CODE OF ETHICS AND CONDUCT — AIOTI TECNOLOGIA LTDA.

1. Purpose
This Code of Ethics and Conduct establishes the principles and guidelines that govern the activities of Aioti Tecnologia Ltda. and all its employees, partners, and representatives. It promotes integrity, compliance with the law, and social and environmental responsibility in relationships with customers, suppliers, public authorities, and society.

2. Scope
This Code applies to all Aioti professionals, including shareholders, directors, employees, interns, service providers, sales representatives, and any third parties acting on behalf of the Company.

3. Fundamental Ethical Principles
Aioti conducts its activities according to the following principles:
• Integrity and honesty: Act transparently and ethically in all relationships.
• Compliance with the law: Fully comply with applicable laws, especially those concerning data protection, mobility, road safety, the public sector, and fair competition.
• Social and environmental responsibility: Operate sustainably, promoting road safety and the responsible use of technology.
• Respect for people: Maintain a diverse and inclusive workplace free from discrimination, harassment, and prejudice.
• Commitment to excellence: Continuously improve products, services, and institutional relationships.

4. Expected Conduct
All Aioti employees and representatives must:
• Treat colleagues, customers, partners, and platform users with respect;
• Maintain the confidentiality of information belonging to the Company or third parties;
• Protect personal and sensitive data processed in the course of operations, in compliance with Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados — LGPD);
• Protect the Company’s image and reputation in all internal and external interactions;
• Avoid conflicts of interest and report any potential conflict;
• Refuse and report corruption, bribery, fraud, or improper favoritism.

5. Relationships with the Public Sector
In dealings with public officials, it is prohibited to:
• Promise, offer, or grant any improper advantage;
• Improperly interfere in administrative or public procurement proceedings;
• Use privileged information to obtain a competitive advantage.
Aioti’s participation in public procurement processes and government contracts shall always comply with the principles of legality, morality, impartiality, and transparency.

6. Use of Resources and Tools
Company resources and tools, including equipment, systems, data, trademarks, and documents, must be used responsibly and securely and exclusively for professional purposes.

7. Reporting and Ethics Channel
Aioti shall maintain a communication channel for reporting misconduct, ensuring anonymity and protection against retaliation. Any breach of this Code shall be investigated impartially and may result in disciplinary or legal action.

8. Final Provisions
This Code shall be reviewed periodically and may be updated to reflect legal, regulatory, or strategic changes. All persons involved with Aioti are required to know and comply with its guidelines.

AIOTI TECNOLOGIA LTDA.
Version 1.0 — August 2025