Suitability 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 Suitability Policy ("Policy") aims to establish procedures to maintain the suitability of the investments made by the clients of Decade Wealth Management ("the Advisory firm") to their respective investor profile.

This Policy is in accordance with the applicable rules, including the regulations and self-regulatory rules of ANBIMA applicable to the activities carried out by the Advisory firm, namely:

1. CVM Resolution No. 19 of February 25, 2021;
2. CVM Resolution No. 30 of May 11, 2021.

The application of the procedures established in this Policy constitutes a fundamental part of the advisory activity in order to identify, on an individualized basis, the premises that define the investor profile of each client, as well as to classify and categorize the products recommended for each of them. The classification of the investor profile and of the recommended products is established in accordance with proprietary and evidence-based criteria, and therefore no comparison or equivalence with the investor profiles of other institutions is applicable.

2. Scope

It is important to emphasize that this rule is of mandatory observance for all partners, collaborators, employees, trainees, interns, Clients, and all those who are linked to the Advisory firm.

The verification of the suitability of the products, services, and transactions to the Investor's profile ("Suitability") shall be observed by the Advisory firm when maintaining a relationship with a Client, whether for the purposes of carrying out the respective registrations or for the offering of products, services, and transactions.

The Policy shall be applied to every Client holding investments, being dispensable when it concerns a co-holder of investments and in the cases provided for in the applicable rule, namely:

1. The client is a qualified investor, except in the situations provided for in the applicable regulations;
2. The client is a legal entity governed by public law;
3. The client has its securities portfolio managed on a discretionary basis by a securities portfolio manager authorized by the CVM;
4. The client already has its profile defined by a securities advisor authorized by the CVM and is implementing the recommendation provided by such advisor.

The exemption provided for in item IV does not extend to cases in which the products, services, and transactions ordered by the client are not directly related to the implementation of the recommendations of the Advisory firm engaged by such client.

3. Assignment, Control, and Updating of the Policy

The Compliance Department of the Advisory firm is responsible for updating this Policy, applying the 'Suitability Questionnaire', and periodically updating the Investment Profile of the Clients.

The Compliance Department is responsible for controlling and verifying the application of this Policy by the Advisory firm, and any collaborator of the Advisory firm must directly report any irregularities in the execution of the procedures established in this Policy.

In order to ensure the execution of the responsibilities related to this Policy, full autonomy shall be guaranteed to the Compliance Department and to the Director responsible for Compliance.

It is also the responsibility of the Compliance Department to provide training to all collaborators on the application of this rule in ordinary activities, so that everyone executes and complies with the procedures determined herein.

It is the responsibility of the Compliance Director to forward to the Senior Management of the Advisory firm, by the last business day of the month of April, a report relating to the previous year, containing: (i) an assessment of compliance with the internal rules, procedures, and controls; and containing (ii) the recommendations to correct any deficiencies identified and a plan/suggestion for their correction.

Additionally, it is the responsibility of the Compliance Department to review and update, if necessary, this Policy at an interval of less than 24 months or within a shorter period, in the event of regulatory changes relevant to this Policy.

4. Document Retention

The files and documents shall be kept for a minimum period of 5 (five) years, counted from the last recommendation provided to the client, or for a longer period, by express determination of the CVM, in the event of administrative proceedings, as well as all documents and declarations required by law. The documents and declarations may be kept in physical or electronic form, and the replacement of documents by their respective scanned images is permitted.

5. Definition of the Client Profile

The Client Profile is a description that assists in characterizing the needs, preferences, and characteristics of a Client in relation to the Investment Products that will be made available to such Client. It is fundamental for understanding risk tolerance, financial objectives, and economic conditions, allowing the Advisory firm to offer personalized recommendations that align with the interests and circumstances of the Client.

5.1. Client Profile Assessment Procedure

To identify and assign an investment profile to the client, this procedure and Suitability questionnaire shall be applied before the first investment, whether remotely or in person, synchronously or asynchronously, to all clients, both individuals and legal entities.

a) Collection of Information

The Agent responsible for the personalized service to the client, duly qualified to carry out this activity, shall forward or make available the questionnaire to the Client, whether a legal entity or a natural person. The client shall be informed of the importance and objectives of the questionnaire.

b) Completion of the Questionnaire

The Client shall complete the questionnaire in a regular manner and without alterations, such that it is not possible to assign more than one score to each question. The completion may be carried out online or orally, and shall not, in any form, be directed toward a specific or expected type of intended profile.

c) Verification of Responses and Definition of the Client Profile

Upon assigning a value to each quality of the Client's response, the values shall be tallied, scored, and ranked. In this way, at the end, the Client's profile shall be defined as conservative, moderate, or aggressive.

d) Recording and Availability of Information

Upon receiving the form, based on the Client's responses, it shall be forwarded to the compliance department so that this department exclusively tallies the score and ranks the Client and, finally, assigns a client profile: conservative, moderate, or aggressive.

e) Periodic Updating of the Client Profile Analysis

The client profile shall be updated within a period not exceeding 24 months, with the application of the questionnaire to identify and ensure the suitability of the profile.

f) Monitoring

The monitoring of the suitability of the products offered to Clients, in relation to their Client Profile, is the responsibility of the Compliance and Internal Controls Department.

g) Misalignment of the Client Profile and its Investments

In the event that the client requests the execution of transactions that are not aligned with its investor profile, the responsible agent must, before the first transaction with the new asset category: (I) alert the client about the absence or outdatedness of the profile or its unsuitability, indicating the causes of the divergence; and (II) obtain an express declaration from the client confirming that it wishes to proceed with the investment decision.

h) Prohibitions

It is prohibited to offer products, services, and transactions that are not compatible with the client's profile, to clients who have not responded to the Questionnaire or whose client profile is not duly updated, or to assign a Client Profile that is incompatible with the methodology applied in this policy.

5.2. Definition of the Client Profile

The Advisory firm, aiming to identify the investor's risk profile and thus define which asset allocation model is most suitable for the client's profile, carries out the process of collecting information in order to, by means of a quantitative model, outline the risk profile of each client.

I — Identification of the Client's Financial Situation

1. The client shall declare its usual income and its investment availability;
2. Identify the investor's assets and their value;
3. Question whether there is any foreseeable situation that could result in redemption, in order to identify the need for liquidity.

II — Identification of Investment Objectives

1. Identify the intended period and duration of the investment;
2. Identify the investor's tolerance to risk;
3. Identify the purpose for which the investment will be made.

III — Definition of the Client's Knowledge

1. Identify which assets the investor has already had contact with;
2. Request that the investor declare its experience in the financial market;
3. The nature, volume, and frequency with which a given investment was made;
4. The Client's academic and professional background.

5.3. Classification of the Client's Investment Profile

Based on the information collected, in the manner described by this Policy, the Client Profile shall be defined as:

It is important to emphasize that certain clients, even those with adequately defined investor profiles, may experience changes in their objectives or in their personal circumstances that impact the ideal risk-return scenario. In such cases, it is essential that clients be advised to mandatorily seek out the responsible advisor.

5.4. Method for Assigning a Risk Profile Based on the Questionnaire

In this questionnaire, each question refers to a concept for the classification of the investor profile, considering aspects such as experience and knowledge about financial investments, investment interests and goals, as well as risk acceptance.

The minimum score resulting from the application of the questionnaire is 0 points and the maximum is 78 points, distributed as indicated:

5.5. Investment Products

The Advisory firm shall not offer investment products incompatible with the Client Profile, defined in the manner of this Policy. The products to be offered to clients must be compatible with the verified client profile, considering the following criteria:

• A) Risks associated with the product and its underlying assets: market risk associated with the product, potential losses arising from variations in prices of financial assets, interest rates, currencies, and indices.
• B) Profile of the Issuers and associated credit risk: classification of the issuing institutions by the entities responsible for the analysis and classification of an entity's vulnerability to default.
• C) Existence of guarantees: investment in certain products has guarantees that may partially or fully secure the amounts invested by the client.
• D) Lock-up periods and associated liquidity risk: the length of time for which the investor proposes to maintain its position in the product.

In the event of misalignment, the Client shall sign the Misalignment Acknowledgment Term in order to be able to make new investments in products misaligned with its profile.

5.6. Complex Investment Products

Complex products are those that present an intricate structure, difficulty of assessment, and/or have a limited or nonexistent secondary market. Within this classification, the following aspects are included:

1. Asymmetry in Results
2. Pricing Methodology
3. Reference Indices
4. Exit Costs
5. Payments and Discontinuity Events
6. Capital Protection
7. Convertibility Events
8. Credit Assignment and Specific Backing
9. Differentiated Guarantees

For purposes of self-regulation and in accordance with this Policy, the following are considered complex investment products:

• Structured Transaction Certificates
• Convertible debentures
• Real Estate Investment Funds
• Credit Rights Investment Funds
• Private Equity Investment Funds
• Investment Funds with a quota valued other than daily and redemptions exceeding 180 days
• Offshore Investment Funds

6. Client Registration and Record

In accordance with the regulations of ANBIMA and CVM, before any transaction is carried out for the Client, the Client shall provide all mandatory registration information required by the aforementioned entities, whether an individual or a legal entity.

These are the minimum information and documents necessary that shall be periodically updated, within a period not exceeding 24 (twenty-four) months, by the clients or whenever there is a need and request on the part of the Company.

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