COSMOS ADVISORS – BEST PRACTICES

The Company’s Best Practices was implemented based on our values, ideals and business perspectives, respecting the balance and solidity of our brand, and aligning the best corporate governance and market practices with new global values.

It establishes a set of guidelines and guidelines that will guide the conduct of our employees, including the Compliance Officer, and will solidify the standards and rules of reputable and ethical behavior that guide the Company’s business conduct in all its actions.

2. COMPANY VALUES

The Company has in its values the basis that makes it a reference in transaction advisory services. For this, it created a solid base of knowledge, relationship and service portfolio that underlies its entire capacity to generate benefits for customers, optimizing operations and investments. It has a true chain of values that guide the behavior, attitudes and decisions of people in the exercise of their responsibilities, namely:

• Respect – All our relationships must be permeated by respect for people, customers and Cosmos’ values.
• Ethics – Professional ethics to build respectful and lasting relationships with our people, customers and suppliers.
• Diversity – Diversity for building and maintaining an environment that is abundant in terms of culture, knowledge and respect.
• Versatility – We must be aware of advances and changes in the market in which we operate, especially in relation to people, customers and suppliers so that we can adapt quickly, maintaining the quality of our services and, consequently, our competitiveness.
• Maximum quality in service provision – We are a reference for our customers in terms of quality. We must (i) understand and adapt to our customers’ needs (ii) be collaborative, proactive, insightful and relevant to our customers (iii) be extremely discerning and detail-oriented during the review and review processes and (iv) be punctual in the deliveries of our work;
• Clear communication – Internal communications must be clear and objective so that the entire team understands the company’s objectives, so that everyone is converging in the same direction. External communications must be done in a clear and transparent way, but with common sense and cordiality.
• Engagement – Supporting Cosmos’ values and culture is fundamental to form and maintain a team willing to dedicate itself, get involved and interact in our work environment. Therefore, we must encourage and provide practices such as: (i) timely feedback, (ii) recognition and appreciation of our team, (iii) training, (iv) transparency about the company’s direction and (v) opening of new growth opportunities ;
• Qualification of our people – We must all encourage and participate in the qualification of our team through formal and on the job training. Training can provide career development for our employees, allowing them to occupy more prominent positions with better remuneration.

3. COMPLIANCE OFFICER RULES

1. assess the effectiveness and compliance of the Company’s internal controls and compliance risk management process;
2. assess whether the recommendations for improvements in internal controls have been properly implemented by the Company’s management;
3. certify the compliance of procedures with applicable rules, regulations and laws;
4. monitor the policies, procedures, responsibilities and definitions relevant to the operational and compliance risk management structure;
5. review and propose to the Company’s management to update this Manual, when necessary; and
6. regularly position the Company’s management on the activities and make the recommendations it deems appropriate.

4. CUSTOMERS, SUPPLIERS AND OTHERS

The Company’s mission is to contribute, today and in the future, to the success of our customers and our businesses, offering services based on quality, innovation and excellence. Therefore, we rely on the development of respectful, cordial, professional and transparent relationships with all our customers and suppliers.

Compliance with the rules of conduct provided for in this Manual must be ensured to guide the relationship with the Company’s customers, following the initiatives for

action and excellence. Therefore, we rely on the development of respectful, cordial, professional and transparent relationships with all our customers and suppliers.

Compliance with the rules of conduct provided for in this Manual must be ensured to guide the relationship with the Company’s customers, following the initiatives to assess the issues of employee conduct, information security and the offer of products and services, mitigating the inherent risks of the relationship with customers.

Suppliers are carefully selected in search of the best cost-benefit ratio, in a confidential and confidential manner. The Compliance Officer must be informed of any behavior that does not respect the criteria established by the Company and any illegal, unethical or inappropriate conduct in quotation processes or the acquisition of goods and services.

It is prohibited to hire suppliers that use slave, forced, compulsory, child labor or any other form of exploitation that violates human rights.

The relationship with governmental or non-governmental public entities is not differentiated, respect and transparency permeate the relations between such entities, our Compliance Officer and all other employees are instructed not to accept and not condone acts of corruption.

5. ANTI-CORRUPTION POLICY

The Company’s Good Practices Manual incorporates and complies with the provisions of Law No. 12,846, of August 1, 2013 (“Anti-Corruption Law”), in order to guide all its employees in complying with the existing guidelines in this Good Practices Manual Practices and the Anti-Corruption Law, including attributing the responsibility to each one of investigating and getting to know all agents, consultants, distributors, customers and suppliers with which they do business and describing what must be done to prevent fraud and corruption, mitigate risks and fight them effectively.

6. CONFLICT OF INTEREST

A conflict of interest occurs when private and individual interests overlap with those of the Company. It arises when acts are committed with the aim of satisfying one’s own and/or third parties’ interests, causing damages or losses to the company or improperly influencing the normal course of operations.

It is everyone’s duty not to use their position or the Company’s name to obtain personal benefits. It is essential not to accept, directly or indirectly, resources from any person or entity that has or is interested in creating business relationships with the Company. In case of doubt, submit to the Executive Board all occurrences that may generate a conflict of interest for clarification and validation, if applicable.

7. CONDUCT

Company employees must base their conduct on good social responsibility practices, complying with current legislation, seeking improvements in their management system and always respecting human rights.

The Company’s management is based on respect, discernment, transparency, responsibility and commitment to the work. Conduct incompatible with such principles and with the Company’s policies and values, including, but not limited to, differentiation by social, financial or hierarchical position, intimidation and abuse against the moral and physical integrity of any person, abuse of power, attitudes that characterize moral or sexual harassment, discrimination based on ethnicity, gender, age, marital status, religion, sexual orientation, special needs, nationality, political conviction or any other form of prejudice, disrespect, acts of corruption or any other unlawful act, not will be admitted or tolerated.

The Company does not recognize and does not accept conduct deemed illegal, unfair, anti-competitive or unethical, as well as apparent misconduct or impropriety on the part of anyone working for, or representing the Company. We value healthy competition, free from practices that violate current legislation and harm competition.

The Company values respect and preservation of the environment and encourages sustainable development. The Company’s employees are expected and required to comply with environmental legislation.

8. SAFETY

Each professional must enjoy a safe, healthy work environment free from any type of discrimination and prejudice. To this end, the Company adopts good safety and quality of life practices at work and expects its employees to act in accordance with such practices.

The consumption of illegal drugs and other narcotics while carrying out professional activities is strictly prohibited.

All activities must be carried out in full compliance with its stipulations, as well as in compliance with applicable legislation, rules and programs.

Employees will be held liable for any damage or loss, direct or indirect, caused to the Company or third parties

for any reason arising from or related to non-observance or infringement of current legal provisions, regulations or positions.

9. INTELLECTUAL PROPERTY

Intellectual and industrial property developed internally or externally by the Company’s employees and/or collaborators as part of their work activities are the property of the Company, regardless of their nature, and must be protected against unauthorized disclosure.

The Company prohibits the copying, reproduction, transmission, distribution or use of the same for private purposes or transfer to third parties. Likewise, the intellectual property rights of third parties must be respected. The use of confidential data of third parties by inappropriate means or unauthorized disclosure is prohibited.

10. CONFIDENTIAL INFORMATION

During or outside working hours, Company employees may have access to confidential information, including, but not limited to, the list of customers and suppliers, production and marketing values, pricing and know-how criteria, accounting information and financial, personal data of employees, and other information considered confidential and privileged (“Confidential Information”). Such Confidential Information must be treated confidentially, stored securely and must never be shared with third parties who may illegally benefit from the inappropriate and unfair use of this information. Thus, Compliance employees undertake to:

• Not reveal Confidential Information to any third party or any person who, due to their functions, should not know them;
• Do not use Confidential Information for your own benefit or that of third parties;
• Immediately cease using such information in the event of termination or termination of the contractual relationship with the Company, returning lists, files, reports, records and any other types of documents containing Confidential Information and destroying copies of files with such information.

11. NON-COMPLIANCE WITH THE INTERNAL REGULATION

Failure to comply with the terms and provisions of this Manual will result in appropriate disciplinary action, such as a verbal or written warning, suspension, dismissal and/or termination of employment, depending on the seriousness of the violation.

Each and every employee must immediately inform the Compliance Officer of any observed violation, and the omission in the face of possible violations will also be considered unethical conduct and will entail the same sanctions applicable to other occurrences.

Failure to comply with the Anti-Corruption Law will result, in addition to the appropriate disciplinary measures, in serious civil and criminal penalties for the individual involved.

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