Conflict of Interest Policy

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

Purpose

To define how Straloo Tecnologia LTDA identifies, discloses, assesses, and manages conflicts of interest, so that business decisions are made on the merits and in the company's legitimate interest, and so that personal relationships or outside interests never improperly influence the company's dealings with customers, partners, suppliers, investors, or public bodies.

This policy supports the commitments made in our Code of Conduct and complements the Anti-Corruption and Anti-Bribery Policy and the Gifts and Hospitality Policy.

Scope

This policy applies to all Straloo Tecnologia LTDA employees, contractors, consultants, temporary workers, interns, officers, and partners (sócios), and to anyone acting on the company's behalf.

It applies to actual conflicts, potential conflicts, and situations that a reasonable outside observer could perceive as a conflict. A perceived conflict must be disclosed on the same terms as an actual one.

What is a conflict of interest

A conflict of interest exists whenever a person's private interest — financial, personal, family, or professional — interferes, or could reasonably appear to interfere, with their ability to act in the best interest of Straloo Tecnologia LTDA.

A conflict is not in itself misconduct. Failing to disclose it is.

Situations that must be disclosed

The following must be disclosed in every case:

• A financial, commercial, or ownership interest in a customer, prospective customer, supplier, competitor, partner, or investor of Straloo Tecnologia LTDA, other than a small holding in a publicly traded company.
• A personal relationship — family, marriage or equivalent partnership, close friendship, or a shared financial interest — with an employee, director, or decision-maker of a customer, prospective customer, supplier, competitor, partner, or investor, where that person is or may be involved in a transaction with Straloo Tecnologia LTDA.
• A personal relationship of the kind described above between two people inside Straloo Tecnologia LTDA where one reports to, evaluates, or sets the compensation of the other.
• Outside employment, consulting, advisory work, or a board, committee, or governance position in another company or entity, whether paid or unpaid, that relates to Straloo Tecnologia LTDA's business or could compete for the person's time, attention, or loyalty.
• Being a Politically Exposed Person (PEP), having held a relevant public office in the last five years, or having a close family member in either category.
• Any business dealing, benefit, or arrangement between the person (or a family member) and a public official, public body, or political party.
• Participation in a hiring, procurement, contracting, or vendor-selection decision involving a party connected to the person by any of the relationships above.
• Receiving or offering a gift or hospitality outside the limits of the Gifts and Hospitality Policy.
• Any opportunity discovered through the person's role at Straloo Tecnologia LTDA that they wish to pursue personally.

Disclosure

Disclosures shall be made to the Policy Owner in writing, at the earliest of: joining the company, the conflict arising, or becoming aware of it — and in any event before participating in the decision affected.

Where the conflict concerns the Policy Owner, the disclosure shall be made to the remaining member of the company's leadership.

Disclosures may also be raised through the channels in the Whistleblower Policy, including the anonymous channel, where the discloser prefers.

Personnel shall confirm their disclosures, or confirm that they have none, at least annually.

Assessment and management

On receiving a disclosure, the Policy Owner shall record it and decide, proportionately to the risk, how the conflict will be managed. Available measures include:

• Recording the conflict with no further action, where the risk is immaterial.
• Removing the person from the decision, negotiation, evaluation, or approval concerned (recusal).
• Reassigning the relationship, account, or reporting line.
• Requiring additional review or a second approver for the affected decision.
• Disclosing the conflict to the affected counterparty.
• Requiring the person to divest the interest or step down from the outside position.
• Declining the transaction or relationship.

The decision and its rationale shall be recorded. A conflict that cannot be managed effectively shall be resolved by declining the underlying transaction or relationship.

Related-party and counterparty transactions

Any transaction between Straloo Tecnologia LTDA and a partner (sócio), officer, employee, or a party connected to one of them shall be disclosed in advance, approved by a leadership member with no interest in it, and recorded on arm's-length terms.

Where a customer, partner, or investor asks the company to declare connections between our personnel and theirs — including in supplier due diligence questionnaires — the declaration shall be made from the disclosure register, and any new connection identified in the process shall be recorded as a disclosure.

Records

The Policy Owner maintains a conflict of interest register recording each disclosure, the assessment, the management measure applied, and the date. The register is confidential and access is restricted; it is retained in accordance with the Data Management Policy.

The Policy Owner reports to leadership at least annually on the disclosures received and how they were managed.

Training

Personnel receive guidance on this policy on joining and periodically thereafter, as part of the awareness programme described in the Human Resource Security Policy.

Exceptions

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

No exception may waive the obligation to disclose a conflict.

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.

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