Letter from the President

RESPONSIBILITY All of our company’s employees are responsible for taking full responsibility for the actions practiced in the exercise of their position or function. This means not omitting and not transferring to others the responsibility for complying with the policies, standards, and procedures of the company. It is essential that the guidelines made available in this Code of Ethical Conduct be a daily reference for our employees in their relationships and work practices, with all of us being responsible, regardless of our positions, for creating and maintaining a space that ensures mutual respect and conditions of physical and psychological safety. CONFLICT OF INTEREST Conflict of interest in the Employee-Company relationship occurs when the employee uses their influence or commits acts with the intention of favoring private interests that oppose the interest of the company or may cause damage or harm to it. All company employees must avoid actual or potential conflicts of interest. If any employee considers that they might engage in any activity that generates a conflict of interest, they must seek prior approval from their immediate superior or from the representative of the Ethics Committee. The employee may not carry out external activities that compromise their dedication to Vitopel, such as consulting or holding positions in organizations with conflicting interests or that do business with Vitopel. No private commercial transactions will be allowed within the premises of the company. Vitopel will make the “Classifieds” section available on the bulletin boards only to advertise the sale of employees’ own goods. Announcements should be made through the HR of the units and should specify telephone numbers or private contacts so that transactions can be made outside of working hours and the workplace. Corporate links, of their own or through direct family members, with suppliers or competitors of the company are also not accepted if the position the employee holds gives them the power to influence transactions or allows access to privileged information. WORK CONDITIONS We do not admit and do not tolerate forced labor, slave labor or similar conditions, child labor, sexual exploitation and human trafficking in Vitopel’s activities, as well as in our suppliers, customers or business partners. PREJUDICE AND RESPECT FOR DIVERSITY Vitopel does not admit discrimination or prejudice of any kind, including race, hierarchical level, social condition, religion, age, sex, political conviction, nationality, marital status, sexual orientation, or physical condition. ALCOHOL, DRUG AND WEAPON USE The intake of alcoholic beverages during working hours and entering the company in a drunken state is prohibited. It is also forbidden to use or carry drugs and to remain in the work environment in a state altered by the use of these substances, which could affect the safety or performance of other employees. The use of weapons is not allowed on company premises, with the exception of expressly authorized professionals. POLITICAL PARTICIPATION It is forbidden for employees to make, on behalf of Vitopel, any contribution in value, goods, or services for campaigns or political causes, except upon the decision of the company’s Board of Directors, and this contribution must be made in compliance with the effective legislation. Vitopel respects the individual right of employees to become involved in civic affairs and participate in the political process, but such participation must take place in their free time, outside company premises and at their own expense. In this situation, the employee must make it clear that the manifestations are their own and not those of Vitopel. Company resources, space, and image cannot be used to serve personal political or partisan interests. COMPANY ASSETS The company’s assets, equipment, and facilities are intended for the exclusive use of its operations and cannot be used for private purposes. It is the responsibility of the employee to watch over the proper use and conservation of the company’s assets under his/her care, as well as its reimbursement in cases of eventual damage. GIFTS AND PRESENTS No Vitopel employee must accept or offer gifts, directly or indirectly, or favors of a personal nature that may influence decisions, facilitate business or benefit third parties. Gifts may be accepted if they have a value of less than 50 dollars and after authorization by the immediate superior. When the value of the gift exceeds $50, the employee must previously submit it to the knowledge and approval of his or her Management. Giving or receiving cash gifts for any reason is forbidden. PARTICIPATION IN SPONSORED EVENTS Invitations to events with expenses defrayed by customers, suppliers, government agencies, and others, can only be accepted when there is a real opportunity to develop business contacts, which have also been extended to professionals from other companies, and upon prior authorization from the Board of Directors. HARASSMENT AND ABUSE OF POWER Vitopel does not admit any type of sexual, economic, moral harassment or situations that represent pressure, intimidation or threats in the relationship between employees, regardless of their hierarchical level. It is considered abuse of power to use the hierarchical position to request personal services from subordinates. The employee who considers himself/herself discriminated against, a target of prejudice, pressure, or abusive practices or in a situation of disrespect and feels embarrassed to deal with the subject with his/her hierarchical superior, must communicate the fact to the Ethics Committee. PRESS Contact with the press will be promoted, exclusively, by the spokespersons designated by the company, after prior authorization by the Board and orientation by the hired Press Agent. It is forbidden, therefore, for unauthorized persons to make contact with the press on behalf of Vitopel. INTELLECTUAL PROPERTY Intellectual Property is the set of rights inherent to intellectual activity in the industrial, scientific, literary, and artistic fields, including, without limitation, scientific works, inventions, discoveries, industrial designs and models, industrial, commercial, or service marks, patents (registered or not), copyrights, database and database rights, know-how, trade secrets, confidential information, computer programs (software), source codes, and any other similar rights. In Brazil, Intellectual Property rights are mainly governed by laws 9279/1996 (Industrial Property Law), 9610/1998 (Copyright Law), 9660/1998 (Software Law), and other sectorial laws. Vitopel is committed to maintaining an ethical and fair competitive environment, which includes protecting our intellectual property and that of our suppliers, clients, commercial partners, competitors and employees. No employee must misuse the Intellectual Property of Vitopel or third parties, in other words, it is expressly forbidden for an employee to transmit without authorization, misuse, copy, reproduce, reverse engineer or otherwise violate an Intellectual Property right of Vitopel or third parties. The employee must always inform and transmit to Vitopel all materials and information related to any Intellectual Property generated in the course of his relationship with the company. As part of our practice, Vitopel invests in materials, information, know-how, resources and personnel to improve, develop and/or create materials, products or processes, and understands that the improper use of such creations can harm and compromise the company and our ability to supply products and/or services to our clients and business partners. In this sense, all Intellectual Property produced by employees or contractors in the development of their professional activities is the exclusive property of Vitopel. This includes any information, material, document or good (tangible or intangible) that: (a) was developed as a result of an employment contract or results from the services for which the employee or service provider was hired to develop for Vitopel; and/or (b) results from the activities of the employee (even if not linked to the activities or responsibilities arising from his employment contract with Vitopel) that were developed using data, documents, equipment, information, materials, personnel, procedures, computer programs, resources, installations owned or supplied by Vitopel. If the employee develops a work, invention or produces a material that can be considered Intellectual Property under the terms of this Code of Ethical Conduct, such employee undertakes to sign a document assigning free of charge all Intellectual Property rights over such work, invention or material to Vitopel. If applicable, the employee can retain the moral rights of such Intellectual Property in the form of the legislation in force. Unless otherwise agreed upon, the employee has no autonomy over the management and use of the Intellectual Property that he produces or has access to during his relationship with Vitopel, and its use must occur only within the conditions previously agreed upon with the company. Any resource used by employees that has been supplied by Vitopel (including, without limitation, data, documents, equipment, information, materials, personnel, procedures, computer programs, resources and facilities) is the exclusive property of Vitopel and/or licensed for use by such employee. In this sense, the use of such resources by the employee must respect this Code of Ethical Conduct and any other documents (such as contracts, internal policies and guidelines, written or not) made available by Vitopel. The use of a resource made available to the employee in a manner different from that instructed will constitute a violation of the contract between this employee and Vitopel, subject to the applicable penalties. GENERAL LAW OF DATA PROTECTION (LGPD) Vitopel undertakes to meet the requirements of the General Law of Data Protection (Law No. 13,709/2018) and the National Data Protection Authority (ANPD), following the guidelines and guidance in relation to the principles, purpose, protection and treatment of personal data. Therefore, it is the duty of Vitopel’s employee to carry out the appropriate treatment of documents and personal information belonging to Vitopel or third parties, ensuring confidentiality and respect for the General Data Protection Law and Vitopel’s or third parties’ Privacy and Data Protection Policy. CONFIDENTIAL INFORMATION Confidential information is all technical, financial or commercial information made available by Vitopel to the employee, regardless of the media in which it was transmitted, that is not widely available to the public. During his relationship with Vitopel, the employee may have access to such information, materials, documents and resources that belong to the company and are of a strategic and confidential nature. Employees do not have permission to use or share confidential information for any other purpose, except to carry out their commitments with Vitopel, and it is therefore their responsibility to protect it, both inside and outside Vitopel’s premises. Employees must keep confidential information in protected locations, such as drawers and/or cabinets in their workplace, and must not disclose Vitopel’s information in public or shared locations (such as, for example, cafeterias, restaurants or open spaces, among others), even if such locations are within the company. It is important that the employee always has in mind that confidential information is often provided only to specific employees, according to Vitopel’s internal processes and controls. The employee must use confidential information, whether from Vitopel or third parties, only for the purpose for which it was collected. Any disclosure of Vitopel’s confidential information must be made according to the instructions provided by the company itself, respecting the internal policies and processes for disclosure of such information. All Vitopel employees are responsible for the safekeeping of confidential documents and information relating to their activities and must make sure that such documents and confidential information are not exposed during periods of absence from their workstation. Disclosure of this information is not permitted without the express authorization of the company’s management. Physical or virtual access to Vitopel’s networks and facilities can be tracked to ensure that all actions are liable to audit and/or access control in order to identify an employee who behaves contrary to this Code of Ethical Conduct. Confidential information in response to legitimate requests from government authorities must be provided with previous analysis by the Vitopel legal area and only through an employee duly authorized to do so. The improper use or sharing of confidential information of the company or third parties constitutes illegal action and anti-competitive practice, including after the end of the relationship between the employee and Vitopel. Broadly speaking, employees will not be able to: (a) use Vitopel’s information for their own benefit or that of third parties, and the sharing of company information for private e-mails is forbidden, whether of the employee himself or not. Access to or sharing of any information supplied by Vitopel (whether of a confidential nature or not) may only be carried out within the systems made available to the employee or by other means, as long as previously agreed with Vitopel; (b) delete or destroy confidential information without strictly following Vitopel’s information disposal or elimination policies; and (c) use resources and equipment supplied by Vitopel for any purpose other than the exercise of their activities, including installing third party computer programs without the express authorization of the company; INFORMATION AND COMMUNICATION RESOURCES Vitopel has and keeps updated the procedure for equipment management and use of information technology and, therefore, all company employees must respect and follow the rules and guidelines contained therein. HEALTH, SAFETY AND ENVIRONMENT The health and physical integrity of employees and the protection of the environment are priorities for Vitopel. We have adopted an Integrated Management Policy that permeates all company processes, and its compliance is mandatory and obligatory for all employees. As part of our culture, Vitopel determines that its employees respect and comply with all official and governmental acts, requiring compliance with actions aimed at meeting the health rules established by the Public Administration. Thus, the employee must comply with all guidelines issued by federal, state, municipal or indirect public administration authorities related to sanitary, environmental and/or safety rules. In addition, employees must also take all necessary precautions to ensure that health and safety rules are followed during the exercise of their activities for Vitopel. Employees must fully comply with the standards of conduct and procedures eventually demanded by the certifications obtained by Vitopel, available at: https://vitopel.com/en/who-we-are/certifications/  as well as meet the instructions provided by companies related to health, safety, environment and welfare. Vitopel may issue instructions to ensure that its processes occur in a safe manner and take protective measures to prevent accidents, and it is the responsibility of employees to comply with them. Vitopel may keep records of documents and produce reports related to the safety, health and welfare of employees.