Ethics and integrity

1. Purpose

The 2Secure Technology Code of Ethics and Conduct reflects our commitment to integrity, responsibility, and transparency. This document establishes the principles that guide our relationships with clients, employees, partners, suppliers, government entities, competitors, regulatory authorities, and society as a whole.

Our mission is to conduct business ethically, in compliance with applicable laws, and with respect for people and the environment in which we operate.

2. Scope

This Code applies to:

• Shareholders, directors, and leaders;
• Employees and interns;
• Third-party contractors, partners, and suppliers;
• Any individual acting on behalf of 2Secure Technology.

3. Principles and Expected Conduct

3.1 Relationships with Clients and Partners

• Act with respect, transparency, efficiency, and quality.
• Maintain confidentiality regarding sensitive information.
• Reject any practice involving favoritism or undue advantage.

3.2 Work Environment

• Promote a healthy, respectful, and collaborative workplace.
• We do not tolerate harassment, discrimination, prejudice, or any form of moral, physical, or verbal abuse.
• We value continuous professional development.

3.3 Integrity in Business Relations

• Strictly comply with contracts, laws, and regulations.
• Strongly oppose any practice involving bribery, corruption, money laundering, or financing of illicit activities.
• Act ethically, including in competitive situations.

3.4 Relations with Government Authorities and Regulators

• Our interactions with public authorities are guided by legality, impartiality, and integrity.
• We reject any attempt to influence decisions through undue advantages.
• We strictly comply with deadlines, requirements, and regulatory obligations.

3.5 Privacy and Data Protection

• We respect data privacy in full compliance with the Brazilian General Data Protection Law (LGPD) and other applicable regulations.
• We protect confidential information against unauthorized access and misuse.

4. Prohibited Conduct

• Bribery, corruption, or any unlawful practice.
• Moral or sexual harassment, or any form of discrimination.
• Improper use of privileged or confidential information.
• Practices that may create conflicts of interest, including seeking personal benefit from one’s position within the company.
• Use of company assets for personal or illegal purposes.

5. Reporting Channel and Handling of Irregularities

• 2Secure Technology provides a secure and confidential reporting channel, with the possibility of anonymity, for reporting misconduct, inappropriate behavior, and irregularities.
• All reports are treated seriously, respectfully, confidentially, and without any form of retaliation.
• Reporting link: https://forms.gle/yLFtTBNfYc1chaQV9

6. Penalties

• Failure to comply with the provisions of this Code may result in disciplinary measures, ranging from warnings to termination for cause, in addition to any applicable legal actions.

7. Commitment

By being part of 2Secure Technology, each individual commits to:

• Acting ethically, responsibly, and with integrity.
• Complying with this Code, applicable laws, and company values.
• Contributing to a healthy professional environment and to the sustainability of the business.

Effective Date: This Code shall enter into force on January 1, 2026, and shall be reviewed periodically whenever necessary, or at least every 24 months.

1. Introduction

2Secure Technology maintains a non-negotiable commitment to ethics, transparency, and compliance in all of its corporate activities. This Integrity Program was developed with the purpose of preventing, detecting, and addressing potential misconduct, fraud, irregularities, and unlawful practices, especially in interactions with public administration entities, both in Brazil and abroad.

Our commitment is to foster an ethical corporate environment free from practices that could compromise the company’s reputation, while ensuring compliance with applicable laws and regulations.

2. Program Objectives

The main objectives of the 2Secure Technology Integrity Program are:

• To prevent, identify, and correct acts of fraud, misconduct, and unlawful practices.
• To promote an organizational culture based on ethics, transparency, and compliance.
• To mitigate corruption risks and ensure integrity in relationships with public officials and business partners.
• To ensure corporate practices aligned with integrity, accountability, and transparency at all levels of the organization.

3. Organizational Structure and Responsibilities

Integrity Program Officer

• E-mail: legal@2secure.com.br and dpo@2seclabs.io.

Governance Structure

Ethics and Compliance Committee

• Oversees the implementation and continuous development of the Integrity Program.
• Receives periodic reports from the Integrity Program Officer and defines strategic actions to strengthen the culture of integrity.
• Evaluates and deliberates on improvements and updates to the program.

Integrity Program Officer

• Responsible for the implementation, management, and continuous improvement of the program.
• Conducts analyses and investigations regarding reports, misconduct, and potential non-compliance issues.
• Ensures that all investigative procedures respect due process and the right of defense.

Compliance Team

• Provides technical and operational support in implementing the program’s guidelines.
• Performs ongoing monitoring to ensure compliance with internal policies and legal requirements.
• Conducts training sessions, awareness campaigns, and guidance on ethical and integrity practices.

4. Policies and Procedures

4.1. Interactions with Public Officials

Scheduling and Registration

• All visits and interactions with public authorities must be previously authorized and properly documented.
• Records must include details such as date, time, participants, location, and meeting agenda.

Conduct During Interactions

• All employees are required to act with honesty, transparency, and respect in any interaction with public entities.
• It is strictly prohibited to offer, promise, or grant any undue advantage to public officials.

Post-Interaction Reporting

• Every interaction must be formally documented through a report describing the matters discussed and any commitments made.

4.2. Detection and Response Mechanisms

Reporting Channel

• A secure, confidential, and, if desired, anonymous reporting channel is available for reporting suspicious conduct, fraud, or violations of company policies.
• The reporting channel guarantees full protection against any form of retaliation against whistleblowers.
• Access: https://forms.gle/yLFtTBNfYc1chaQV9

Investigation Process

• Every report is initially assessed by the Integrity Program Officer.
• When necessary, a formal investigation will be conducted with support from the compliance team, ensuring impartiality throughout the process.

Corrective Measures

• Investigation conclusions may result in disciplinary actions, adjustments to internal processes, and communication of findings to the Ethics and Compliance Committee.

4.3. Education and Awareness

Training

• Continuous training is provided to employees on integrity, anti-corruption legislation, and corporate best practices.
• Specific content will be offered to teams that interact directly with public sector entities or operate in sensitive areas.

Internal Campaigns

• Regular engagement campaigns are promoted to reinforce ethical and compliance values.
• Educational materials, guidelines, and relevant communications regarding the Integrity Program are distributed internally.

5. Monitoring and Continuous Improvement

The 2Secure Technology Integrity Program is dynamic and undergoes continuous reviews and improvements based on market best practices and regulatory requirements.

Audits

• Internal and external audits will be conducted periodically to assess adherence to the program’s principles and identify improvement opportunities.

Monitoring Reports

• Periodic reports will be prepared for the Ethics and Compliance Committee, containing information regarding reports, investigations, training activities, and the evolution of the program.

Feedback Collection

• The company encourages employee participation in the continuous improvement of the program through suggestions and ongoing evaluations.

6. Effectiveness

This Integrity Program shall enter into force on January 1, 2026, and shall be reviewed annually, or whenever necessary due to legislative, regulatory, or strategic changes.