Code of Ethics

This English version is a convenience translation. In case of any discrepancy, the Portuguese version prevails.

January 2026 — Version 1.0

1. Purpose

The purpose of this Code of Ethics is to make public the values and principles of Decade Wealth Management Ltda ("Decade" or the "Company") and of all other entities controlled by and affiliated with the Decade group, establishing the ethical and conduct standards expected of all employees, both in their internal performance and in their communications with the various stakeholders, including clients, partners, suppliers, competitors, and regulatory bodies.

This Code aims to promote an ethical, responsible, and professional work environment, ensuring that all actions are aligned with the highest standards of integrity and in compliance with applicable law.

In compliance with Article 14, item II, of CVM Resolution No. 19/2021, this Code is available on Decade's website for public consultation.

2. Applicability

This policy applies to Decade Wealth Management Ltda (CNPJ 64.755.417/0001-47) and to all other entities controlled by and affiliated with the Decade group, collectively referred to as "Decade" or the "Company" in this document.

This Code applies to all "Employees," understood as those persons who hold a position, function, role, corporate relationship, employment relationship, commercial, professional, contractual, or fiduciary relationship with Decade, including:

• Members of the Board of Directors
• Directors and executives
• Employees and service providers
• External consultants and advisors
• Interns and trainees
• Other persons acting on behalf of or in representation of Decade

All Employees, upon receiving this Code, must sign the Acknowledgment and Commitment Term, confirming that they have read, understood, and resolved any questions regarding the provisions of this Code. Signing this term is an essential condition for beginning or continuing activities with Decade.

3. Parties Responsible for the Code

The coordination, implementation, monitoring, and oversight of activities related to this Code are the responsibility of the Compliance Team, composed of the Compliance Officer and the other Employees who assist in Decade's compliance activities.

The Compliance Team is responsible for:

• Ensuring the dissemination of and training on the Code for all Employees
• Monitoring compliance with the guidelines established in this document
• Receiving and analyzing reports or inquiries related to ethical matters
• Proposing updates and improvements to the Code
• Reporting to the Board of Directors and the Executive Board on compliance with the Code

The Compliance Officer acts independently, reporting directly to the Board of Directors, ensuring the impartiality and effectiveness of compliance actions.

4. Legal Basis

This Code was prepared in compliance with the Brazilian legislation and regulations applicable to securities advisory activities, including, but not limited to:

1. Resolution No. 19 of the Securities and Exchange Commission ("CVM"), of February 25, 2021, as amended by CVM Resolution No. 179/2023 ("CVM Resolution 19"), which governs securities advisory activity;
2. Code of Ethics of the Brazilian Financial and Capital Markets Association ("ANBIMA"), applicable to securities advisors;
3. Law No. 6,385, of December 7, 1976, which governs the securities market;
4. CVM Instruction No. 358, of January 3, 2002, which governs the disclosure and use of information regarding material acts or facts;
5. Law No. 13,709, of August 14, 2018 (General Data Protection Law — LGPD), which governs the protection of personal data;
6. Other statements, guidance letters, and resolutions of the regulatory and self-regulatory bodies applicable to Decade's activities.

5. Principles, Values, and Standards of Ethical Conduct

All Employees must fully respect the principles, values, and standards of ethical conduct described below. This Code shall be filed internally and made available for permanent consultation by all Employees.

5.1. Guiding Ethical Principles

The ethical principles that guide Decade's activities are:

• Integrity: Commitment to professional, ethical, and honest actions in all circumstances.
• Respect: Actions based on the rights, duties, and aspirations of employees, clients, and other stakeholders.
• Transparency: Clear and objective actions, focused on the results and quality of the services provided, with appropriate disclosure of information.
• Honesty: Actions that strictly conform to the rules of good conduct and market best practices.
• Trust: Actions guided by responsibility, reliability, and credibility before clients and the market.
• Confidentiality: Absolute secrecy in the handling of non-public, privileged, or confidential information.
• Quality: Continuous pursuit of excellence in the execution of actions and in the provision of services.
• Independence: Acting free from external influences that could compromise professional judgment and the provision of advisory services.
• Loyalty: Commitment to the interests of clients, always placing them above one's own interests or those of Decade.
• Diligence: Care and attention in the performance of duties, applying the diligence that any prudent and responsible person customarily devotes to their own affairs.

5.2. Standards of Conduct

All Employees must follow the following standards of conduct, including, but not limited to:

• Knowing and complying with the legislation and internal rules, acting with transparency and respect for the laws and regulatory bodies.
• Acting in good faith, with transparency, diligence, and loyalty, always prioritizing the interests of clients (CVM Res. 19/2021, art. 16, I).
• Providing advice independently and on a well-founded basis, without influence from third parties or conflicts.
• Contributing to the reputation of Decade and its values.
• Identifying, managing, and mitigating conflicts of interest that affect impartiality.
• Maintaining sound professional and moral conduct.
• Fulfilling obligations with diligence, being accountable for acts and infractions.
• Acting with free initiative and competition, avoiding unfair practices.
• Avoiding conflicts between personal interests, those of Decade, and those of clients.
• Keeping documentation up to date (including the client profile) for clients and regulators.
• Transferring to clients the benefits obtained, except where the regulations permit otherwise.
• Not discriminating (origin, ethnicity, religion, sex, etc.).
• Trusting one's own judgment and contributing to a healthy work environment.
• Immediately informing the Compliance Officer of situations of risk or violation.
• Informing the CVM of occurrences or indications of violation of the legislation under its supervision, within 10 business days (CVM Res. 19/2021, art. 16, XI).

5.3. Work Environment Free of Discrimination and Harassment

Decade has adopted the standards of conduct described above to create a work environment free of discrimination of any kind, including moral, sexual, or other types of harassment in the workplace.

Attitudes that constitute the following will not be tolerated:

• Moral harassment (abusive conduct that undermines the dignity or psychological integrity of the employee)
• Sexual harassment (unwanted conduct of a sexual nature)
• Discrimination based on origin, race, color, sex, sexual orientation, age, religion, disability, or any other condition
• Intimidation, humiliation, or embarrassment of colleagues, subordinates, or superiors

Any situation of this nature must be immediately reported to the Compliance Officer for appropriate measures.

6. Relationship with Clients, the Market, and Competitors

6.1. Relationship with Clients

Respect for the rights of clients must be reflected in concrete attitudes and actions that seek the ongoing satisfaction of their expectations regarding the advisory services provided by Decade. All Employees must be aware that maximizing client satisfaction is Decade's primary objective, with a direct impact on its corporate and institutional image.

Employees must always seek to serve the interests of Decade's clients, observing the following principles:

• Fiduciary Duty: Avoiding practices that could harm the fiduciary relationship maintained with clients, always acting with loyalty and in their best interest;
• Suitability to Profile: Performing their duties in a manner that seeks to meet clients' investment objectives, taking into account their financial situation and profile, in accordance with the regulations on suitability;
• Transparency: Providing clear, objective, truthful, and complete information about the advisory services, without misleading the client;
• Information on Risks: Providing clients with information about the risks involved in the recommended transactions, including making clear that certain transactions (such as derivatives) may result in losses exceeding the amount invested;
• Rationale: Providing the information requested by the client that is relevant to the basis of the investment recommendations made;
• Confidentiality: Any and all information relating to Decade's clients is considered the exclusive property of Decade, subject to the obligation of confidentiality. Its use is the responsibility of the partners, administrators, and the Compliance Officer. All Employees are permanently obliged to ensure that the use they intend to make of such information complies with the terms of this Code and with the General Data Protection Law (LGPD);
• Prohibition of Guarantees: Information relating to the provision of advisory services may not ensure or suggest the existence of a guarantee of future results or the absence of risk to the investor.

6.2. Relationship with the Market

Decade is committed to protecting market information and to maintaining the integrity and soundness of the securities markets.

The following is absolutely prohibited:

• Using privileged information (insider information) to carry out transactions or recommendations, for one's own benefit or that of third parties
• Disclosing privileged information prior to its disclosure to the market
• Manipulating prices or creating artificial conditions of demand, supply, or price of securities
• Carrying out fraudulent transactions or inequitable practices

Information provided to the market shall always have a legal, regulatory, and ethical basis, in accordance with this Code, and may not be disrespectful toward the other participants in the financial and capital markets.

6.3. Relationship with Competitors

Decade respects all competitors and seeks to promote fair and loyal competition, based on ethical principles and following the applicable rules and legislation, especially the antitrust legislation.

Comments or rumors that could harm the business or image of competing companies will not be disseminated, and Decade requires and expects reciprocal and cordial treatment from such companies.

It is absolutely prohibited to disclose any relevant information or information of interest to Decade to its competitors, except in exceptional cases, subject to the prior and express authorization of the Compliance Officer.

7. Relationship with Suppliers and Service Providers

Decade, guided by the highest standards of conduct, honors its commitments to its suppliers and service providers ("Third Parties"), always seeking to establish objective, efficient, and appropriate contracts for the proper conduct of its business, which, to the extent possible, should not leave room for multiple interpretations or contain material omissions or ambiguities.

Technical, professional, market, logistical, and ethical criteria, in the best interest of Decade and its clients, must always prevail in the selection of Third Parties.

All Third Parties will be analyzed before being engaged by Decade, respecting best practices and contributing to the fight against money laundering, terrorism financing, and corruption.

Decade adopts manual verification and due diligence procedures for Third Parties, with the possibility of implementing automated systems in the future.

8. Relationships in the Work Environment

It is essential to maintain a harmonious and respectful coexistence in the work environment among Employees. It is fundamental to preserve this environment, fostering among Employees a spirit of teamwork, innovation, and maximization of results.

Decade's partners and administrators must serve as examples of conduct for the other Employees. The use of one's position to obtain illicit or immoral benefits, or to obtain, to the detriment of Decade or of subordinates, any type of personal advantage, whether inside or outside Decade, will not be tolerated.

All Employees will have equal opportunities for professional development, recognizing the merits, competencies, characteristics, and contributions of each individual toward achieving Decade's goals.

9. Relationship with Supervisory and Oversight Bodies

Compliance with the determinations of the supervisory and oversight bodies of the financial and capital markets, as well as strict adherence to the rules in force, represents an essential part of Decade's ethical conduct.

Decade undertakes to:

• Maintain a transparent, respectful, and collaborative relationship with the CVM, ANBIMA, and other regulatory and self-regulatory bodies;
• Promptly respond to requests for information and documents made by the supervisory and oversight bodies;
• Inform the CVM whenever it verifies the occurrence or indications of a violation of the legislation that the CVM is responsible for supervising, within a maximum period of 10 (ten) business days from the occurrence or identification, as provided in Article 16, item XI, of CVM Resolution 19/2021;
• Provide any other information required by the other oversight bodies within the legal deadline.

10. Advantages, Benefits, and Gifts

Employees must not, directly or indirectly, whether for themselves or for third parties, solicit, accept, or allow money, benefits, favors, gifts, promises, or any other advantages that could influence the performance of their duties or as a reward for an act or omission arising from their work.

10.1. Permitted Exceptions

The following benefits or gifts may be permitted:

• Meals: Provided they are not of a value high enough to influence the proper performance of the Employee's duties;
• Advertising or Promotional Material: Up to USD 100 (one hundred U.S. dollars) or the equivalent in reais, distributed in the normal course of business;
• Gifts on Festive Occasions: Up to USD 100 (one hundred U.S. dollars) or the equivalent in reais, customarily offered on the occasion of a birthday, Christmas, year-end, or similar occasions;
• Other Gifts or Benefits: Up to USD 100 (one hundred U.S. dollars) or the equivalent in reais;
• Gifts from Family and Friends: Without restrictions, provided they are not connected with the Employee's professional duties and responsibilities.

If the benefit or gift does not fall within the exceptions above, the Employee may only accept it with the prior authorization of the Compliance Officer.

When in doubt about the appropriateness of accepting a particular benefit or gift, the Employee must always consult the Compliance Officer before accepting it.

11. Conflict of Interest

11.1. Definition

Conflicts of interest are situations arising from the performance of a given Employee's duties, in which such Employee's personal interests may be divergent from or in conflict with the interests of Decade and/or between the interests of two or more clients, to whom Decade owes a fiduciary duty.

11.2. Duty to Identify and Report

The Employee has the duty to act in good faith and in accordance with the interests of investors, in order not to harm the fiduciary relationship with the client. To this end, the Employee must be alert to a possible situation of conflict of interest, and whenever such a situation arises they must:

1. Immediately inform the Compliance Officer of its existence;
2. Refrain from carrying out the act or omission giving rise to the Conflict of Interest until a decision to the contrary by the Compliance Officer;
3. Await guidance on the measures to mitigate or eliminate the conflict.

11.3. Examples of Conflicts of Interest

By way of mere example, the following are considered situations of possible conflict of interest:

• Influence on judgment: Situations in which the Employee's professional judgment may be unduly influenced by personal, financial, or third-party interests;
• Diversion of business opportunities: Personal exploitation of opportunities that should be allocated to Decade or to clients;
• Competition: Engaging in activities that compete with the activities and/or business carried out by Decade;
• Personal relationships: Analysis or recommendation of securities issued by companies with which the Employee has a personal relationship with individuals in decision-making positions or who may have access to confidential information;
• Personal investments: Carrying out personal transactions in securities that are the subject of recommendation to Decade's clients (see the Securities Trading Policy);
• Use of time: Significant use of the Employee's time or attention on activities other than those performed for Decade, reducing their efficiency and productivity;
• Damage to reputation: Situations that could cause damage to the reputation of the Employee and/or of Decade;
• Exclusive benefits: The characterization of exclusive benefits to the Employee at the expense of Decade or its clients.

11.4. Mitigation Measures

Upon identifying any situation of potential conflict of interest between the activities provided by Decade, by its Employees, and/or vis-à-vis clients, Decade undertakes to take all appropriate measures for the continuous observance of its duty of fiduciary loyalty and good faith in its performance, including, among others and as applicable:

• Informing the client whenever a conflict of interest is identified, indicating the sources of that conflict and presenting the appropriate alternatives for its mitigation;
• Observing the principle of full disclosure (broad transparency and awareness) to the client, in accordance with the prohibition in Article 18, item IV, of CVM Resolution 19/2021, against omitting information on conflicts of interest;
• Implementing measures to segregate activities, when applicable;
• Refusing to act in situations where the conflict cannot be adequately mitigated;
• Other measures determined by the Compliance Officer for the mitigation or complete elimination of the respective conflict.

Should any other exceptional situations of conflict of interest be identified, it is the responsibility of the Compliance Officer to discuss and decide on the resolution of these conflicts.

As a measure to prevent potential Conflicts of Interest, Employees must follow this Code, as well as Decade's other applicable internal policies, especially the Securities Trading Policy.

12. Compliance Officer

The Compliance Officer is responsible for implementing and ensuring compliance with Decade's internal rules, procedures, and controls, as well as the standards established in CVM Resolution 19/2021 and other applicable regulations.

12.1. Duties and Responsibilities

The duties of the Compliance Officer are:

• Coordinating and monitoring the activities related to this Code of Ethics;
• Ensuring the dissemination of the Code to all Employees;
• Receiving, analyzing, and taking action regarding reports, inquiries, or situations that may constitute a violation of the Code or of the applicable regulations;
• Resolving questions about the application of the Code and internal policies;
• Deciding on situations of conflict of interest and determining mitigation measures;
• Approving exceptions to the rules established in this Code, when appropriate and justified;
• Periodically reporting to the Board of Directors and the Executive Board on compliance with the Code;
• Proposing updates and improvements to the Code;
• Maintaining a relationship with the CVM, ANBIMA, and other regulatory bodies on compliance matters.

12.2. Independence

The Compliance Officer must perform their functions with independence, reporting directly to the Board of Directors, ensuring the impartiality and effectiveness of compliance actions.

The compensation of the Compliance Officer may not be associated with Decade's commercial performance, so as to ensure their independence in the exercise of their functions.

13. Specific Prohibitions

In accordance with Article 18 of CVM Resolution 19/2021, Decade's Employees are expressly prohibited from:

• Acting in the structuring, origination, and distribution of products that are the subject of guidance, recommendation, and advice to Decade's clients, unless the provisions on the segregation of activities set forth in Article 21 of CVM Resolution 19/2021 are observed;
• Making any type of relevant modification to the basic characteristics of the services provided, except with the prior written authorization of the client;
• Guaranteeing levels of profitability or ensuring future results to clients;
• Omitting information about conflicts of interest and risks relating to the subject of the advisory services provided;
• Receiving any compensation, benefit, or advantage, directly or indirectly through related parties, that could potentially impair independence in the provision of securities advisory services, except where the advice is provided to clients classified as professional investors, provided that they expressly attest in writing to a statement of awareness, in accordance with CVM Resolution 19/2021;
• Acting as attorney-in-fact or representative of clients before institutions that are part of the securities distribution system, for the purpose of implementing and executing the transactions that reflect the recommendations that are the subject of the advisory services provided.

In addition to the prohibitions above, Employees must observe the following prohibitions:

• Using privileged information (insider information) for one's own benefit or that of third parties;
• Manipulating prices or creating artificial market conditions;
• Carrying out fraudulent transactions or inequitable practices;
• Disclosing confidential client information without authorization;
• Making investment recommendations without adequate justification;
• Recommending products unsuitable to the client's profile.

14. Consequences for Non-Compliance

Failure to comply with the provisions of this Code of Ethics may give rise to the application of disciplinary measures and sanctions, which will be determined by Decade in accordance with the severity of the infraction, and may include:

• Verbal warning;
• Written warning;
• Temporary suspension of activities;
• Termination of the employment contract or service agreement for just cause;
• Termination of the corporate or professional relationship;
• Reporting the fact to the competent authorities (CVM, Public Prosecutor's Office, police), when it constitutes an infraction of the legislation in force.

The application of internal sanctions does not exclude the possibility of civil, administrative, and criminal liability of the offending Employee, in accordance with the applicable legislation.

Decade may also be subject to sanctions by the CVM and other regulatory bodies in the event of non-compliance with CVM Resolution 19/2021, in accordance with Article 24 of that Resolution, which considers the violation of the rules contained in Articles 16, 18, 20, 21, 22, and 23 to be a serious infraction.

All Employees have the duty to cooperate with internal or external investigations related to possible violations of this Code.

15. Effectiveness and Updating

This Code of Ethics enters into force on the date of its approval by Decade's Board of Directors and will be reviewed annually, and may be amended at any time due to circumstances that require such action, including changes in the applicable legislation or regulations, changes in Decade's activities, or the identification of needs for improvement.

Any changes to this Code will be duly communicated to all Employees, who must acknowledge them and sign a new Commitment Term, when applicable.

The updated version of this Code will always be available on Decade's website and in the internal systems for permanent consultation.

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