Ethics, Integrity and Anti-Corruption Policy

Infinity Media Brasil LTDA. is committed to conducting its business ethically, with integrity, transparency and in compliance with applicable law.

This Ethics, Integrity and Anti-Corruption Policy establishes the principles and standards of conduct expected from directors, employees, partners, suppliers, service providers, sales representatives and other third parties acting on behalf of or for the benefit of Infinity Media Brasil.

The company does not tolerate corruption, bribery, fraud, improper favoritism or any conduct intended to obtain an improper advantage.

Infinity Media Brasil activities must be conducted with honesty, integrity, transparency, respect for the law, fair competition and corporate responsibility.

All business decisions must be made based on legitimate business criteria, quality, technical capacity, price, performance and the company's interests, and obtaining advantages through unlawful or unethical means is prohibited.

It is prohibited to offer, promise, authorize, request, receive or grant, directly or indirectly, any payment, advantage, benefit or item of value for the purpose of:

• improperly influencing a decision;
• improperly obtaining or retaining business;
• securing privileged treatment;
• accelerating procedures through unauthorized means;
• influencing public or private officials;
• obtaining any improper commercial or personal advantage.

This prohibition applies both to relationships with private companies and to relationships with public bodies, public officials, state-owned companies and other government representatives.

Infinity Media Brasil observes applicable Brazilian law, including the principles established by Law No. 12,846/2013, the Brazilian Anti-Corruption Law, and other rules applicable to its activities.

Any interaction with public officials must be transparent, professional and legitimate.

It is strictly prohibited to offer money, gifts, benefits, entertainment, travel, favors, employment opportunities or any advantage intended to influence an official decision.

Facilitation payments or payments intended to expedite routine government procedures are not permitted when used to obtain improper treatment.

Gifts, giveaways, meals, hospitality or entertainment may only be offered or received when they:

• are reasonable and compatible with legitimate business practices;
• are not intended to influence decisions;
• do not create an obligation or expectation of favoritism;
• comply with applicable law and the policies of the organizations involved;
• do not involve cash or cash equivalents.

Any benefit that may be interpreted as an attempt at improper influence must be refused.

Additional care must be taken when public officials are involved.

Commissions, remuneration, fees and other payments made by Infinity Media Brasil must correspond to legitimate services or activities actually provided.

Payments are not permitted when they:

• lack a legitimate commercial justification;
• are made with a false or incomplete description;
• are directed to third-party accounts without justification;
• are intended to conceal the true beneficiary;
• are used to fund bribery, corruption or other unlawful activities.

Commissions and payments to representatives, partners or intermediaries must be compatible with the services provided and properly documented.

Infinity Media Brasil expects business partners, suppliers, consultants, representatives, service providers and other third parties to adopt ethical standards compatible with this Policy.

The company may evaluate third parties before the start of or during the business relationship, especially where there is risk related to corruption, fraud, conflicts of interest or relationships with the public sector.

Infinity Media Brasil may suspend or terminate business relationships if practices incompatible with its integrity principles are identified.

Directors, employees and representatives must avoid situations in which personal interests may interfere, or appear to interfere, with decision-making on behalf of the company.

Any actual, potential or apparent conflict of interest must be reported to Infinity Media Brasil management.

Business decisions must not be influenced by personal, family, financial relationships or any other private interests.

All commercial and financial transactions must be recorded correctly, completely and transparently.

The creation of false, incomplete or misleading records is prohibited, as is the use of unrecorded accounts, funds or payments.

Expenses related to travel, gifts, entertainment, commissions, consulting and services must have appropriate documentation and a legitimate business purpose.

Infinity Media Brasil supports free and fair competition.

Practices intended to manipulate prices, divide markets, coordinate proposals, obtain competitors' confidential information through improper means or adopt any conduct contrary to competition rules are not permitted.

Confidential information belonging to Infinity Media Brasil, clients, partners, suppliers or third parties must be protected and used exclusively for authorized purposes.

The company also maintains specific policies related to privacy and personal data protection.

See also the Privacy Policy.

Anyone who knows of or suspects a violation of this Policy may report it to Infinity Media Brasil.

Reports will be handled responsibly and, whenever possible, confidentially.

Infinity Media Brasil does not tolerate retaliation against people who report possible irregularities in good faith.

Contact channel for ethics and compliance matters:

contato@mediainfinity.com.br

Failure to comply with this Policy may result in administrative, disciplinary or contractual measures, including termination of the commercial or professional relationship, without prejudice to applicable legal measures.

When necessary, potentially unlawful facts may be reported to the competent authorities.

Infinity Media Brasil management is responsible for promoting a culture based on ethics, integrity, transparency and compliance.

Employees and third parties are encouraged to request guidance whenever there is doubt about the application of this Policy.

This Policy may be updated periodically to reflect legislative, regulatory or internal procedure changes at Infinity Media Brasil.

The current version will be available on the company's official website.