities, resources, equipment, and work materials, and only use them for personal purposes in the event of an emergency that does not jeopardize the integrity of the Bank’s assets.

M. Adopt the principles of conscious consumption: do not waste water, energy, paper, plastic objects, office supplies, and all other resources available for the performance of your professional activities (in accordance with the Social and Environmental Policy).

N. Avoid financial imbalances, as they cause personal and professional losses.

O. It is prohibited to enter and remain on the Bank’s premises carrying firearms, as well as to show up at work with signs of intoxication and under the influence or in possession of drugs.

P. Take care of your personal image on social networks and media.

Q. Do not disclose Bank information or comment on everyday work situations on social media.

R. If you identify any situation that jeopardizes your integrity or that of other employees, do not hesitate to seek guidance from Bank representatives.

S. Any type of discrimination is prohibited, including—but not limited to—issues of gender, race, color, ethnicity, social class, religion, age, marital status, sexual orientation, nationality, political or philosophical beliefs, physical characteristics, or any other reason.

T. It is unacceptable to engage in, instigate, or tolerate moral or sexual harassment or any other act that causes risk or harm to the personal integrity of others.

6.11. Unsure about what decision to make?

If you are unsure about how to proceed on a particular issue in this Code, answer the questions on the right. If you answered no to any point, rethink and reevaluate your decision.

If you have any difficulties or questions, consult the Compliance and/or Human Capital area.

1. Am I making this decision based on the guidelines and directives of this Code and internal policies?

2. Will my decision help the Bank and the people who are part of it (e.g., customers, users, and employees)?

3. Can I justify my decision positively?

4. Am I considering the opinion and guidance of my manager and Senior Management?

5. Is my decision publicly acceptable?

7. CORPORATE ETHICS MANAGEMENT

The Ethics Committee will review all questions and complaints submitted to the Reporting Channel.

Everyone is required to follow the principles contained in this Code. It is also our duty to monitor compliance and report any cases of non-compliance.

It is essential that we pay attention to the Policies and Standards that establish the criteria for our work to always remain within regulatory limits. To this end, all employees must be familiar with and comply with the Bank’s guidelines, policies, and practices.

8. VIOLATION OF THIS CODE – CONSEQUENCES

The Bank reserves the right to take the measures it deems necessary in the event of non-compliance with the rules contained in this Code, including (i) warning, (ii) suspension, or (iii) dismissal.

If the Bank believes that this Code has been violated, it may require a remediation action plan, suspension, or termination of the employment, partnership, or relationship agreement, as detailed in our Conduct Program.

8.1. Applicability

If you become aware of any irregularity or conduct that may violate the provisions contained in this Code, you must report it to the Compliance or Internal Controls area or register it with the Bank’s Reporting Channel, so that it can be properly investigated and, if applicable, the appropriate sanctions and punishments can be applied.

The complaint will be handled and investigated confidentially, with anonymity guaranteed and an appropriate investigation process, and a follow-up protocol will be made available.

9. GUIDANCE AND REPORTING CHANNELS

For questions regarding the Code of Ethics and Conduct, Conflicts of Interest, Compliance, and Corporate Policies:

Contact:
compliance@lusobank.com.br

For questions regarding acts of corruption and bribery, money laundering, and related matters:

Contact:
pld.controlesinternos@lusobank.com.br

To report evidence of harassment, discrimination, workplace misconduct, and related matters:

Contact:
https://www.canalintegro.com.br/lusobrasileiro/%2BuIPiimcxzE%3D