ebanx compliance & corporate governance

Index

1. Introduction and Objectives

2. Scope and Users

3. Terms and Definitions

4. Directives

4.1. Implementation Responsibility

4.2. Risk management

4.3. Trainings

4.4. Disciplinary measures

4.5. Validity

5. Principles

6. Normative references

7. Publication and Distributing Policies

1. Introduction and Objectives

This Policy is an extension of the EBANX Code of Conduct. It aims to establish conduct, principles, guidelines and procedures for EBANX's socio-environmental practices, based on the principles of relevance and proportionality.

Through this, the objective is to ensure that the company's practices and strategies are aligned to safeguard the protection and propagation of sustainable socio and environmental development.

2. Scope and Users

This document applies to all ebankers, all products and all EBANX companies in all locations where EBANX is located, and which are performing professional activities, whether in the country where they are registered or abroad, including:

• Partners and shareholders

• Directors

• Employees

• Temporary employees

• Trainees

• Apprentices

Individuals, companies, service providers and business partners with EBANX are also required to comply with the rules set forth in this Policy.

3. Terms and Definitions

For purposes of this Policy, the following definitions apply:

• SERP: Social and Environmental Responsibility Policy;

• KYP: Know Your Partner - Procedure carried out by the Compliance area in order to learn about the nature and reputation of companies and agents with which EBANX does business;

• Conflict of Interests: Situation generated by the conflict between an individual interest (an ebanker, a supplier, a customer, among others) and a corporate interest, in which there is damage to EBANX;

• Socio-environmental responsibility: development of company practices and decision-making based on compliance with good socio-environmental practices, acting responsibly, promoting an ethical and transparent corporate environment and respecting applicable laws and regulations;

• Socio-environmental Risks: socio-environmental events that arise from uncertainties to which the Company is exposed, and which may negatively impact the objectives and value generation for EBANX and its customers;

• Risk assessment: that part of risk management that provides a structured process that identifies how objectives may be affected and analyzes the long-term risk of consequences and their likelihood before deciding whether further treatment is required.

• Risk & Control Assessment (RCA): is a continuous process that aims to map the main business processes, identify, assess and monitor their associated risks and controls, identify risk exposures and determine corrective actions. It is carried out by the areas that execute the processes, with the support and governance of the Internal Controls team;

• Impact: The negative result of a risk event on the company's objectives;

• CIPA: Internal Accident Prevention Commission;

• Greenhouse gasses (GHG): gasses that absorb a part of the sun’s rays and redistribute them in the form of radiation in the atmosphere generating the "greenhouse effect". The main gasses are carbon dioxide, methane, nitrous oxide, ozone and water vapor;

• ISO 20400: Provides guidance for organizations, regardless of their activity or size, on integrating sustainability into procurement.

4. Directives

4.1. Implementation Responsibility

The responsibility for implementing the PRSA rests with the EBANX board, employees and suppliers, observing the following Governance guidelines:

4.1.1. Board of Directors

The Board of Directors shall:

• The creation of measures and strategies for sustainability (initiatives to protect the environment and human rights) aimed at sustainable economic development, in accordance with applicable laws;

• Verification of any need to update or create more socio-environmental measures;

• Appoint those responsible for the Policy and for its internal and external disclosure.

4.1.2. Legal

The area of Legal shall:

• Acting in legal proceedings in which it is triggered as a result of conduct by customers, suppliers, employees and other partners related to socio-environmental damage;

• The implementation of socio-environmental obligation clauses, prevention of slave and child labor and sexual exploitation, respect for the environment and the fight against all forms of corruption;

• Exercise a consultative role to ensure that socio-environmental practices are in accordance with current legislation and regulations.

4.1.3. People

The People area is responsible for:

• Promote actions and recommendations to disseminate the PRSA guidelines in the EBANX culture, paying attention to them when choosing environments, in relationships with customers, employees, service providers;

• Encourage diversity and inclusion in the work environment, through selection, retention and relationship processes with ebankers;

• Implement socio-environmental programs, such as Young Apprentice and People with Disabilities;

• Promote social actions;

• Ensure the alignment of actions carried out with the communities in which EBANX operates, in accordance with PRSA guidelines, in a transversal and transparent manner.

4.1.4. Procurement

The Procurement team is responsible for:

• Analyze whenever possible environmental, social and governance criteria in purchasing processes and policies, as provided for in ISO 20400.

4.1.5. Global Risk & Compliance

The Global Risk & Compliance area is responsible for:

• Monitoring compliance with the SERP, monitoring any infringements;

• Promoting training for ebankers on the Policy, instructing on its compliance, conceptualizing and defining possible violations and promoting instruction on SERP guidelines;

• Carrying out the preparation of socio-environmental opinions when identified some risk or negotiation that may affect the socio-environmental issue;

• Implementing this Policy guidelines during KYP procedures;

• Establishing requirements and procedures in actions involving donations and sponsorship;

• Performing Due Diligence on clients and suppliers, natural and legal persons, including the verification of international and national news involving corruption, money laundering, fraud and socio-environmental scandals;

• Apply lists of prohibited and restricted products in onboarding and monitoring procedures;

• Implementing normative documents and processes to avoid Conflict of Interest;

• Defining a socio-environmental risk matrix;

• Including socio-environmental risks in the Risk & Control Assessment (RCA), establishing systems, routines and procedures to identify, classify, evaluate, monitor, mitigate and control environmental risk present in EBANX activities and operations;

• Establishing criteria for monitoring and evaluation of processes related to socio-environmental risk and perform monitoring;

• Observing compliance with the Policy in creating new services and products.

4.1.6. Internal Audit

Internal Audit area is responsible for:

• Periodically verify and evaluate the effectiveness of the implementation of the Policy and point out any opportunities for improvement.

4.1.7. Other Areas

It is up to all EBANX employees:

• Observe compliance with the Policy and the respective Laws and Regulations thatunderpin it;

• Prefer and use digital documentation, avoiding the printing and use of paper;

• Practice conscious consumption and effective use of resources inside and outside thecompany;

• Report, through the EBANX Helpline, non-compliance with the Policy and itsguidelines;

• In conducting business, take into account the recommendations made by the GlobalRisk & Compliance team.

4.2. Risk Management and Internal Controls

To monitor the occurrence of losses and socio-environmental damage and maintain adequate risk controls, EBANX has systems, routines and procedures that aim to identify, assess, manage and mitigate the socio-environmental risks of its operations and activities, which are defined on the basis of the principles of relevance and proportionality.

Risk management should consist of the following actions:

• Include socio-environmental risks in the Risk & Control Assessment (RCA), establishing systems, routines and procedures to identify, classify, evaluate, monitor, mitigate and control the environmental risk present in EBANX's activities and operations;

  
  

• Establish criteria for monitoring and evaluation of processes related to socio-environmental risk;

  
  

• Prior assessment of possible negative socio-environmental impacts to which the company is subject, paying attention to reputational risk;

  
  

• Define a socio-environmental risk matrix and, when a stakeholder presents a risk, forward the case to the Compliance team for in-depth analysis;

  
  

• Record data referring to actual losses related to socio-environmental damage. Such data consist of values, type of damage, location of damage, economic sector object of the operation. Furthermore, this data will remain recorded for a minimum period of 5 years;

  
  

• Implementation of procedures for the constant adaptation of socio-environmental risk management procedures to legal, regulatory and market changes.

4.3. Training

EBANX will promote training on the Policy, instructing about its guidelines and compliance, conceptualizing and defining possible violations to all ebankers directly involved in its implementation.

4.4. Disciplinary measures

Ebankers must be aware that failure to fulfill their responsibilities and non-compliance with this Policy may result in sanctions and disciplinary measures.

4.5. Duration

The review of this Policy shall take place on an annual basis and shall be approved by the Board of Directors and disclosed internally and externally to interested parties.

5. Principles

EBANX is committed to guiding its actions based on socio-environmental responsibility, guiding its activities and products to promote responsible economic and social development, inspired by the Sustainable Development Goals (SDGs), part of the 2030 Agenda launched by the United Nations (UN) in 2015, which defines the priorities and aspirations for sustainable development and seeks to unite efforts around objectives, targets and indicators.

The incorporation of the practices in this Policy will coincide with the specificities of the company's activity, respecting the applicable legal and regulatory guidelines and aiming to reduce any harmful socio-environmental impacts.

The guidelines agreed in this document were established in line with the relevance of the company's activities and operations and proportionally to their complexities. The actions that govern this Policy are integrated with the management of Social-Environmental Risks of EBANX activities and products, as well as based on the following principles:

• Promoting sustainable development in the economic, social and environmental context.

  
  

• Full respect for human rights, committing to promote an environment of integrity and social inclusion, while respecting the countries and people on which EBANX operates and others.

  
  

• Ethical and transparent positioning before the public and the authorities, acting effectively to curb acts that undermine this Policy.

  
  

• Respecting national and international norms and policies that cover the theme, aiming at the continuous improvement of our practices.

  
  

• The implementation of these principles that guide EBANX activity is present in its relationship with the community and the environment.

5.1. Society

EBANX is guided by the values of Knowledge, Commitment, Persistence, Orientation to Results and Big Dream, all of which are directed to achieve its mission of promoting access.

For the realization of these values in a sustainable way, it is indisputable the need to provide decent working conditions for all our employees, customers and suppliers, repudiating all possible discriminatory acts that are contrary to our Code of Conduct and other policies.

In line with these guidelines, EBANX has a team responsible for the governance and monitoring of the Business Continuity Plan and has an Internal Commission for Accident Prevention (CIPA), aimed at mitigating accidents and disseminating improvements in the well-being of our employees.

We value respect for our customers, employees and suppliers, we implement practices that safeguard transparency and impartiality in our activities. Thus, through our wide variety of policies, such as our Code of Conduct, our Anti-Bribery and Anti-Corruption and Anti-Money Laundering Policies, we aim to prevent, detect and remedy any acts that are not in line with our principles.

In this way, we direct the propagation of a culture of respect and integrity in the corporate environment. Compliance with such recommendations may even lead to the termination of the relationship with customers, suppliers or employees who practice conduct contrary to our principles and values.

In addition, we safeguard corporate responsibility, committing to maintain a relationship with the authorities based on transparency, promoting good practices with regulatory bodies and acting in accordance with the relevant laws and regulations.

5.1.1. Culture and Education

The EBANX values mentioned in the previous topic are intended to carry out the company's main mission, to provide access. Our performance as a company transcends our performance objectives in the market, we seek to provide access in the broadest sense of the word.

As this is our mission, we develop various cultural and educational actions that aim at social development in various ways.

Some of the practices adopted to promote sustainable development are:

• Constant mobilization of social actions in communities close to the regions where EBANX has operations;

• Promotion of events and promotion of culture;

• Development of projects to reduce the absence of women in the technology market;

• Holding events that seek to discuss and disseminate knowledge on topics relevant to society;

• Partnerships and donations with NGOs and associations, promoting multiple fundraising campaigns;

• Interaction with educational institutions and universities;

• Employment opportunities for minors apprentices and persons with disabilities;

• Support to organizations that promote the defense of human rights of LGBTQIA+ people, social inclusion through sport, the defense of women’s rights and equality.

5.2. Environment

EBANX is committed to propagating a corporate environment that values the preservation of the environment, promoting sustainable practices, which are constantly evolving.

The following practices are some examples of how EBANX manages socio-environmental impacts and risks aimed at preserving the environment:

• Preference for the adoption of documents and communications in digital format thus reducing paper and toner consumption;

• Selective waste collection for recycling;

• Automation of taps to avoid water waste;

• Awareness for sustainable consumption in the office;

• Encouragement of conscious mobility;

• Measuring and mitigating the greenhouse gas emissions caused by the operation;

• Monitoring and circularity of electronic equipment used by ebankers.

6. Normative references

Due to its institutional character, the Social and Environmental Responsibility Policy is correlated to the following company documents:

• COD-002-GR&C - Code Of Conduct;

• POL0020117 - Anti-Money laundering and counter financing of financing of terrorism policy;

• POL-011-GR&C- Anti-bribery and Anti-corruption Policy.

7. Publication and distribution of policies

Any new policy or modification of an existing document must be made available to all interested parties.

Policies are available for consultation, by ebankers, on MyEBANXLife, in the “Policies & Standards” section.

Public documents can be found on EBANX websites.