Normative document
Code of Conduct
Version 1.0 — effective from 31 July 2026.
Controller: GBS PRIVATE LTDA, CNPJ 68.307.907/0001-31, Avenida da Liberdade, 91, Room 144, Liberdade, São Paulo – SP, 01503-000, Brazil.
This code sets out the duties of conduct applicable to managers, employees, interns, service providers and counterparties of GBS PRIVATE LTDA.
1. Addressees
This code binds all persons acting on behalf of the company or maintaining a commercial relationship with it. Adherence is a condition of engagement and of its continuation. Ignorance of its provisions does not exempt from liability.
2. Compliance with the law
It is a duty to comply with Brazilian law and with the law applicable in each market where the operation takes place, as well as with the company's internal rules. Where a rule conflicts with an instruction received, the rule prevails and the fact must be reported to management.
3. Integrity and anti-corruption
It is prohibited to offer, promise, give, solicit or receive an undue advantage, directly or through an intermediary, to or from a public or private agent. Gifts and hospitality are admitted only where of symbolic value, consistent with ordinary commercial practice and recorded. Political donations on behalf of the company are prohibited.
4. Conflict of interest
Any situation in which a personal, family or third-party interest may influence a decision taken on behalf of the company must be reported to management before the act is performed. The person in conflict abstains from participating in the decision until management resolves the matter.
5. Confidentiality and data protection
Commercial, registration and operational information obtained by reason of one's role is confidential and may not be disclosed, used for personal or third-party benefit, or accessed without a functional need. Processing of personal data is governed by the Privacy Policy and applicable law.
6. Records and assets
Accounting, tax and operational records must accurately reflect the reality of operations. It is prohibited to create, alter or omit a record in order to conceal a fact. The company's resources and systems are intended exclusively for the purposes of its activity.
7. Labour relations
The company does not accept child labour, forced labour or labour in conditions analogous to slavery, in its own operations or in those of its counterparties. Discrimination, moral harassment and sexual harassment are prohibited. Every person must be treated with respect and civility.
8. Relations with counterparties
The selection of counterparties follows objective criteria and the identification and due diligence process described on the Governance and compliance page. It is prohibited to engage a counterparty whose identity has not been verified or that appears on an applicable restrictive list.
9. Reporting breaches and measures
Breaches of this code must be reported to management through the whistleblowing channel, including anonymously. Retaliation against a person reporting in good faith is prohibited. Where a breach is established, applicable measures are taken, which may include a warning, termination of the engagement or contract and reporting to the competent authorities.
10. Effectiveness and review
This code takes effect on the date stated at the top of this document and is reviewed at least annually. Each revision receives a new version number and a new effective date.