CODE OF ETHICS AND CONDUCT

1. Purpose and Applicability of the Code

This Code of Ethics and Conduct is intended to communicate Sondotécnica’s ethical guidelines, which must be followed and promoted by all individuals and entities within its value chain, including Board Members, Officers, Employees, Interns, Young Apprentices, Third Parties (Service Providers, Suppliers, Partners, Intermediaries, and Associates), and anyone acting on behalf of Sondotécnica.

The ethical values upheld by Sondotécnica are based on mutual respect and are intended to foster sound business and social relationships.

In addition, the ethical principles that guide our activities support Sondotécnica’s reputation as a solid and trustworthy company committed to compliance with applicable laws and to maintaining internal procedures designed to prevent acts that may cause harm to Brazilian or foreign public administrations.

Sondotécnica’s Management is committed to integrity in public-private relationships and to maintaining appropriate conditions for consolidating a strong anti-corruption culture.

2. Expected Conduct

Everyone must conduct their relationships and activities in accordance with Sondotécnica’s Principles and the guidelines established in this Code, ensuring compliance and maintaining the highest standards of integrity. Expected conduct also includes:

- Acting in strict compliance with all applicable laws, including anti-corruption and anti-bribery laws;

- Acting responsibly in relationships with government authorities, clients, competitors, suppliers, community members, and all other individuals, companies, and organizations with which Sondotécnica interacts in the course of its regular business activities, always seeking to preserve the company’s reputation, image, and relationships.

3. Unlawful Conduct

Unlawful practices, as well as attempts to engage in such practices, will not be tolerated. These include corruption, bribery, extortion, kickbacks, money laundering, and terrorist financing in any form, whether involving public or private entities.

4. Unacceptable Practices

Workplace harassment and sexual harassment are unacceptable practices and may be subject to criminal proceedings, disciplinary action, and termination for cause.

Any and all forms of discrimination are prohibited, including discrimination based on origin, race, political beliefs, social or economic status, nationality, color, religion, sex, gender identity, age, physical characteristics, or disability.

All acts of intimidation, insults, or aggression, whether physical or verbal, are prohibited.

The possession of weapons of any kind on Sondotécnica premises is prohibited.

The use of alcohol and drugs in the workplace is prohibited.

We do not permit minors to engage in activities that may constitute an employment relationship or child labor, except for apprentices hired in accordance with applicable law.

We also prohibit any employment relationship that may constitute forced labor, slave labor, or conditions analogous to slavery, both within Sondotécnica and among our suppliers and partners.

Any act deemed harmful to Brazilian or foreign public administrations, as defined under Federal Law No. 12,846/2013 (Brazilian Anti-Corruption Law), is prohibited.