I. Introduction AIOTI Tecnologia Ltda. reaffirms its commitment to integrity, ethics, and transparency in all its activities. This Anti-Corruption Policy establishes guidelines to ensure that all employees, partners, and third parties acting on behalf of the Company meet the highest standards of conduct and help prevent and combat corruption.
II. Purpose This Policy establishes clear rules for preventing, identifying, and addressing corruption, bribery, and any other unethical conduct that could harm the reputation or operations of AIOTI Tecnologia Ltda.
III. Scope This Policy applies to all employees, directors, business partners, suppliers, consultants, and any person representing AIOTI Tecnologia Ltda., regardless of where the activities are performed.
IV. Definitions • Corruption: The act of offering, promising, giving, or receiving any improper payment or benefit to influence a decision or obtain an improper advantage. • Bribery: Offering or receiving anything of value as an incentive to perform an improper or unethical act. • Conflict of Interest: A situation in which an employee’s personal interests may interfere with the interests of the Company.
V. Principles and Commitments • Prohibition of bribery and corruption: Offering, promising, paying, authorizing, or receiving any form of bribe, directly or indirectly, to obtain an improper advantage is prohibited. • Gifts and entertainment: Gifts, hospitality, and other benefits may be offered or accepted only when they are of modest value, comply with local laws and regulations, and are not intended to improperly influence a decision. • Conflicts of interest: All employees must avoid situations that could create a conflict between their personal interests and those of the Company. Any potential conflict must be reported to the employee’s immediate supervisor.
VI. Internal Controls AIOTI Tecnologia Ltda. shall implement and maintain internal controls to ensure compliance with this Policy. All financial and accounting transactions must be recorded accurately and completely, and no transaction may be concealed.
VII. Training and Communication All employees shall receive periodic training on this Policy so that they understand their rights and responsibilities. The Policy shall be broadly communicated to ensure that everyone involved is familiar with its contents.
VIII. Reporting AIOTI Tecnologia Ltda. encourages employees and partners to report any suspected violation of this Policy. Reports may be submitted confidentially and without fear of retaliation through the internal channels established by the Company.
IX. Consequences of Noncompliance Any violation of this Policy shall result in disciplinary action, which may include a warning, suspension, or dismissal. The Company may also take appropriate legal action when necessary.
X. Policy Review This Policy shall be reviewed periodically to ensure compliance with applicable laws and market best practices. Any changes shall be communicated to all employees and interested parties.
XI. Responsibilities All employees are responsible for complying with and supporting compliance with this Policy. The leadership of AIOTI Tecnologia Ltda. is responsible for ensuring its effective implementation and for promoting a culture of integrity and compliance.
XII. Contact Employees may contact the Company’s compliance department or management team with any questions or requests for guidance concerning this Policy.
AIOTI Tecnologia Ltda. Last reviewed: August 1, 2025
