Code of Ethics and Conduct

Objective and scope

The Code establishes the guidelines and rules that govern Swapo's activities as a virtual asset service provider company (SPSAV), exclusively in the intermediation category, with a focus on transparency, security, legal compliance and ethics. Its objectives are:

• To guide employees and partners on Swapo's principles and standards of conduct.
• To consolidate ethical and professional values as the foundation of the company's culture.
• To build Swapo's reputation through professional conduct guided by corporate governance and Compliance.
• To indicate the channels for reporting improper conduct, with a guarantee of confidentiality.

All employees, staff, managers, administrators and partners must adhere to the Code. Partners and suppliers must be encouraged to adopt similar principles and to adhere to the Code by signature. The Code must be interpreted together with the law, regulations and Swapo's other policies.

Anyone who violates the Code is subject to disciplinary and legal measures. Suspicions of corruption or other violations may be reported to the authorities.

Principles and values

• Transparency: operate with transparency in transactions and communications, so that everyone is informed about products, services and risks.
• Integrity: act with high ethical standards in interactions and in the performance of duties.
• Client protection: prioritize client security, with measures to protect their assets and personal information and encouragement of responsible practices.
• Responsible innovation: develop and implement innovations responsibly and in compliance with ethical and regulatory standards.
• Inclusion and accessibility: offer fair and accessible opportunities, regardless of the client's profile or financial size.
• Accountability: work with independence and transparency, answering for the consequences of one's own behavior.
• Cooperation: bring conduct that violates the law or the Code to the attention of a superior or Compliance.
• Equality: offer equal opportunities and prohibit discrimination, harassment and retaliation.
• Excellence: win clients through the quality of services, with fair and honest competition.

In situations not provided for, the Code guides people to assess whether the action is permitted by law, is consistent with the Code, the policies and the company's values, and whether the person would be comfortable having it made public or explaining it to colleagues and family. When in doubt, the immediate superior, Legal or Compliance should be consulted.

Expected conduct

• Professional conduct: serve with attention, efficiency and respect, without prejudice or distinction based on gender, origin, religion, nationality, color, age, marital status, sexual orientation, physical or mental condition, political preference or social position.
• Use of resources: use company computers, phones, systems and e-mail only for work. Swapo may run checks to identify misuse.
• Confidentiality: do not disclose confidential, strategic or privileged information of Swapo and its partners, nor information about transactions of Swapo and its clients. This duty continues after the relationship ends.
• Conflicts of interest: decide impartially, without personal or financial interests that affect or appear to affect judgment. When in doubt, consult the supervisor, Human Resources, Legal or Compliance.
• Anti-corruption: refuse and do not offer payments, gifts, presents, hospitality or advantages intended to trade favors or to influence the winning or retention of business. All forms of bribery are prohibited. Cash payments may not be made or accepted without prior consultation with management. Everyone must comply with Law No. 12,846/2013.
• Competition: obtain competitor information only from public sources and notify Legal and Compliance in advance about participation in events with a risk of exchanging sensitive information.
• Anti-fraud: disclose accurate and timely information, keep faithful financial and accounting records and report to the competent bodies, such as COAF (Brazil's Financial Intelligence Unit), the transactions required by law.
• Personal data: use third-party data only for the authorized purpose, to the minimum extent necessary, and protect it against improper disclosure or use.
• Technology: use only licensed and authorized software and adopt security measures to protect data.
• Ethical use of technology: use artificial intelligence ethically and transparently, inform clients about the use of algorithms and ensure they are used fairly and without discrimination.
• Media and social networks: refer requests from the press, analysts and investors to authorized spokespersons. Employees may share content already published by the official channels. Partners and administrators must make clear when an opinion is personal.

Unacceptable conduct

• Working while intoxicated or under the influence of drugs, carrying weapons or acting in unsafe conditions.
• Exploiting slave labor, labor analogous to slavery, or child labor.
• Engaging in or tolerating moral or sexual harassment.
• Using Swapo's e-mail or equipment for improper or unlawful purposes.
• Using confidential or privileged information for one's own benefit or that of relatives, friends or third parties, or disclosing it improperly.
• Using one's relationship with Swapo to obtain an undue advantage or favor another party, such as receiving a reward for favorable treatment.
• Offering or giving public officials, politicians or political parties gifts, financial assistance, discounts above what is reasonable or any advantage, including payments to expedite routine services, licenses or official documents.
• Exchanging sensitive information with competitors or entering into anticompetitive agreements, such as price fixing or market division.
• Misleading another party to obtain an advantage, using false documents or hindering an investigation or inspection.
• Sharing personal data of employees, partners or clients without consent or in violation of the Privacy Policy.
• Sharing individual passwords or accessing inappropriate websites with Swapo devices.
• Speaking on behalf of Swapo or using its brand without prior authorization from the communications department, or disclosing non-public information on personal networks.
• Dealing with a friend or relative in the Government on behalf of the company. The situation must be reported to the superior or to Legal and Compliance.

Relationships

Clients: must be treated in an upright, equal, courteous and transparent manner. The employee must clearly inform clients about products and services, respect clients' contracts and rights, and guarantee the confidentiality of their information.

Suppliers and partners: selection must follow economic, technical, ethical and reputational criteria, with equitable treatment. Suppliers must comply with the Code and applicable rules. It is prohibited to contract anyone who exploits slave labor, child labor or labor analogous to slavery, who has been cited by the Ministry of Labor and convicted in court for these practices, or who is proven to be involved in corruption.

Competition: Swapo values free and fair competition. Employees must not discuss with competitors topics relevant to competitiveness and must preserve the confidentiality of information of Swapo and its clients.

Government: meetings with public officials or politicians must be open, with two or more Swapo representatives, preferably during the authority's public schedule, and documented as completely as possible.

Whistleblowing channel

Anyone who, in good faith, suspects or witnesses conduct contrary to the Code must report it for investigation. The Code provides for a Compliance and whistleblowing channel and a specific Compliance department.

The Code provides that reports are received by an independent company and investigated by Legal and Compliance, with confidentiality and independence. Swapo does not allow retaliation against anyone who reports in good faith or cooperates with the investigation. Any retaliation must be reported through the channel and subjects the person responsible to the sanctions of the Code.

Compliance, training and monitoring

Verifying compliance with the Code is the responsibility of the Compliance Officer, assisted by a permanent Compliance Committee of three internally elected members, with decisions by majority. The Committee must support the monitoring of standards of conduct, training, the definition of penalties, the management of conflicts of interest and the oversight of investigations of serious violations.

Officers, employees, interns and other staff must be trained and updated periodically, with annual training.

The Code provides for continuous monitoring of trading activities, communications and transactions to identify violations and suspicious behavior, as well as periodic internal and external audits to verify adherence to the Code and the law.

Consequences of violations

Anyone who violates the Code, the law, regulations or Swapo's policies is subject, as applicable, to:

• Verbal warning.
• Written warning.
• Suspension of the employment relationship or contract.
• Termination of the employment relationship or contract for cause.

Without prejudice to these measures, Swapo must seek compensation for the damage caused and report the facts to the competent authorities, where applicable.

Review and effective date

The Code may be amended whenever necessary. In case of conflict, Swapo's articles of incorporation and the law in force prevail over the Code.

The Code took effect on September 21, 2026.

Regulatory basis

• Law No. 12,846/2013 (Anti-Corruption Law) and related legislation.
• Rules on reporting transactions to COAF.
• Swapo's Privacy Policy.

About this version

Public version of the document “Code of Ethics and Conduct”, dated September 21, 2026, which is part of the authorization request filed with the Central Bank of Brazil. Authorization has not been granted yet.

This text summarizes the internal document. Personal data (LGPD), monitoring parameters and technical details whose disclosure would undermine security, fraud prevention and anti-money laundering efforts have been omitted, as have terms subject to business confidentiality (BCB Resolution No. 520/2025, art. 52, § 2). This version does not replace the service agreement or the applicable regulations.

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