1. Objective

 

The Code of Ethics and Conduct of Atlas Finance & Tech Ltda represents the highest standards of ethics, integrity, and professional conduct. It establishes guidelines for our company, members, and partners, reflecting the values and principles by which we govern ourselves.

 

Thus, we expect everyone who is part of our organization to act in accordance with this code in all aspects of their activities.

 

2. Integrity and Honesty

 

All members of Atlas Finance & Tech must strictly comply with Brazilian anti-corruption regulations, including the provisions of Law No. 12,846/2013 and its regulatory decrees, as well as the norms and personal data protection of Law No. 13,709/2018 (General Data Protection Law – LGPD) and Circular Bacen No. 3,978/2020.

 

It is essential that all information provided to clients, partners, and stakeholders be accurate, truthful, and transparent. Making false, misleading, or exaggerated statements about our products, services, or financial performance is not allowed.

 

Engaging in illegal activities, bribery, corruption, fraud, or any form of unethical behavior is strictly prohibited. Any suspicion of illegal or unethical activity must be immediately reported and dealt with according to the company's appropriate procedures and applicable laws.

 

3. Conduct in Social Relations

 

Conduct in social relations encompasses employees, partners, directors, and representatives acting on behalf of Atlas Finance & Tech.

 

3.1. Relationship with Clients

 

We are committed to prioritizing the interests of clients above all else. All decisions and actions must be geared towards providing financial products and services that meet the needs of clients and promote their financial well-being.

 

It is mandatory for all company members to respect and protect the confidentiality and privacy of client information. No personal or financial information should be disclosed or used improperly except when authorized in writing by the clients themselves or when required by law.

 

We pledge to provide clear and transparent information to clients about products, services, prices, terms, and conditions. All communications should be understandable and not misleading, ensuring that clients can make informed decisions.

 

The company and its members must identify, disclose, and whenever possible, avoid conflicts of interest that may harm these interests. In cases of conflict, the priority should always be the interests of the clients.

 

3.2. Work Relationship and Diversity

 

Atlas Finance & Tech is committed to creating and maintaining an inclusive work environment where all members are treated with respect and dignity, regardless of race, gender, sexual orientation, religion, origin, culture, or other personal characteristics.

 

Atlas Finance & Tech promotes equal opportunity in all aspects of employment, from hiring to training and career advancement. Recruitment, promotion, and compensation decisions are based on merit and competence.

 

We do not tolerate any form of discrimination or harassment in the workplace. All members have the right to work in an environment free from sexual harassment, moral harassment, racial discrimination, or any other form of unfair treatment.

 

The company values the diversity of perspectives and experiences that each member brings to the team. We encourage diversity and inclusion and recognize that they strengthen our company and contribute to innovation.

 

We support a healthy balance between work and personal life. We promote policies and practices that enable members to manage their professional and personal responsibilities effectively.

 

3.3. Relationship with Partners and Service Providers

 

Atlas Finance & Tech values the selection and hiring of partners and service providers based on technical, professional, and ethical criteria, always conducting through competitive processes that ensure the best cost-benefit ratio.

 

We always analyze and avoid hiring or terminate contracts, as the case may be, with Partners or Service Providers that have a dubious reputation, indicating conduct divergent from this Code, and that use child labor or conditions analogous to slavery, as well as those who disrespect the environmental, cultural, and social heritage of the community in which they operate.

 

From the effective date of this Code, all contracts entered into with Atlas Finance & Tech must contain an appropriate anti-corruption clause regarding the risks represented by the other party's actions, providing for indemnities, penalties, and/or the possibility of contract termination in case of non-compliance with ethical norms and fraud and corruption practices.

 

3.4. Relationship with the public sphere and participation in bidding processes.

 

Atlas Finance & Tech knows, respects, and complies with internal rules regarding relations with the public sector: agents who hold public office; agents who work or hold a position in a public agency, Brazilian or foreign; agents who work or hold a position in a company or institution controlled or managed by the government; agents who represent or hold a position in a political party; and candidates for political positions, refraining from any action directly or indirectly, for the benefit of offering, payment, promise of payment, gifts, authorization, and/or approval of the supply of any value, goods, or any other valuable item.

 

Participation in bidding processes must observe the Bidding Law (Law 8,666/93), the Law on Defense of Free Competition (Law 12,529/12), and other applicable legal provisions, not admitting any conduct that plans or results in fraud, manipulation, or undue influence of Public Agents' decisions, or any action that can be characterized as influence peddling to accelerate routine services or administrative actions for the benefit of Atlas Finance & Tech.

 

3.5. Relationship with the press

 

We must ensure the accuracy of the information conveyed to the media, ensuring that any statement or pronouncement on behalf of the company is made only by authorized persons, and must forward any request made by a media outlet, such as television, radio, websites, newspapers, to the responsible person in the Marketing department of Atlas Finance & Tech.

 

4. Gifts, Presents, and Favors

 

No member of Atlas Finance & Tech should offer, seek, or accept personal benefits such as gifts, presents, favors, or any form of gratification that may negatively influence their business decisions or that are not in accordance with company policies.

 

Gifts or values ​​above R$ 500.00 (five hundred reais) must be forwarded to the Compliance and Risk area.

 

Items such as agendas, pens, calendars, T-shirts, or any other of small value will not be considered as gifts.

 

Gifts, invitations, or presents that may be interpreted as an intention to affect the impartiality of its recipient must be refused and reported to the Compliance and Risk Area.

 

5. Donations and Sponsorship

 

Atlas Finance & Tech recognizes the importance of contributing to the development and well-being of the communities in which it operates. Therefore, it establishes clear and transparent guidelines for the donation and sponsorship process, ensuring that all contributions are made ethically, transparently, and in compliance with applicable laws and regulations and in accordance with the Donations and Sponsorship Policy.

 

No donation or sponsorship may be made with the intention of obtaining or resulting in improper benefits for Atlas Finance & Tech, its employees, or anyone representing it.

 

Political-party donations are prohibited, and the name of Atlas Finance & Tech should never be associated with any donation of this nature, even if made by employees.

 

6. Conflict of Interest

 

All members of Atlas Finance & Tech must be aware of the possibility of conflicts of interest that may arise in their activities. It is the responsibility of each individual to identify and promptly report any potential or actual conflict of interest.

 

When a conflict of interest is identified, it must be promptly disclosed to the Compliance and Risk department or company management. This includes any direct or indirect financial interest that may influence a decision or action.

 

In the event of a conflict of interest, those of clients and the company must always be prioritized. Decisions should be

 

 made with the aim of maximizing the benefit of clients and the company, even if it means sacrificing personal interests.

 

Conflicts of interest must be resolved transparently and fairly. The company's management must assess each situation and take appropriate measures to eliminate or mitigate the conflict, always in compliance with applicable regulations and ethical standards.

 

7. Social Responsibility

 

7.1. Community Involvement: We are committed to making a positive contribution to the community and society at large.

 

We encourage our members to participate in voluntary activities and corporate social responsibility programs to support beneficial causes.

 

7.2. Environmental Sustainability: We recognize our responsibility to minimize our environmental impact. We are committed to adopting sustainable practices in our operations, such as energy conservation, recycling, and waste reduction, whenever possible.

 

7.3. Business Ethics: Atlas Finance & Tech is committed to conducting business in an ethical and responsible manner. We do not engage in unethical business practices, such as bribery, corruption, or tax evasion, and we respect applicable laws and regulations.

 

7.4. Support for Financial Education: We recognize the importance of financial education in society. We are committed to supporting financial education initiatives that empower individuals to make informed and responsible financial decisions.

 

8. Transparency and Accountability

 

8.1. Transparency in Communications: Atlas Finance & Tech is committed to providing clear and transparent information to clients, partners, and members. All communications, documents, and agreements must be understandable and accurate.

 

8.2. Financial Accountability: The company is responsible for maintaining accurate and detailed financial records. Financial reports, accounting statements, and related information must be presented accurately and in accordance with applicable accounting principles.

 

8.3. Audits and Reviews: We agree to fully cooperate with internal and external audits, regulators, and government authorities. All records and information must be available for review and audit as necessary.

 

8.4. Ethics, Conduct, and Compliance Committee: The company will establish an Ethics, Conduct, and Compliance Committee responsible for overseeing and ensuring compliance with this code and all applicable regulations. The committee will be composed of independent and impartial members.

 

9. Prevention of Money Laundering and Terrorism Financing

 

Atlas Finance & Tech maintains strict controls regarding the prevention of money laundering and terrorism financing, not favoring transactions based on illicit activities.

 

All members are trained and guided on internal standards and procedures related to the prevention of money laundering, provided for in the Anti-Money Laundering and Terrorism Financing Policy. They are aware of the importance of fighting organized crime and collaborate to prevent money laundering and terrorism financing, immediately reporting to the Compliance and Risk department any activity that may be considered suspicious due to indications or certainty of being related to money laundering and/or terrorism financing.

 

10. Information Security

 

Complementary Law No. 105/2011 establishes the duty and obligation of banking secrecy of institutions regulated by the Central Bank of Brazil to safeguard customer data, with the breach of secrecy without authorization from the Judiciary considered a crime subject to penalties that can vary from one to four years imprisonment and fine for the offender.

 

All members of Atlas Finance & Tech are subject to the terms of the Confidentiality Statement, which regulates the use and care to be taken with the company's confidential information, to which they have access due to the functions performed.

 

11. Compliance and Regulatory Compliance

 

11.1. Compliance with Laws and Regulations: Atlas Finance & Tech is committed to strictly complying with all applicable laws, regulations, and financial standards, including specific regulations of the white-label industry. This includes adhering to financial, privacy, and data protection regulations.

 

11.2. Internal Compliance: The company maintains internal policies and procedures to ensure compliance with all relevant laws and regulations. All members are required to adhere to these policies and procedures.

 

11.3. Cooperation with Regulators: The company agrees to fully cooperate with financial regulators, government authorities, and oversight entities. This includes providing information and records necessary for audits and investigations when legally required.

 

11.4. Non-Conformity Reporting: All members and employees are required to report any situation that may violate laws, regulations, or internal company policies. Reports of non-compliance will be treated confidentially and responsibly.

 

12. Update and Training

 

12.1. Mandatory Training: We require all members and employees to participate in regular training related to ethics, conduct, compliance, and financial regulations. These training programs are designed to keep all members updated on the latest ethical and regulatory practices.

 

12.2. Continuing Education: Atlas Finance & Tech encourages members to pursue relevant continuing education for their roles and responsibilities. This includes participation in courses, seminars, and professional development programs related to the financial industry.

 

12.3. Periodic Review of the Code of Ethics and Conduct: Atlas Finance & Tech's code of ethics will be periodically reviewed to reflect changes in laws, regulations, and industry best practices. Members will be notified of any updates and must be aware of the changes.

 

12.4. Compliance Assessments: The company will conduct regular compliance assessments to ensure that all members are adhering to the ethical and regulatory guidelines established in this code. These assessments may include internal and external audits, as necessary.

 

12.5. Ethics, Conduct, and Training Committee: An Ethics, Conduct, and Training Committee will be established for compliance assessments and updates to the code of Ethics and Conduct. The Committee will also serve as a resource to clarify ethical and compliance-related doubts and concerns.

 

13. Reporting Violations

 

Atlas Finance & Tech establishes an accessible and confidential reporting channel for members, employees, clients, partners, and other stakeholders to report ethical concerns or violations of this code of ethics and conduct or applicable laws and regulations.

 

It is guaranteed that all whistleblowers will have their identity kept confidential whenever possible.

 

 In addition, no retaliation or discrimination will be taken against any person who submits a good-faith report.

 

All reports will be treated fairly and appropriately, with an independent team or committee designated to investigate the reports and take appropriate action to address any identified violations.

 

If a violation is confirmed, the company will take immediate and appropriate corrective action to resolve the situation. This may include implementing disciplinary measures or correcting inappropriate practices or policies.

 

14. Penalties for Non-Compliance

 

In the event of a violation of any provision of this Code, the Compliance and Risk area will be notified, which must evaluate the facts in order to ensure the prompt interruption of irregularity, the timely remediation of damages generated and apply, as the case may be, the disciplinary measures below, in any order, depending on the severity of the situation:

 

Warning by electronic correspondence (email);

 

Suspension of activities, which may vary from 3 (three) to 30 (thirty) days;

 

Contract Termination/Dismissal in accordance with the law.

 

15. Final Provisions

 

Atlas Finance & Tech reaffirms its commitment to integrity, ethics, and excellence in all operations. This code of ethics and conduct serves as an essential guide for all members, partners, and stakeholders who play a key role in our journey.

 

We believe that adhering to these ethical principles and applicable regulations is fundamental to our continued success and to building strong and trustworthy relationships with our clients and partners.

 

As we continue to grow and evolve in the world of financial technology, we remind all members of our team that integrity and ethics must always be at the center of our actions. We value each individual's commitment to upholding this code and working together to achieve our common goals.

 

We thank everyone for their commitment to these principles and for contributing to our culture of responsibility, transparency, and excellence.

 

16. Approval

 

Preparation: Eliane Pereira Guimarães

Revision: Juçara Ap. Mamede Gozi

Approval: Fernando Carlomagno

Deliberation: Compliance and Risk Area

Date: 03/04/2024