Personal Investments Policy

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

March 2026 — Version 1.0

1. Purpose

The purpose of this instrument is to formalize the Securities Trading Policy ("Personal Investments Policy"), in order to avoid potential conflicts of interest between the interests of the clients of Decade Wealth Management Ltda ("the Advisory firm") and the personal investments of the team, as well as those made by the Advisory firm's treasury within the scope of the financial and capital markets.

Accordingly, it aims to allow the Advisory firm's teams to invest their resources efficiently, preventing the improper use of inside information, speculative conduct, and, above all, their personal interests from overriding those of the Advisory firm and its clients.

2. Scope

The guidelines established in this Personal Investments Policy must be observed by the entire team of the Advisory firm, in particular those involved, directly or indirectly, in the securities advisory activity.

3. Methodology

All securities trading involving members of the Advisory firm's team must take place with the aim of maintaining such assets as an investment, holding the position for a minimum period of 30 (thirty) days, with all decisions being made on logical and analytical grounds, without, under any circumstances, allowing any uncertainty to hang over the full independence between the interests of the Advisory firm and those of the members of its team.

The team must always prioritize the clients' interests over their own interests, whether conflicting or not. All conflicts of interest identified or suspected must be reported, mandatorily and immediately, to the Compliance department.

Exceptionally, certain of the above operations not contemplated herein may be carried out in the team members' own names, provided that they are previously and expressly approved by Compliance and do not constitute a situation of conflict with the interests of the Advisory firm's clients. For the purpose of authorizing operations on an exceptional basis, the Compliance department must analyze the following aspects:

1. Whether the intended operation may result in any loss for the Advisory firm or its investors;
2. Whether the intended operation may, in any way, limit the discretion of the Advisory firm's team in the performance of its activities. Should this operation limit the analytical power of the Advisory firm's team, Compliance may not authorize it;
3. The actual objectives of the intended operation, so as to ensure the good faith of the Advisory firm's team and maintain the strict fiduciary relationship between the Advisory firm and its investors.

Team members may not:

1. Participate in any transaction that may, in any way, compromise their solvency and/or credibility;
2. Use inside information obtained through or about clients, resulting from their position as investment advisors;
3. Use any inside information, regardless of its source.

4. Methodology for Allocation of Treasury Resources

The Advisory firm's scope does not include the active management of treasury resources. Thus, cash resources will be held only for the payment of expenses, whether ordinary or extraordinary, and any surplus will be held in currency, savings accounts, CDBs, repurchase agreements, or DI-referenced investment funds, at the discretion of Management.

5. Monitoring

Compliance will collect the declaration of the team members in which they attest to compliance with this Personal Investments Policy, pursuant to the Terms of Adherence to this Policy set forth in Annex I.

Should it deem it necessary, Compliance shall have the authority to request the statement of the consolidated position of the personal investments of the Advisory firm's team members in order to verify adherence to this Policy. If any possibility of conflict or non-compliance with the Personal Investments Policy is identified, the Compliance Officer will take the appropriate measures, such as a request for clarification or a recommendation to dispose of the position.

6. Recordkeeping

Compliance shall keep on file the grounds that led to the authorization of personal investments on an exception basis to the general rule established in this Personal Investments Policy, as well as a copy of the declarations signed by the members of the Advisory firm's team, for the legally required period.

The documents may be filed in physical or electronic form, and the original physical copy of the documents may be replaced by the digitized copy.

Failure to comply with the provisions of this Policy will result in a warning, suspension, dismissal, or exclusion for just cause, according to the severity and recurrence of the violation, without prejudice to civil and criminal penalties.

7. Updates

This Policy will be updated annually or within a shorter period as needed, taking into account changes to certain internal procedures and/or changes in legislation.

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