Code of Ethics

Introduction

In alignment with HyperMatrix's core operations, we are committed to sharing a common definition of our values, goals, and ethics with all employees, regardless of their background or function.

It is essential that, both individually and collectively, every person adheres to and shares the same code of conduct within HyperMatrix. Compliance with moral, professional, and ethical rules is mandatory to guarantee an environment of cohesion and mutual respect for all HyperMatrix employees.

1. Ethics in our relations with third parties

HyperMatrix's relationship with third parties, especially clients, is built fundamentally on the trust they place in the company, as well as on our global reputation and expertise.

1.1. Acquisition of standard goods and services

When acquiring goods and services (including outsourcing), supplier selection must be conducted fairly, based on objective comparison criteria and strictly in accordance with the company's established commercial procurement procedures.

1.2. Prevention of money laundering

HyperMatrix's commitment to impartiality, integrity, and transparency is reflected in its strict adherence to all anti-money laundering laws across every jurisdiction in which it operates.

1.3. Illicit payments, gifts and favors — preventing corruption

To safeguard HyperMatrix's reputation, directors and employees are strictly prohibited from promising or offering undue advantages to any partner, client, supplier, political party, political representative, or public official.

1.4. Loyalty, integrity and conflict of interest

Integrity and loyalty must prevail in all working relationships of every employee, both within and outside the company.

1.5. Respect for free competition

Free competition is upheld across various countries, strictly within the boundaries established by antitrust and competition laws.

1.6. Financial contributions to public authorities

HyperMatrix employees are free to make personal financial contributions to political parties or candidates, provided this is done on their own time and exclusively using their personal funds.

1.7. Zero tolerance for corruption with public authorities

Corruption, in all its forms, is completely unacceptable and incompatible with the core ethos of HyperMatrix.

2. Ethics within HyperMatrix

2.1. Compliance with laws, regulations and taxation

HyperMatrix places paramount importance on acting as a responsible corporate citizen in every market it serves.

2.2. Confidential information

HyperMatrix discloses select company information via its website and other public communication channels. Any information not officially communicated by HyperMatrix must be treated as strictly confidential.

2.3. Insider information and undisclosed operations

Insider information refers to non-public data that could materially impact an investor's decision to buy or sell securities. Trading or sharing this information is strictly forbidden.

2.4. Use of company assets

HyperMatrix provides its employees with assets, services, and tools tailored to their roles to ensure effective performance. All such equipment remains the exclusive property of HyperMatrix.

2.5. Third-party intellectual property rights

All confidential information handled by HyperMatrix fully respects the intellectual property rights of third parties.

2.6. Respect for delegations of power and signature

Every employee is personally responsible for ensuring they do not commit HyperMatrix to any obligations that exceed their explicitly granted delegated powers and authority.

2.7. Confidentiality of personal information

The confidentiality of personal information regarding HyperMatrix employees must be strictly maintained at all times in compliance with data privacy regulations.

2.8. Human resources policy — equal opportunity

The motivation, professionalism, and cohesion of our workforce are critical to achieving our strategic corporate objectives.

2.9. Protection against harassment

Harassment—whether physical, moral, written, electronic, or verbal—affecting any employee, supplier, contractor, client, or third party will not be tolerated at HyperMatrix. All incidents will be processed according to local jurisdiction laws, resulting in severe disciplinary sanctions for the offending party.

Any employee who is a victim of harassment, or suspects that someone is being harassed by a HyperMatrix representative, must immediately report it to their direct supervisor and/or Human Resources. The situation will be assessed and appropriate decisive action will be taken.

During the offboarding process, departing employees will undergo an exit interview that explicitly addresses any potential harassment incidents experienced during their tenure.

Moral Harassment: Abusive conduct (via words or actions) that, through severity or repetition, damages a person's dignity or physical/psychological integrity, humiliating them in front of colleagues or toxifying the workplace environment.

Sexual Harassment: The act of coercing someone by exploiting hierarchical power to extract sexual favors. This constitutes a severe offense and a criminal act.

2.10. Sustainable development and environmental protection

Every employee is expected to actively assist HyperMatrix in achieving its sustainable development goals by promoting economic progress, environmental stewardship, and social equity.

HyperMatrix Solutions Ltd.
Cond. Ed. Plaza I
R. James Joule, 92 — Cidade Monções
04576-080, São Paulo/SP, Brasil