Anti-Corruption and Anti-Money Laundering Policy

Tradsul is committed to conducting its business with the highest standards of honesty, integrity and transparency. We recognize that corruption and money laundering harm society and the integrity of the market. This procedure sets out our unwavering commitment against these practices, in line with applicable legislation and corporate best practices.

To establish clear guidelines to prevent acts of corruption and money laundering within the organization and in its transactions with third parties. This includes:

• Identifying risks;
• Implementing preventive controls;
• Conducting regular training;
• Maintaining an effective and confidential whistleblowing channel.

This procedure applies to:

• All Tradsul employees, including senior management, managers and staff;
• Consultants, agents and suppliers acting on the company's behalf;
• Any party that has a business relationship with Tradsul.

4.1. Prohibition of Corrupt Practices

It is strictly prohibited to:

• Offer, promise, give or accept a bribe;
• Request or authorize any undue advantage.

4.2. Relationships with Insurers and Policyholders

Must be conducted transparently and ethically, avoiding any attempt at undue influence.

4.3. Donations and Contributions

Must be lawful, ethical and properly recorded, following internal policies.

• Receiving money, gifts or favors from companies under analysis or from any party with an interest in the cases handled by Tradsul.
• Altering reports or technical studies in exchange for any form of payment or personal benefit.
• Obtaining financial gain or advantages from the work performed beyond the salary and benefits regularly agreed with the company.
• Accepting trips, meals or other favors that may influence, or appear to influence, the impartiality of analyses and decisions.
• Maintaining financial or personal relationships with parties directly involved in the cases under analysis that may give rise to a conflict of interest.
• Using confidential information obtained in Tradsul's cases for personal gain or the gain of third parties.

Any breach of these prohibitions will be met with strict disciplinary measures, including dismissal for cause and legal action, in accordance with applicable law.

6.1. Identification and Verification

Implement procedures to verify the identity of clients and the origin of their funds.

6.2. Transaction Monitoring

All financial transactions will be analyzed to identify possible signs of money laundering.

6.3. Suspicious Transaction Reporting

Suspicious transactions will be reported to the competent authorities, in accordance with current legislation.

Tradsul will provide regular training on:

• Anti-corruption legislation;
• Money laundering prevention;
• Identifying and reporting violations.

Employees will be instructed to act in accordance with this procedure and applicable legal standards.

The whistleblowing channel is a confidential means of reporting violations: antifraude@tradsul.com.br.

Reports will be handled confidentially, in accordance with the law and ensuring protection for the whistleblower.

Compliance will be checked regularly, and any violations are subject to:

• Disciplinary measures (including dismissal);
• Legal consequences, in accordance with current legislation.

This procedure will be reviewed annually to remain aligned with the law and governance best practices.