Anti-Corruption and Anti-Bribery Policy

Policy Owner: Daniel Peixoto
Effective Date: Sep 24, 2026

Purpose

To prohibit bribery and corruption in every form in Straloo Tecnologia LTDA's business, and to define the controls through which the company prevents, detects, and corrects it.

Straloo Tecnologia LTDA competes on the quality of its products and services. The company does not obtain or retain business, or secure any improper advantage, through improper payments or benefits, and does not tolerate anyone doing so on its behalf.

Scope

This policy applies to all Straloo Tecnologia LTDA employees, contractors, consultants, temporary workers, interns, officers, and partners (sócios), and to every third party acting for or on behalf of the company — including agents, intermediaries, consultants, distributors, public relations and marketing agencies, logistics providers, customs brokers, and joint venture or partnership counterparties.

It applies to dealings with public officials and with private parties alike, in Brazil and in any other country where the company operates.

Applicable laws

Straloo Tecnologia LTDA conducts its business in compliance with the anti-corruption laws applicable to it, including:

Where this policy and applicable law differ, the stricter requirement applies. Local custom, market practice, and commercial pressure are never a justification for departing from this policy.

Prohibited conduct

The following are strictly prohibited, with no exceptions:

1. Offering, promising, giving, authorizing, soliciting, or accepting any bribe — meaning anything of value provided to improperly influence a decision, obtain or retain business, or secure any improper advantage.
2. Corruption, kickbacks, embezzlement, misappropriation, fraud, or influence peddling in any form.
3. Making a payment or providing a benefit to a public official, or to anyone else, to obtain preferential, faster, or otherwise improper treatment.
4. Financing, funding, sponsoring, or in any way subsidising an act prohibited by this policy.
5. Using an intermediary — an agent, consultant, partner, supplier, or any other third party — to do indirectly anything this policy prohibits directly.
6. Obstructing, or interfering with, an investigation or inspection by a public authority or regulator.
7. Frustrating or defrauding a public tender or a contract arising from one.

"Anything of value" is not limited to cash. It includes gifts, hospitality, travel, discounts, favours, loans, donations, sponsorships, employment or internships for relatives, business opportunities, and the use of company assets.

Public officials

Personnel shall not offer or provide anything of value to a public official, to a person acting in a public capacity, to a public body, or to a family member of any of them.

This prohibition is absolute: it applies regardless of amount, regardless of whether the official requested it, and regardless of whether the company stood to gain. It covers officials of any country, employees of state-owned or state-controlled entities, candidates for public office, and officials of political parties.

Ordinary, unavoidable, and transparently documented interactions with public bodies — paying a published official fee, complying with a lawful request, submitting a tender — are not prohibited by this section.

Facilitation payments

Straloo Tecnologia LTDA prohibits facilitation payments.

A facilitation payment is a small, unofficial payment made to secure or speed up a routine action to which the payer is already entitled — for example expediting a licence, permit, inspection, customs clearance, or administrative filing.

The prohibition applies even where such payments are locally customary or locally tolerated, and even where the sum is small. Anyone who is solicited for a facilitation payment shall refuse, and report the solicitation to the Policy Owner.

The single exception is a payment made under duress where a person's safety, health, or liberty is at immediate risk. Such a payment shall be reported to the Policy Owner as soon as it is safe to do so, and recorded accurately in the company's books.

Political contributions

Straloo Tecnologia LTDA does not make contributions of any kind — monetary or otherwise, direct or indirect — to political parties, party officials, candidates for public office, or campaign organisations.

Company funds, assets, personnel time, or facilities shall not be used to support a political campaign. Personnel are free to participate in the political process in their personal capacity, at their own expense and on their own time, and shall not give the impression that they do so on the company's behalf.

Vote buying and the financing of vote buying are prohibited, in line with Lei 9.840/1999.

Charitable donations and sponsorships

Charitable donations and sponsorships shall be made only to bona fide organisations, for legitimate purposes, approved in advance by the Policy Owner, paid to the organisation's own account, and recorded accurately.

A donation or sponsorship shall not be made where it has been requested or suggested by a customer, public official, or counterparty in connection with a pending decision, contract, tender, or approval.

Gifts and hospitality

Gifts and hospitality are governed by the Gifts and Hospitality Policy. Nothing in that policy permits anything that this policy prohibits.

Third parties and intermediaries

A third party acting on the company's behalf can create liability for Straloo Tecnologia LTDA. Accordingly:

• Third parties shall be engaged only after risk-based due diligence under the Third-Party Management Policy, proportionate to the corruption risk of the country, sector, counterparty, and the third party's contact with public officials.
• Engagements shall be documented in a written agreement that includes an obligation to comply with applicable anti-corruption law and with this policy, audit and information rights proportionate to the risk, and a right of termination for breach.
• Remuneration shall be commercially reasonable for the services actually performed, paid to the third party's own account in its country of business, and supported by an invoice describing the work.
• Where a customer or partner requires notice before the company engages a subcontractor or intermediary on work performed for them, that notice shall be given before the engagement.
• Due diligence shall be refreshed periodically and on any change of ownership, control, or risk profile.

Books, records, and internal controls

All transactions shall be recorded accurately, completely, and in reasonable detail in the company's books and records. No account, fund, or asset shall be undisclosed or unrecorded, and no entry shall be false, misleading, or mischaracterised.

The company maintains internal controls designed to prevent, detect, and correct fraud, misappropriation, and unlawful acts, and to support the reliability of its financial statements. Expenses shall be supported by documentation sufficient to establish what was paid, to whom, and why.

Red flags

The following warrant escalation to the Policy Owner before proceeding:

• A counterparty, agent, or partner who requests cash, an unusual payment route, payment to a third country, or payment to an account in another name.
• A request for commission, success fees, or discounts that are out of line with the market or with the work performed.
• A counterparty who declines to accept anti-corruption contract terms, or refuses to answer due diligence questions.
• A recommendation or requirement to use a specific intermediary, made by a public official or by a customer's employee.
• A counterparty who is a public official, a PEP, or connected to one, or who states that they have special influence.
• Vague, missing, or altered invoices and supporting documentation.
• Pressure to complete a transaction urgently, outside the normal approval process.

Reporting

Suspected or actual breaches of this policy, and any solicitation of a bribe or facilitation payment, shall be reported immediately to the Policy Owner at daniel@straloo.com.br, or through the channels in the Whistleblower Policy, including the anonymous channel at https://forms.gle/y5PaTbs1ySW6FqXm8.

Reports made in good faith are protected from retaliation under the Whistleblower Policy. No one will suffer demotion, penalty, loss of business, or any other adverse consequence for refusing to pay a bribe, even if the company loses business as a result.

Training and awareness

Personnel receive guidance on this policy on joining and periodically thereafter, as part of the awareness programme described in the Human Resource Security Policy. Personnel in roles with greater exposure — those dealing with public bodies, procurement, partnerships, or intermediaries — receive additional guidance proportionate to that exposure.

Monitoring and review

Corruption risk is assessed within the process defined in the Risk Management Policy. This policy is reviewed at least annually, and after any material change to the company's operations, counterparties, or applicable law.

Exceptions

Requests for an exception to this policy must be submitted to the IT Manager for approval.

No exception may be granted to the prohibitions in "Prohibited conduct", "Public officials", "Facilitation payments", or "Political contributions".

Violations & enforcement

Any known violations of this policy should be reported to the IT Manager, or through the channels in the Whistleblower Policy.

Violations of this policy can result in immediate withdrawal or suspension of system and network privileges and/or disciplinary action in accordance with company procedures up to and including termination of employment, termination of a third-party relationship, and referral to the competent authorities.

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