Gifts and Hospitality Policy

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

Purpose

To define what gifts and hospitality Straloo Tecnologia LTDA's personnel may offer and receive, so that ordinary business courtesies never become — or appear to become — a means of improperly influencing a decision.

This policy gives effect to the Anti-Corruption and Anti-Bribery Policy in the specific case of gifts and hospitality. Nothing in this policy permits anything that the Anti-Corruption and Anti-Bribery Policy prohibits.

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 covers anything of value offered, given, requested, or received in connection with the company's business, including gifts, meals, entertainment, travel, accommodation, event and conference invitations, discounts not available to the public, loans, favours, and the use of facilities.

General principle

A gift or item of hospitality is acceptable only if all of the following are true. If any one fails, it must be declined.

1. It is not intended, and could not reasonably be perceived, to improperly influence a decision or to obtain any improper advantage.
2. It is not offered or received in exchange for anything, expressly or by implication.
3. It is modest, proportionate, and reasonable in the circumstances.
4. It is infrequent, and not part of a pattern involving the same counterparty.
5. It is given openly and transparently — never in secret, and never to a person's home or private account.
6. It is lawful, and permitted by the recipient's own employer's rules.
7. It is not cash or a cash equivalent.
8. It would not embarrass the company, the recipient, or the giver if it were publicly reported.
9. It is not offered or received while a contract, tender, proposal, renewal, audit, approval, or dispute involving the counterparty is pending or under negotiation.

Absolute prohibitions

The following are prohibited in every case, regardless of value:

• Anything of value to a public official. Straloo Tecnologia LTDA personnel shall not offer or provide any gift or hospitality to a public official, to a person acting in a public capacity, to an employee of a state-owned or state-controlled entity, to a candidate for public office, to a political party official, or to a family member of any of them. This prohibition admits no exception and no approval.
• Cash, cash equivalents, gift cards, vouchers, securities, loans, or the payment or reimbursement of personal expenses.
• Gifts or hospitality solicited or requested, whether for oneself or for a third party.
• Anything offered or accepted in circumstances suggesting an expectation of reciprocity.
• Entertainment that is indecent, sexually oriented, or otherwise inconsistent with the Code of Conduct.
• Travel or accommodation paid for a counterparty, or accepted from one, without the prior written approval of the Policy Owner.
• Gifts or hospitality routed through a family member, intermediary, agent, or any other third party in order to circumvent this policy.

Receiving gifts and hospitality

Personnel may accept a modest gift or item of hospitality that satisfies the general principle above, within these limits:

A promotional item of nominal value carrying a company's branding — a pen, notebook, mug, or similar — may be accepted without recording.

Where declining would cause genuine offence, or where a gift arrives unannounced and cannot practicably be returned, the recipient shall notify the Policy Owner, who may direct that it be returned with an explanation of this policy, donated to charity, or shared among the team. The receipt and the outcome shall be recorded either way.

Offering gifts and hospitality

The same principle and the same limits apply to anything the company offers, with the following additions:

• Gifts and hospitality shall be offered only to private-sector counterparties, never to public officials.
• They shall be provided in the company's name, not in a personal capacity, and paid for by the company with proper documentation.
• Hospitality shall be incidental to a genuine business purpose, and a company representative shall be present.
• The value shall be reasonable relative to the counterparty's seniority and the occasion, and shall respect any limit the counterparty's own policy imposes.
• Anything above the limits in the table above requires the Policy Owner's prior written approval.

Approval and register

Requests for approval shall be made to the Policy Owner in writing, in advance, describing what is proposed, to or from whom, its approximate value, the business purpose, and any pending matter involving the counterparty.

The Policy Owner maintains a gifts and hospitality register recording the date, the counterparty, a description, the estimated value, whether it was offered or received, the business purpose, and the approval decision where one was required. The register is reviewed at least annually and reported to leadership together with the conflict of interest register.

All gifts and hospitality shall be recorded accurately in the company's books and records, in accordance with the Anti-Corruption and Anti-Bribery Policy.

Third parties

Third parties acting on the company's behalf are bound by this policy in respect of that work. Contracts with agents, intermediaries, and partners shall require compliance with it, and shall not permit the third party to do on the company's behalf what the company's own personnel could not do.

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.

Exceptions

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

No exception may be granted to any item listed under "Absolute prohibitions".

Violations & enforcement

Any known violations of this policy should be reported to the IT Manager, or through the channels in the Whistleblower Policy, including the anonymous channel at https://forms.gle/y5PaTbs1ySW6FqXm8.

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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