Code of Conduct

LAST UPDATED: JUNE 2026

Ethics and integrity have been fundamental principles of Costa Rodrigues Advogados ("Costa Rodrigues", "COSRO" or "Firm") since its foundation. We believe that collaboration and equity among all members are at the root of our institutional strength. We value diversity of backgrounds, knowledge, and skills. A collaborative and diverse environment is only possible with a unison culture, disseminated and applied by each of our employees. It is for this purpose that the COSRO Integrity Program was created.

This Code of Conduct ("Code") is the fundamental document of the Integrity Program, reflecting the values and principles that guide the performance of our Firm. More than a set of rules, it represents our culture, our commitment to integrity, transparency and ethics in all relationships with customers, partners, authorities, employees and society in general. Respect for the laws, our principles and culture is the basis of the trust we build daily as an institution and what makes the difference in each relationship we build.

1. THE COSRO CULTURE

Reputation is the most valuable asset of individuals and institutions. It is built with technical competence and results, as well as from the decisions made each day, with the fulfillment of our commitments and in the way we conduct each relationship. The trust we earn with customers, authorities and society depends, above all, on the integrity with which we act every day.

This Code of Conduct, as well as the policies of the Integrity Program, were approved by the Firm's leadership to reflect the commitment to our values. The Code reaffirms the conviction that integrity is not an abstract value, but a constant practice, present in every interaction and decision we make every day.

We believe that law practice has a transformative role in society. Therefore, we seek to incorporate and promote principles of sustainability, diversity, and inclusion, aware that a plural and responsible environment strengthens our culture, improves our solutions, and expands our positive impact. Each member of the Firm is the guardian of this reputation and co-responsible for keeping it alive, this is part of our culture. Acting ethically and respectfully is protecting what is most important to us: the trust that sustains our name.

2. OUR VALUES

• Cross-sector, multidisciplinary approach that works in an integrated, collaborative, and diverse way
• Consistent value creation that stems from a deep understanding of our clients’ businesses
• Technology and innovation that enhance our deliverables
• With an eye toward long-term impact, convinced that a sustainable future depends on what we do today
• Consistency
• Non-negotiable integrity is the basis of all our decisions and relationships

3. SCOPE AND APPLICATION OF THIS CODE

This Code reflects COSRO's values and culture and provides guidelines for decision-making by the Firm's Employees. It serves as a guide, to be consulted at all times and to facilitate making ethical, sustainable decisions that strictly follow all applicable laws and regulations.

This Code’s guidelines must be observed indiscriminately by all partners, lawyers, employees, trainees, paralegals, interns, service providers, business partners, correspondents and/or any other persons and entities acting on behalf of or in partnership with the Firm ("Employees").

Employees must read, know, follow and promote the provisions of this Code and the other policies of the Firm, regardless of their position and the place where they work. Employees are expected to act ethically, respectfully and in compliance with the laws even outside the work environment or hours. Integrity is a linear and constant value.

4. SOCIAL RESPONSIBILITY AND SUSTAINABILITY

In line with our commitment to sustainability and social development, we have been signatories to the United Nations Global Compact since our foundation. We promote respect for and defense of human rights, including diversity and gender equality, the effort against climate change, and the fight against corruption of any kind.

In accordance with the best governance practices, we have established our Sustainability Committee to support and carry forward our commitments to integrate sustainable practices into COSRO's operations.

5. RESPECT FOR THE LAWS AND THE FIRM'S POLICIES

As a legal services provider, we strictly follow the regulations of the Brazilian Bar Association (OAB), especially OAB’s Statute and the Code of Ethics and Discipline of the OAB. All lawyers who provide services for or are linked to COSRO must know and follow these rules.

In case of questions about a law practice ethical matter or any conflicts between the OAB rules, this Code or any COSRO policy, the lawyer should consult the COSRO Ethics Committee.

In addition to complying with all applicable laws and regulations, Employees must know and follow all documents and policies that make up the COSRO Integrity Program. It is everyone's role to ensure compliance with all laws, any suspicion of violation must be reported in good faith through the COSRO Ethics Channel.

5.1. Commitment Against Corruption and Money Laundering

COSRO is committed to fighting any type of corruption, whether in the public or private sphere, in Brazil or abroad. In this sense, any form of offer, promise, authorization or receipt of undue advantage, directly or indirectly, to public or private agents, with the objective of obtaining favor, unduly interfering in a contract, business, decision, functional or fiduciary duty is prohibited.

All relations with the public sector must be guided by legality, morality and impersonality. All Employees must avoid any conduct that may constitute an act of improbity, including the misuse of information, undue influence or obtaining undue advantages.

Undue advantages are not limited to cash payments and may include favors, tokens, gifts, hospitality, entertainment. Anti-corruption violations include:

• Promising, offering or giving, directly or indirectly, an undue advantage to a public official or a third person related to him/her;
• Frustrate, defraud, manipulate, impede or disturb public bids, administrative contracts and their amendments;
• Hinder investigation or inspection activity or intervene in the performance of regulatory agencies or other public bodies;
• Promise, offer or give an Undue Advantage to a private individual to obtain favorable treatment, obtaining, retaining or directing business;
• Assist, influence or support an employee of a private company to commit fraud or violate the policies or code of conduct of the institutions to which they belong.

Despite the Firm not being subject to controls and report obligations, the fight against money laundering is also a commitment of COSRO. In this sense, we combat all types of fraud, bribery and money laundering, and all Employees are expressly prohibited from engaging in acts or omissions that constitute a crime under Brazilian criminal law.

Clients, institutions and countries have their own rules and definitions on corruption and money laundering. COSRO's Integrity Policy provides examples and indicates limits to be respected so as not to violate any law or private rule.

5.2. Compliance with Labor Legislation

We strictly comply with the Statute of the Law Practice and Brazilian employment legislation, ensuring fair, safe and inclusive working conditions. Respecting health and safety standards, as well as combating any form of discrimination, harassment or inequality, is an essential part of our culture.

5.3. Privacy and Data Protection

We respect the right to privacy of the people with whom we have a relationship and the Brazilian General Data Protection Law (LGPD). The LGPD considers personal data to be any information that enables the identification of a natural person, including name, document number, telephone number, e-mail, etc.

COSRO treats as confidential any personal data to which it has access and uses it for legitimate purposes, respecting the purpose for which it was processed and the rights of the data subject, in accordance with the Firm's Privacy Policy.

The Firm's Privacy Policy is mandatory for all Employees, including service providers and business partners.

Any incident of non-compliance with the Privacy Policy, such as destruction, loss, alteration, disclosure or unauthorized access to personal data processed by the Firm must be immediately reported to the Data Protection Officer (DPO) through the e-mail: dpo@cosro.com.

6. PROPER CONDUCT AND RESPECT FOR OTHERS

The Firm's culture is built on mutual respect, collaboration, and valuing people. Therefore, all Employees must act with courtesy, empathy and professionalism, maintaining a safe, inclusive work environment free from discrimination or any form of abuse.

Proper conduct is a direct reflection of our values and the reputation we cultivate. Therefore, we do not tolerate behavior such as discrimination, harassment, injustice, offenses and conflict of interest.

Any Employee representing the Firm, in a professional or social situation, must behave in accordance with the highest ethical standards, not adopting postures or attitudes that may compromise the image, reputation or interests of the Firm.

Attitudes we want to avoid include:

• Insults, offensive or prejudiced terms and words;
• Physical or verbal violence, threats, screaming;
• Any type of discrimination;
• Harassment, humiliation, intimidation, coercion, embarrassment, being unfairly passed over, isolation;
• Create or spread offensive nicknames or malicious, ironic, derogatory or joking rumors;
• Unwanted actions, suggestions or comments of a sexual nature;
• Placing or remaining in a situation of conflict of interest.
• Moral and Sexual Harassment and Discrimination

Moral harassment is defined as the violation of the dignity or psychological or physical integrity of another person through abusive conduct, regardless of intention. Harassment may or may not be practiced by a person superior in the hierarchy and may be characterized by the requirement to perform unnecessary or exorbitant tasks, discrimination, humiliation, embarrassment, isolation, social exclusion, defamation or humiliating and embarrassing situations likely to cause suffering, physical or psychological damage.

Sexual harassment is defined as conduct with a sexual connotation practiced against someone's will, in a physical, written, verbal or non-verbal way, manifested by words, gestures, physical contact or other means, in a way that disturbs or embarrasses the person, affects their dignity, or creates an intimidating, hostile, degrading, humiliating or destabilizing environment.

Discrimination encompasses any distinction, exclusion, restriction or preference based on race, ethnicity, color, sex, gender, religion, disability, political opinion, national ancestry, social origin, age, sexual orientation, gender identity and expression, or any other that undermines the recognition or exercise, under equal conditions, of fundamental rights and freedoms in any field.

The Firm is committed to promoting an environment free from any type of harassment or discrimination. In the recruitment, selection and promotion processes, candidates must be evaluated solely and exclusively for their ability to adapt to the expectations of the position and the ethics of the Firm.

7. Conflict of Interest and Relationships

In the relationship between the Employee and the Firm, conflict of interest occurs when Employees have their own interests or those of third parties, which are contrary to the interests of the Firm, in a way that compromises their judgment or influences their decision-making.

Employees must not obtain undue personal advantages for themselves or for third parties in any situation of conflict of interest. But it is not necessary for the Employee to receive an undue payment or advantage to characterize a conflict. If a situation can only be interpreted as a personal favoritism in detriment of the interests of the Firm, it can be characterized as an apparent conflict, which may cause reputational damage to the Employee and the Firm. Apparent conflicts must also be avoided.

The conflict of interest may also arise from contractual obligations assumed by the Firm with its clients. In this sense, it is necessary to avoid having the Firm’s interests in conflict with the clients’, current or former, or having the interests of two clients in conflict.

The following are types of conflicts of interest:

• In the relationship between Employees/Third Parties and the Firm: the conflict of interest in the relationship between Employees/Third Parties and the Firm occurs when they use their influence or act with the intention of benefiting private interests that are contrary to the Firm’s interests or may cause damage or loss, such as: (a) using privileged or confidential information of the Firm and/or its clients to obtain personal benefit or a benefit for a third party; (b) being involved in or influencing the hiring of a relative or close friend to work at the Firm; or (c) using the Firm's working hours or assets for private activities, professional or not.
• In representing clients or potential clients: the conflict of interest is not limited to professional ethical rules, as stated in the Code of Ethics and Discipline of the OAB and other acts and decisions of its Federal Council, and may also arise from contractual obligations assumed by the Firm with its clients. Therefore, a conflict of interest may occur between clients or potential clients of the Firm, and the Firm must analyze case-by-case and solve any situations that may constitute the defense of opposing or conflicting interests.
• Relationship between Employees: cases of affective, loving or family relationships between Employees must be communicated to the team leaders and/or partners of the Firm. Employees in these situations should not work on the same team or in a direct line of subordination.

As soon as a potential or actual conflict is identified, Employees must report it to the Firm's Management Committee in a transparent manner so that it can make a decision and provide the appropriate guidance.

6.3. Professional Secrecy and Intellectual Property

Employees may not reveal or use any confidential information in a manner other than that contracted by clients or business partners of the Firm, notably aiming at any gain or benefit. The disclosure of confidential information may lead to civil and criminal liability, without prejudice to disciplinary sanctions before the OAB, for lawyers and interns.

It is the Employees’ responsibility to ensure professional secrecy and maintain a relationship of discretion and trust with clients, to preserve and maintain in secrecy the information and disclosures of clients, partners and the Firm itself, as well as not to publicize issues and matters of interest to clients and/or the Firm itself, unless expressly authorized.

The Firm respects the intellectual property of third parties, and any type of plagiarism or unauthorized use of information or software owned by others is prohibited. It is up to each Employee to verify the source of the information they use at work.

Likewise, all rights related to intellectual production resulting from works or legal documents produced as a result of the activities developed in or for the Firm and its clients belong exclusively to the Firm.

Employees who leave the Firm must refrain from copying, recording, photographing or reproducing in any form any files and/or documents, electronic or not, without prior authorization from the Firm's area partners.

The information obtained at the Firm must be used only for the work at COSRO, and its use for any other purpose is prohibited.

6.4. Responsible Use of Artificial Intelligence

Collaborators must use artificial intelligence (“AI”) tools in an ethical, legal, responsible, and transparent manner, in compliance with the Firm’s policies and with due regard for dignity, equality, respect for people, and the best interests of the Firm and its clients.

The use of AI to create, reproduce, or disseminate discriminatory, offensive, misleading, abusive content, content that violates third-party rights, or content that is otherwise incompatible with the standards of courtesy, empathy, professionalism, and respect that guide COSRO’s culture is prohibited.

AI may only be used through tools approved by the Firm, with due protection of legal privilege, confidentiality, personal data, and intellectual property.

All content produced or supported by AI must be subject to full human review by the responsible Collaborator, including verification of accuracy, sources, biases, hallucinations, language, style, and ethical fitness, before being shared with colleagues, clients, public authorities, or third parties. AI must be treated as a tool to support professional activities, and not as a substitute for a lawyer’s legal judgment or decision-making.

6.5. Use of Social Media and Media Communications

Only COSRO partners or counsels may use the name of the Firm in interviews, lectures, events or articles for media outlets or publications. Exceptions must be approved by the Firm’s Management Committee. Contributors attending academic events should clearly indicate that their views express their personal point of view.

Under no circumstances is an Employee authorized to make public comments, whether on the internet, social networks or to the press, on cases in which the Firm acts, even if the case in question is public. If the client authorizes comments, only the partner in charge may speak on behalf of the Firm.

The Firm encourages the responsible use of social media, remembering that the image of each Employee can be associated with the Firm’s. Everything that is shared or published on social media can generate consequences and repercussions that go beyond the personal sphere, and may affect the Firm, its clients, authorities and public institutions, among others. Therefore, we recommend caution while communicating personal opinions on social media.

6.6. Use of Firm Assets

All equipment and systems made available to Employees by the Firm for carrying out work are considered assets of the Firm. Firm’s assets include phones, laptops, stored data, email accounts, chair, desk, software, etc.

The Firm's assets must be used ethically, legally, and professionally, in accordance with this Code and the Firm's policies. Each Employee is responsible for taking care of the Firm's assets that have been made available to them.

Employees and business partners should not have an expectation of privacy when using the Firm's assets, including in relation to private data stored in the Firm's assets, as this would be an improper use of the asset.

In accordance with applicable law, the Firm may review, monitor and record the information exchanged at any time and without prior notice or permission from any Employee. This rule covers information transmitted by telephone, e-mail, applications and any other means of communication or storage in the Firm's system or resource.

8. COMPLAINTS AND DISCIPLINARY MEASURES

Employees must immediately and formally report any violation or suspected violation of this Code, the Firm's policies or illegal conduct by any Employees or the Firm's business partners (including clients, suppliers and other business partners).

The Firm also encourages clients and business partners to use the Ethics Channel if they have information about improper or undue conduct.

The Ethics Channel is available through the link Ethics Channel or e-mail: hotline@cosro.com.

Reports can be anonymous and will always be treated confidentially. All complaints will be investigated internally by COSRO's Integrity area. The Firm forbids and repudiates any act of retaliation against any person who, in good faith, reports conduct that is illegal or contrary to the guidelines set forth in this Code.

Violation of this Code, the Firm's policies, laws or regulations may result in sanctions, ranging from a warning to termination of the contract, depending on the severity. Individuals who fail to take reasonable care to detect or report a violation, as well as individuals who refuse or refrain from disclosing information relevant to the proper investigation of the facts, may also be subject to disciplinary measures.

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