Movida Participações S A : Código de Conduta

Code of Conduct

2024February

1 - INTRODUCTION

DEAR SIR/MADAM:

It is with great satisfaction that we present the Code of Conduct for MOVIDA and our controlled companies.

Consisting of a set of guidelines that reect the Company's values (Customer, People, Simplicity, Owner's Attitude, Sustainability and Prot) and the commitments

undertaken with the laws applicable to the business. Our Code describes our daily guidelines and values that guide our way of being and doing business and that must be followed by all of us: employees, third parties, business consultants and customers.

MOVIDA's Code of Conduct, together with our Values Guide and the Company's guidelines, denes what is essential for us to act in an integral, ethical, and transparent manner, in compliance with the legislation in force and the Company's policies, knowing that any action contrary to what is described in this document is contrary to the values and objectives of MOVIDA and all the Group Companies, and in this case will be dealt with appropriately.

Therefore, we must be fully committed to complying with this Code and its disclosure to all audiences related to our business. We believe that the guidelines described only become a culture and a habit if they are put into practice through attitudes and examples.

Any doubts about this Code must be claried with the Company's Internal Control, Risk, and Compliance Department, through the communication channels mentioned here.

Read, share, and Practice! Gustavo Henrique Paganoto Moscatelli

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CONTENTS

MOVIDA ORGANIZATIONAL IDENTITY (Our Principles and Values)	Page 04
Non-negotiable	Page 05
GENERAL GUIDELINES	Page 08
Compliance with laws and regulations
Human rights Page	Page 08
Labor relations (child labor, compulsory or forced labor, moral harassment,

sexual harassment and discrimination, promotion and defense of equality and labor rights) Page 08

Employee conduct	Page 09
Anti-corruption	Page 10

INTERNAL ENVIRONMENT

Internal relationship	Page 12
Health and Safety	Page 12
Conict of interest	Page 13
Information integrity	Page 14
Donations and sponsorships Freebies, gifts, entertainment, and hospitality	Page 15
Freebies, gifts, entertainment, and hospitality	Page 15

EXTERNAL ENVIRONMENT

Customer relations/Shareholder relations	Page 16
Relations with the union	Page 16
Relations with suppliers, service providers, partners, and business consultants	Page 16
Relations with the public sector	Page 17
Relations with competitors	Page 18
Media relations	Page 19
Relations with the environment	Page 19
Community Relations	Page 19
COMPLIANCE RESPONSIBILITIES AT MOVIDA	Page 21
FAILURE TO COMPLY WITH THE CODE OF CONDUCT AND OTHER INTERNAL RULES	Page 21
MEANS OF COMMUNICATION	Page 21
Compliance Function and Transparency
About the Reporting Channel	Page 22
ETHICS AND COMPLIANCE COMMITTEE	Page 23
AUDIT COMMITTEE	Page 23
GLOSSARY	Page 23
CONFLICT OF INTEREST QUESTIONNAIRE	Page 26
TERM OF COMMITMENT AND RESPONSIBILITY	Page 27

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2 | MOVIDA Values

CUSTOMER

It is the reason for our business existence.

We listen to our customers to understand and meet their needs. We are always looking for opportunities to add value and growth for our clients, and we foster relationships of trust because we know that is the best way to retain contracts and continually generate new business.

PEOPLE

That's what

dierentiates us!

Our people enable us to achieve our goals. It is through our people that we live our values and deliver the best services to build customer loyalty and therefore grow. When businesses grow, our people grow too.

SIMPLICITY

Be simple to be agile!

An uncomplicated way of being and acting.

OWNER'S ATTITUDE

If it were mine and for me, would I do it this way?

We do business with depth and a vision of the whole. We are always willing to improve, doing more with less. We work with responsibility, commitment, and cost discipline.

SUSTAINABILITY Every attitude counts!

Economically viable, ecologically sound and socially fair attitudes.

PROFIT

A mission of all!

It is essential for the sustainable growth and development of our business and our people, and for the strengthening and maintaining of our business relationships with our customers.

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3 | NON-NEGOTIABLE

NONNEGOTIABLE

One of Movida's main objectives is to select, train, and develop people who are in line with our Culture and Values and who act in accordance with the Movida Code of Conduct, knowing and replicating the practices that are NON-NEGOTIABLE for us.

Prevent and correct UNACCEPTABLE behavior by being vigilant and proactive. Therefore:

1. DO NOT DISCRIMINATE:

• Practice any type of discrimination, such as race, color, age, religion, social class, position, sexual orientation, political and/or trade union aliation or people with disabilities.
• Treat with disrespect and/or harm someone due to dierences in beliefs, ideas, and thoughts.

2. DO NOT HARASS MORALLY AND/OR SEXUALLY:

• Harassment of any nature or disrespectful treatment towards anyone, including employees, customers, suppliers, business partners, using threats, verbal and physical violence, isolation, stalking;
• Embarrassing employees in the work environment or because of it, demanding sexual and romantic favors from them.

3. DO NOT DISRESPECT THE COMPANY'S RULES OF CONDUCT:

• Failure to comply with the conduct guidelines required by the Company, mainly those set out in our Code of Conduct, Anti-Corruption Policies and Sustainability Policy;
• In any way, cause nancial and image losses to Movida, our customers, suppliers, and service providers, including through obtaining improper advantage, lack of transparency in the intentional provision of information, manipulation of results, and accountability or benet from conicts of interest.

4. DO NOT COMMIT ACTS OF PUBLIC AND/OR PRIVATE CORRUPTION:

• Oering, promising, or accepting improper advantages (prizes, money, goods, gifts), to benet oneself or a third party, to obtain or retain business, whether in the Public sector (public ocials, politicians, civil servants) or in the Private sector Pay bribes, directly or indirectly;
• Violate the Company's Anti-Corruption Policies.

1. DO NOT KEEP CONFLICT RELATIONSHIPS:

• Taking advantage of, romantic or anity relationships with employees and third parties and/or public ocials to obtain improper advantages to the detriment of the Company.
• Failure to notify and/or update the Internal Controls, Risk and Compliance Department of the existence of a conict of interest.

1. DO NOT VIOLATE HUMAN RIGHTS:

• It is prohibited to engage in child labor, slavery, and/or any other conduct that may be detrimental to the dignity of any individual.

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4 | CODE OF CONDUCT

TO WHOM DOES THE CODE APPLY

This Code applies to MOVIDA S/A and all its Controlled and Aliated Companies and consortium members, subject to their respective agreements, hereinafter referred to as MOVIDA, Companies or Company. Consequently, its application extends to its directors, managers, employees, interns, and trainees, as well as service providers, suppliers, business partners, consultants, and third parties in general. MOVIDA values ethics in all its relationships and therefore seeks companies, third parties, customers, and employees who understand its way of doing business and are committed to observing the highest standards of ethics and integrity.

The guidelines contained in this document are based on the laws applicable to the business sector, to the activities and to the relationships established by MOVIDA, and in particular on the following

• Brazilian Anti-Corruption Law (Law 12,846/13) and Decree 11129/2022;
• Brazilian Law Against Misconduct in Public Oce (Law No. 8,429/1992);
• Brazilian Money Laundering Law (Law 9,613/98, amended by Law 12,683/12);
• Brazilian Competition Law (Law 12,529/11);
• Brazil Penal Code (Law 2,848/40);
• Consolidation of Labor Laws (Decree-Law 5452/43);
• The Brazilian Statute of Children and Adolescents (Law No. 8,069/90)
• Brazilian Law on Bidding (Law 8,666/93, Law 10,520/2002, Law 12,462/2011 among others);
• Brazilian Consumer Code (Law 8,078/90).

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General Guidelines

2024February

5 | GENERAL GUIDELINES

5.1. GENERAL GUIDELINES

MOVIDA understands that the principles described below must be incorporated directly into the procedures and activities of all areas and units of the Company, without exception, as they represent the basis of compliance in the corporate environment and enable the dissemination of this ethical culture to all those who are subject to this Code of Conduct. The Company's guidelines are:

5.2. COMPLIANCE WITH LAWS AND REGULATIONS

Compliance with the laws and regulations applicable to MOVIDA's activities is essential to the success and continuity of the business. All employees and third parties in general are expected to know and fully comply with all laws, regulations, self-regulations and policies applicable to the Company's business, to adopt the highest ethical standards and to refrain from any action that could result in the Company being held liable.

5.3 HUMAN RIGHTS

Respect for human rights must be guaranteed to all individuals who interact with MOVIDA, regardless of race, sex, sexual orientation, social class, nationality, ethnicity, language, religion, political/union option, disability, or any other characteristic. MOVIDA prohibits any form of discrimination or disrespect, as well as any behavior that could be harmful to the dignity of any person.

5.4. EMPLOYMENT RELATIONSHIP

5.4.1. Child Labor

MOVIDA does not tolerate any form of child labor and rejects any behavior, directly or indirectly, linked to this type of violation.

5.4.2. Compulsory or Forced Labor

Compulsory or Forced Labor. MOVIDA does not tolerate forced labor and prohibits any non-compliance with this position within the Company or any indirect benet arising from the adoption of such illegal practices by all those covered by the application of this Code as described above.

5.4.3. Moral Harassment, Sexual Harassment, and Discrimination Practices

MOVIDA prohibits any type of discrimination (for example, but not limited to, race, color, age, religion, social class, position, sexual orientation, political/union option, or people with disabilities

• PWD). Acts of disrespect towards employees will not be tolerated. Likewise, MOVIDA prohibits any type of harassment, exploitation, abuse, or violence against physical and mental integrity.

These are just a few examples:

• Pressuring employees to perform personal services for the benet of any other employee;
• Morally and/or sexually harassing employees and third parties;
• Discriminate employees and third parties in relation to association with unions, religion, civil society, and political parties;
• Disqualify, insult, harass or humiliate, publicly or privately, any employee, third party or person who is on Company premises or at an outside event while acting on behalf of the Company;
• Demanding unattainable goals or demanding that business/projects be completed "at any cost";

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• Threatening in any way or for any purpose;
• Use nicknames to refer to employees against their will or in a humiliating and derogatory manner;
• Present the work or ideas of colleagues without giving them credit.

5.4.4. Promotion and Defense of Equality and Labor Rights

Valuing people is one of MOVIDA's fundamental principles. Therefore, the Company demands fair, ethical, and respectful treatment among its employees and in its relationships with its custom- ers, suppliers, service providers, and third parties. MOVIDA implements tools that promote equality and the well-being of its employees, oering professional qualication courses, training and development, and the Canal Ligado em Você (Connected to You Channel) (0800 773 5333), which aims to promote the health, well-being, quality of life and personal and professional satisfaction of all employees and their dependents.

The company has areas accessible to people with special needs and is constantly seeking to improve its infrastructure and promote measures to help these people enter and remain in its activities.

We are committed to complying with labor laws and agreements signed with unions, guaranteeing freedom of association and dialogue, and providing decent wages based on local market assessments.

5.5. EMPLOYEE BEHAVIOR

MOVIDA expects its employees to enjoy the work entrusted to them and to be respectful, generous, and polite at the workplace and to all those who are part of their daily lives. This attitude is an armation of the company's values and should therefore be the focus of its employees.

In addition to the basic attitude described above and the other guidelines set forth in this Code on each specic matter, it is important to highlight examples of some actions by employees and third parties who provide services on the Company's premises, namely:

• Selling products and/or services on the compa- ny's premises, including after hours;
• Using alcoholic beverages and drugs on Compa- ny premises and during working hours, and working in an altered state due to the use of these substances;
• Carrying and using weapons of any kind on the Company's premises;
• Using cell phones, tablets, handhelds and/or desktop computers to access photos, videos, various documents, social networks, websites and/or applications that are not directly related to the employment agreement during the workday. Cell phones, as a telephone device, must be used with common sense and preferably for emergen- cies;
• Using Company-owned vehicles for personal purposes without the prior authorization of the executive ocer responsible for the department;

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• Using the Company's assets and property in a misappropriated or demeaning manner;
• Using Company's computers to post personal pictures and text on social media;
• Disclosing any Company information to nonem- ployees, except that which is already made public. The Company is also concerned with the behavior of the employee in the external environment, as he/she carries the Company's image in all his/her actions. The following are important points that employees should pay attention to:

5.5.1 Image

MOVIDA guarantees the right to freedom of expression to its employees, under the terms guaranteed by the Federal Constitution and does not support any form of restriction of this right.

It's also true that, according to the Brazilian Federal Constitution, this right goes hand in hand with everyone's responsibility for the way they express themselves and the way they behave at work and outside.

It is important to emphasize that even in the external environment, the employees' image is associated with that of the Company; therefore, although the right to freedom of expression is guaranteed, everyone must adopt a righteous and respectful attitude inside and outside the Company at all times in any environment, whether virtual or not. Here are some recommendations on how to behave in dierent situations to avoid unnecessary and damaging exposure for everyone:

• Use discretion when conducting professional or company-related business in public places and at personal events;
• Do not conduct private business in environments that are integrated with the company's public and customer service;
• Do not publish images of other employees in any media without their prior consent;
• Avoid the use of the badge and/or the company uniform outside of working hours in an external

environment that is negatively associated with the image and brand of the Company;

• When expressing personal opinions, explicitly state that you do not represent MOVIDA

5.5.2 USE OF UNIFORMS, BADGE, AND SAFETY EQUIPMENT

MOVIDA provides uniforms and badges to its employees, which must be used for identication and access to the Company's premises. The following are exempt from this requirement: the audit and legal areas, and the positions that make up the management and board of executive ocers.

Regarding the use of uniforms, the employee is responsible for:

• Use it appropriately, only for the purpose for which it is intended;
• Be responsible for the care and maintenance of the uniform and shall not alter or modify the shape, form or appearance of the uniform;
• Notify the Company of any changes that make it unsuitable for use;
• Follow the guidelines for proper and

presentable use.

When required for the position and in accordance with current legislation, MOVIDA and/or its companies will also provide PPE (Personal Protective Equipment), the use of which is also mandatory and the care described above will apply to it.

Each employee is expected to be aware of the importance of the consequences of his or her behavior, whether in the workplace, in the external environment, or with colleagues.

5.6. ANTICORRUPTION

The challenge for the company is to control the performance of all its employees and to supervise subcontractors, considering the dierent segments of activity in the national and international markets. Continuous guidance, training and transparency are tools used by the Company to

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