Code of Ethics, Conduct and Integrity

This Code establishes the ethical principles and mandatory conduct guidelines for all persons who act on behalf of or for the benefit of IDUS Tecnologia Industrial (“IDUS”), in coherence with its Mission, its Vision 2027 and its Values: Honesty, Valuing People, Workplace Safety, Transparency, Ethics, Quality and Organization, in addition to the constant commitment to Innovation and to the Client.

This Code is founded on the principle of responsible decision-making:

1. Ilegal informs what is legally possible;
2. IIcompliance warns about risks;
3. IIIgovernance organizes the decision-making process and its record; and
4. IVthe decision belongs to the competent instance, pursuant to the Corporate Governance Regulation (Shareholders' Meeting › Executive Board › Heads).

As an instrument of strategic level, this Code is subordinate to the Articles of Association and to the Corporate Governance Regulation, which it may not contradict, and binds all other policies, standards and instructions of the company.

This Code exists to:

1. Ireduce legal and reputational risks;
2. IIreduce the subjectivity of decisions, making them traceable and reproducible;
3. IIIimprove the quality of decisions;
4. IVenable growth and internationalization (OE2); and
5. Vfacilitate internal and external audits.

The following persons are subject to this Code, in all activity related to IDUS:

1. Ithe Shareholders;
2. IIthe members of the Executive Board — CEO, CTO and CBGO;
3. IIIthe Area Heads and other occupants of positions of trust;
4. IVemployees under any employment relationship — CLT, independent contractors, interns and young apprentices; and
5. Vsuppliers, service providers, consultants and partners who act on behalf of or for IDUS, on matters compatible with the nature of their contractual relationship.

§ 1 Independent contractors (PJ) who perform executive functions are subject to this Code in all matters compatible with their contract, pursuant to the respective conduct annexes.

§ 2 While the Advisory Council, the COO and the CIGO do not yet exist, the powers that would be attributed to them are exercised under the current structure. When such instances are constituted by the Governance Evolution Plan, this Code shall be extraordinarily revised.

Persons subject to this Code shall guide their conduct by the following principles:

1. IHonesty and Integrity — acting in good faith and in compliance with the law, repudiating corruption, fraud, bribery, money laundering and conflicts of interest;
2. IIValuing People and Respect for Diversity — treating everyone with dignity and equality, without discrimination based on race, ethnicity, gender, sexual orientation, religion, age, disability, neurodivergence, nationality or belief;
3. IIIWorkplace Safety;
4. IVTransparency and Accountability;
5. VEthics and Impartiality;
6. VIQuality and Excellence;
7. VIIOrganization and Traceability;
8. VIIIResponsible Innovation, including in the use of artificial intelligence;
9. IXSustainable Development (ESG); and
10. XContinuous Professional Development.

The following constitute basic rules of conduct, among others: refraining from offensive comments against IDUS, the Executive Board or colleagues; informing the competent instance and the Ethics Committee of situations that compromise the image or assets of IDUS; reporting, through the Integrity Channel, any infraction; devoting oneself to activities during the contracted work hours; practicing professionalism and courtesy, without prejudice or discrimination; maintaining political-partisan, religious and ideological neutrality; respecting the hierarchy and the decision-making powers of Regulation; and permanently seeking professional development, participating in the training offered.

IDUS integrates ESG principles into its strategy and operations, in coherence with Vision 2027 and with OE4.

IDUS promotes diversity and equal opportunity and prohibits discrimination in selection, promotion, remuneration or any decision, including in international contexts (OE2).

IDUS adopts zero tolerance for moral, sexual or psychological harassment and any form of violence, abuse of power, intimidation or coercion. Every incident must be reported through the Integrity Channel, ensuring confidentiality and protection to the victim and the whistleblower.

IDUS undertakes to:

1. Inot admit forced, involuntary, child or slave-like labor, combating such practices in its value chain;
2. IIuse natural resources responsibly; and
3. IIIsupport initiatives with a positive socio-environmental impact.

IDUS guides its relationships by honesty, transparency and ethics, observing specific guidelines for:

1. IClients;
2. IIShareholders, investors and creditors;
3. IIIPartners, suppliers and third parties — with recording, in the Integrity Channel, of any attempt at undue advantage;
4. IVMarket and competitors — fair competition;
5. VGovernment and regulatory bodies — in Brazil and in the countries of operation (OE2); and
6. VIPress and social media — communication only through authorized spokespersons.

Any public statement on behalf of IDUS depends on authorization from the Executive Board or from a formally designated spokesperson.

The duties of all employees are: acting with honesty and transparency; protecting assets and information; proactively declaring conflicts of interest; refusing and reporting undue advantages; respecting diversity; contributing to a safe environment; participating in ethics training; and not retaliating against good-faith whistleblowers.

Positions of trust are additionally responsible for: leading by example; ensuring their teams know and comply with this Code; managing conflicts of interest; monitoring and reporting ethical risks; and ensuring the protection of whistleblowers in their areas.

The Executive Board (CEO, CTO and CBGO) is additionally responsible for: maintaining and strengthening governance; ensuring legal and regulatory compliance; managing strategic and integrity risks; promoting a culture of integrity (OE4); allocating resources to the integrity program and to training; and reporting to the Shareholders' Meeting.

The Integrity Channel allows anyone to report, safely and confidentially, suspicions of violation of this Code or of the law. The channel is accessible to the public — including employees, suppliers, partners and third parties — by confidential email and by electronic form published on the Central IDUS and on the company's official website, admitting anonymous complaints.

The workflow observes:

1. Ireferral to the Committee within 2 (two) business days;
2. IIadmissibility decision within 5 (five) business days;
3. IIIprior statement by the accused within 72 (seventy-two) hours, extendable for an equal period; and
4. IVconclusion of the investigation within 30 (thirty) days, extendable upon justification.

IDUS ensures the good-faith whistleblower full protection against retaliation. Any retaliation, or attempt to identify an anonymous whistleblower, constitutes a serious violation and gives rise to disciplinary action. No person may suffer retaliation for reporting, in good faith, suspected irregularities, even if not subsequently confirmed.

The records of investigations, whether substantiated or not, are confidential and filed by the Ethics Committee, under the CEO's supervision, in IDUS's official repository, for a minimum period of 10 (ten) years.

Violation of this Code subjects the offender, after due investigation process, to the following penalties, applied gradually and proportionally:

1. Iwritten warning;
2. IIsuspension;
3. IIIdismissal for just cause;
4. IVineligibility for promotion; and
5. Vcontract termination, in the case of third parties.

The determination of the penalty considers the severity of the conduct, the damages caused, the intent, mitigating and aggravating circumstances, and the hierarchical level of the offender.

The authority to apply penalties observes:

1. Iwarning — immediate manager, with awareness of Gente & Gestão;
2. IIsuspension — Executive Board, upon recommendation of the Ethics Committee;
3. IIIdismissal for just cause and other serious penalties — CEO, after investigation; and
4. IVpenalties for Executive Board members — Shareholders' Meeting.

Sole paragraph. The determination and the investigation procedure observe the Disciplinary Rules and relevant labor and contractual legislation.

The accused is guaranteed adversarial process and full defense, including formal notification, access to evidence, presentation of defense, production of evidence and appeal of the decision within 3 (three) business days.

This Code is presented to every new employee or executive during onboarding, with signature of an acknowledgment and commitment statement, and remains accessible to everyone on the Central IDUS.

The Gente & Gestão Coordination, with the support of the Ethics Committee, promotes mandatory annual training on ethics, conduct and integrity, keeping a record of attendance.

This Code is ordinarily reviewed every 2 (two) years and, extraordinarily, whenever there is a relevant legislative change or a completed move of the Governance Evolution Plan.

This Code comes into force on the date of its approval by the Shareholders' Meeting and replaces any prior drafts of an IDUS code of ethics or conduct.

In the normative hierarchy, this Code is subordinate to the Articles of Association and to the Corporate Governance Regulation. In the event of conflict with another internal standard on ethics matters, the more restrictive provision prevails, respecting the supremacy of the Regulation.

References to instances that do not yet exist observe the current structure; once each move of the Governance Evolution Plan is completed, this Code will be revised.

Omitted cases are submitted to the Ethics Committee and, when necessary, to the Shareholders' Meeting.