Code of Ethics & Business Conduct

Revelo's Code of Ethics and Business Conduct is an important instrument that reinforces the company's stance on the values of ethics, integrity, and transparency. The main objective of this document is to present the principles and the way in which the company believes we should act and engage with all stakeholders - clients, employees, partners, suppliers, shareholders, press, etc. - whether in a physical work environment or in a remote setting. Here, our values and positions are reflected to be transmitted and perpetuated by all the individuals who make Revelo happen every day. In addition to establishing the moral values that are expected, this Code also clearly states which behaviors will be allowed and which will not be tolerated within the company.

The guidelines and values presented here must be followed and applied by all employees, partners, suppliers, and anyone who acts on behalf of or for the benefit of Revelo, regardless of position or hierarchical level. It is our duty to ensure compliance with this Code, disseminate it to new team members, promote awareness and updates on the topics covered here, clarify doubts, and consult its content and applications. This document will also serve as the basis for the creation and development of other company policies.

Here at Revelo, we are a community of hundreds of individuals passionate about human relationships, dedicated to empowering careers, teams, and businesses. Everything we have achieved, everything we are, is because of each person who is part of Revelo. We understand that each individual is unique, with their own experiences, purposes, skills, and ideas—a combination that cannot be replicated among the billions of people on this planet. We believe that exceptional talent can change the world when given the opportunity to shine and unleash its potential.

Our purpose is to drive prosperity by enabling outstanding talent from anywhere in the world to meet the global demand for solving the most challenging problems of today and the future. Our mission is to be the backbone of remote work in the Americas.

We are guided by three core values:

1. Ethics, Responsibility, and Legal Compliance: We are all unique, with our own expressions, thoughts, attitudes, and stories. We expect our individual journeys to allow for honest and responsible relationships where it is possible to disagree in a kind, respectful, and empathetic manner. Mistakes are allowed here, and we believe that admitting mistakes is the only way to improve as a company and acommunity. Be honest in your relationships, be willing to listen, learn, and apologize. Respect national and international laws. We expect transparency and assertiveness in your actions with all employees, clients, partners, suppliers, and society as a whole. We adhere to applicable laws regarding Anti-corruption, Anti-bribery, Payment Facilitation to public officials, Anti-money laundering, and Anti-fraud.

2. Respect, Inclusion & Non-discrimination: Diversity enhances creativity and innovation! Different perspectives and experiences are essential for creating a diverse, inclusive, and rich environment. Diverse teams provide welcoming work environments with greater openness for employees to feel comfortable sharing their viewpoints. However, we cannot discuss diversity without discussing inclusion and the importance of reinforcing respect and appreciation for each individual's unique characteristics. When encountering people who are different from you, seize the opportunity to develop empathy, understanding, and active listening, while also dismantling prejudices. Always choose non-violent communication when expressing your point of view—everyone has the right to be heard and respected, as long as respect is preserved.

3. Leadership: Leading by Example and Inspiration! Leading a team goes beyond simply delegating tasks to your subordinates. A good leader should stimulate the creative capacity within people, encourage the team with enthusiasm, inspiring trust and a desire to grow alongside the company. Always strive to make decisions that contribute to the best outcome for everyone, be a good listener, and be open to dialogue and feedback. Highlight the best in each individual and acknowledge good performance, which will keep your team motivated and committed. The relationship between leader and team members should be based on respect, transparency, and humility, creating a relationship of trust and a safe environment where employees feel comfortable and confident in carrying out their daily duties.

4. Relationship with Third Parties and Other Stakeholders: We are committed to always acting with ethics, responsibility, and transparency in our relationships with third parties and all other stakeholders of the company. We avoid any actions that may be perceived as dishonest, including situations involving conflicts of interest or generating undue advantages. We fulfill the commitments we make and always act with respect.

5. Conflicts of Interest (Gifts, Presents, and Hospitality): We consider a conflict of interest to occur when a Revelo employee is in a situation that may lead them to make a decision that goes against the interests of Revelo. The following situations may be considered conflicts of interest:

• Harassment: It encompasses a wide range of unwanted and/or offensive behaviors that are or appear to be disturbing and/or threatening. Typically, the behavior is systematic and/or ongoing, targeting one or more individuals that disrupts, restricts, or affects the dignity of one or more persons, whether through actions, gestures, verbal or written communication. Harassment can take the form of bullying, unwanted/non-reciprocal sexual conduct or communication, psychological pressure, prejudice, or physical or moral abuse derived from hierarchical or subordinate positions. Revelo condemnsany action in this regard and aims to ensure a harassment-free work environment, where our employees can feel comfortable, safe, and happy. Therefore, we do not tolerate any form of harassment in the workplace. We believe that the best way to combat this type of behavior is by fostering a friendly culture based on respect and transparency. Suspicious behaviors include, but are not limited to, cases where a Revelo employee: (i) sabotages the work of another Revelo employee with the intention of harming that person; (ii) engages in unexpected and frequent promotions or denunciations; (iii) makes or spreads malicious, defamatory, offensive, and/or discriminatory comments about other Revelo employees; (iv) ridicules, mocks, or makes inappropriate jokes about a colleague in front of others; (v) is forced to perform tasks against their will, especially those unrelated to their job function within the contractual relationship with Revelo; (vi) touches a coworker inappropriately or in a malicious manner; (vii) shows or shares explicitly sexual, discriminatory, and/or offensive images; (viii) makes aggressive, invasive, and/or sexually and/or discriminatory comments about another person's way of being or dressing; (ix) repeatedly and without consent invites someone to go out or engage in any form of intimacy.

• Acting on behalf of and representing the company without authorization: Revelo can only be represented by individuals legally constituted through a power of attorney granted by Revelo's legal representative and in accordance with its by laws, or as a result of a service contract in which "representation" is limited to its object. No employee, supplier, or service provider is authorized to act on behalf of Revelo to give interviews or make public statements without prior express authorization. Any intolerable attitude that is identified or suspected must be reported to the Ethics Committee for investigation and the application of appropriate penalties, according to each case.

• Romantic relationships between Revelo employees: are allowed, as long as there is no direct or indirect subordinate relationship between them, and provided that the individuals involved are not part of the same work team. This is to avoid any conflict of interest or harm to the activities performed.

• Conflict of Interest: In the performance of their duties, all Revelo employees have an obligation to act in the best interest of Revelo. A conflict of interest may arise when, due to personal interest or that of a third party, a Revelo employee may be influenced to act against this Code or any other internal policy of Revelo, in violation of their contractual obligations and causing harm and/or damage to Revelo. All employees must avoid situations that may represent a real or apparent conflict of interest, and they must disclose the existence of such conflict to their immediate supervisor, the Human Resources department, or the Ethics Committee.

• Corruption: We do not tolerate any practices that are contrary to the anti-corruption laws in force in Brazil, Mexico, the United States of America, and other countries where Revelo operates or where its partners and/or shareholders are based. It is expressly prohibited for any employee to offer, promise, or receive any type of benefit, hospitality, advantage, or gifts with an economic value, or to make any payment to public officials or representatives of public entities ("Public Agents"), whether national or foreign, with the aim of conducting, retaining, and/or obtaining an advantage in business. Any payment of political, electoral, public event contributions, and/or bribery practices related to public or private agents is also prohibited, in accordance with the definition provided by the Applicable Law, in any circumstances. Any meeting held with Public Agents must be attended by a minimum of 2 (two) Revelo representatives and must be documented in writing in the respective minutes, which should include: (i) the names of the participants; (ii) date, location, and time; (iii) topics discussed; and (iv) signatures of all participants.

• Discrimination of any kind: Discrimination is the unfair or harmful treatment of different categories of people, including race, age, physical or mental disability, or sexual preference. Discrimination is defined as treating people in similar situations differently based on one or more criteria prohibited by law, such as discrimination against strikers, discrimination related to opinions and beliefs, or discrimination related to the person, among others. Suspicious behaviors include, but are not limited to, cases where (i) a Revelo employee denies another employee the possibility of professional growth due to their age, race, gender, religion, sexual preference, or any other subjective characteristic unrelated to the job; (ii) a Revelo employee requests that another employee perform a task based on their age, race, skin color, gender, or any other subjective reason unrelated to the job.

• Disclosure or improper use of any Confidential Information: Each employee declares agreement with the company's Confidential Information and Privacy protection policy, as well as being aware of the applicable penalties under the law in the event of misuse of such information.

• Workplace violence, whether in remote work or in-person at occasional meetings: It refers to any threat or acts of verbal and/or physical violence committed by a Revelo employee against another employee or third parties, including verbal, written, and/or gestural offenses and threats. Revelo does not allow the use of firearms or weapons in the workplace under any circumstances.

• Use of alcohol and toxic substances: Revelo prohibits and does not tolerate the use, distribution, and/or commercialization of alcohol, narcotics, and/or drugs in the workplace and Revelo's facilities.

• Improper use of company assets: All employees are prohibited from misusing, personally or through third parties, the company's assets, including but not limited to financial resources, motor vehicles, and electronic equipment owned by Revelo. Violation of this provision is subject to penalties provided by law.

We believe that a good leader builds a successful team, so it is important that our leaders be our greatest examples and make their best efforts so that, together with their team, everyone knows and respects this manual. Our leaders should promote an inspiring and inclusive work environment and not differentiate based on personal characteristics of clients, employees, candidates, or third parties. Furthermore, they should preserve the integrity of the information they come into contact with due to their position and never use it for personal gain.

The leader should make decisions and allocate tangible and intangible resources and assets of Revelo in accordance with the previously established company standards and in compliance with its internal policies, regulations, and business objectives, refraining from any action based on favoritism or any form of individual benefit or contrary to the law. It is essential to respect employees or third parties and refrain from any conduct that could be characterized as abuse of power, moral, sexual, or any other form of harassment.
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Lastly, any practice of bribery or public or private corruption is strictly prohibited, andfirm action must be taken to prevent any such occurrences. Our Workplace Harassment and Discrimination Policy aims to make the rules of conduct clear in order to prevent any occurrence of discrimination or harassment, of any nature.

To achieve this, we must protect all employees against any form of discriminatory or harassing conduct, establish a culture of justice and mutual respect, and create channels for reporting. All employees must be aware of these guidelines and follow the established directives, under the penalty of termination of their employment contract and civil and criminal sanctions.

This manual, in addition to being provided at the time of hiring for all employees, will always be available at the time of admission to the company. If you need to consult it later, please request it from the People team.

The Revelo Code of Ethics and Business Conduct should guide all our actions in our daily lives and should be consistently put into practice, with its principles being absorbed and implemented naturally by everyone who is part of the company. If you encounter an ethical dilemma or have doubts about how to act in a particular situation, use the following questions to help you make the right decision:

Remember: the image and reputation, both yours and the company's, depend on each and every one of us! And if you come across any irregularities being committed by a colleague or third party, use the Ethics Channel to protect our values and integrity as an institution.

If you come across an act - whether by employees or third parties - that involves misconduct or violates this code, Revelo's policies, or even current laws, you have a duty to inform Revelo so that corrective measures can be taken immediately. For this purpose, the company provides an Ethics Channel for you to protect your integrity and that of the company.

The Ethics Channel is a platform focused on being a listening channel, capable of making the reporting person's experience as comfortable as possible. The main objective is for employees to feel comfortable and encouraged to report any irregularities, violations of laws, or inappropriate behavior that has occurred to themselves or to others in their work environment.

Reports can be made anonymously or identified, and the information will be treated confidentially. After an initial assessment by professionals trained in the subject, the report is forwarded to the Ethics Committee while maintaining the reporter's anonymity. The situation will be evaluated, and a final resolution will be reached in accordance with the Consequences Policy. If you feel uncomfortable with any situation, even if it is not explicitly stated in this document, please use our Ethics Channel or seek assistance from someone you trust within the company. We are here to help you!

Disregard for the Code, Revelo's policies, or even current laws may result in disciplinary actions according to the severity of the misconduct, with the employee subject to:

Reports will be received through the Ethics Channel, a tool dedicated exclusively to this purpose, and will be evaluated and handled by the Ethics Committee, which is defined in the subsequent item.

The Revelo Ethics Committee is a non-statutory body of a permanent nature, constituted in a diverse and representative manner with the objective of acting as an advisory, independent, and permanent body on Ethics, Integrity, Transparency, and Conduct matters.

The committee will meet quarterly to deliberate and discuss ethics and conduct-related topics that are of interest to the company. Any communication with the Revelo Ethics Committee should be made through the official reporting channel (Ethics Channel) or via the email address ethics@revelo.com.

The Revelo Code of Ethics and Business Conduct reflects the company's principles, therefore, all employees and third parties acting on behalf of the company are responsible for upholding the guidelines contained in this document. The management of the Code will be the responsibility of the Ethics Committee, which will also ensure compliance with the presented guidelines. The updating and validation of the document will be the responsibility of the Compliance team, which is part of the People department.

Definitions: Employees, Collaborators, Staff, or Reveloers: All employees of Revelo, as well as its subsidiaries and affiliates, regardless of hierarchical level, including employed and statutory directors, executives, shareholders, and board members.

Ethics Committee: The Revelo Ethics Committee is a non-statutory permanent body constituted with the objective of acting as an advisory, independent, and permanententity in matters of Ethics, Integrity, Transparency, and Conduct.

Founders: The founding executive directors of the company, namely Lucas Mendes and Lachlan de Crespigny.

Revelo, Company, or Corporation: Refers to Revelo, including its controlled and affiliated companies.

Third Parties or Stakeholders: Shareholders, Suppliers, Competitors, Press, Community, Unions and Associations, Government, and Public Agents. Encompasses all service providers, business partners, representatives, suppliers, outsourced employees, offices, consulting firms, and any other individuals or legal entities acting on behalf, interest, orbenefit of Revelo.