To guide the conduct of its employees, upholding ethics and integrity, while clearly defining the company's social stance toward the various stakeholders with whom it interacts, as well as ensuring compliance with and preventing violations of the applicable legal and regulatory frameworks in force in the country, including Law No. 12,846/13, among others.

All employees of Grupo SEB, equally and without any distinction, regardless of hierarchical level, provided they maintain a business relationship with any company affiliated with Grupo SEB.

The People and Services Department, with the support of the Corporate Departments, has developed this Policy with the purpose of disseminating understanding through the formalization of standards and rules, promoting the engagement of Grupo SEB professionals regarding the principles of Conduct and Ethics in the performance of their professional activities.

In addition, this Policy aims to provide Grupo SEB employees with a communication channel for reporting and clarifying any potential violations of these provisions. All reports received will be duly investigated and, depending on the circumstances, may result in corrective, preventive, and/or disciplinary actions whenever any violation of these provisions becomes known.

It is important to emphasize that Grupo SEB does not tolerate any form of retaliation against any individual who reports a violation of this Policy or assists in an internal investigation, and any such retaliation must also be reported.

Employees: comply with the rules and standards set forth in this Policy, as well as report any violation of the rules established herein.

• We respect human rights and do not tolerate any form of exploitation, discrimination, or disrespect in the conduct of our activities at any of our facilities.
• We oppose any form of manipulation, coercion, or undue pressure in our operations and business activities.
• We comply with the laws, rules, and regulations of the countries and locations where we operate, at all levels.
• We adopt practices aimed at preventing and combating all forms of illicit payments or receipts, personal gain, undue privileges, fraud, money laundering, and potential conflicts of interest.

We maintain corporate governance practices designed to ensure:

• Diligent and ethical management that preserves the good reputation of Grupo SEB and the satisfaction of its customers.
• The alignment of our activities with the commitments set forth in this Policy and with the guidelines related to sustainability, people management, performance, compensation systems, risk management, financial controls, auditing, internal controls, and corporate security.
• The independence of our risk management, internal control, auditing, and ombudsman processes, with the full support and cooperation of employees and related parties in internal and external audits, internal inquiries, and investigations, through the provision of complete and accurate information and the preservation of all materials that may be relevant.
• Timely communication to society and stakeholders regarding Grupo SEB's purposes, decisions, and results.
• That statements, reports, communications, and disclosures accurately and transparently reflect the reality of Grupo SEB.
• That our contracts are easily understandable and clearly define the rights and obligations of the parties involved, highlighting any existing risks.
• The protection of non-public information (restricted, confidential, and internal) to prevent its unauthorized disclosure from harming Grupo SEB and its stakeholders.

• We conduct our operations and business activities under market conditions and place the interests of Grupo SEB first, observing strictly arm's length conditions, negotiated independently through a transparent, ethical process and in compliance with applicable laws and regulations.
• We provide clear and accurate information necessary for related parties to make informed decisions.
• We adopt transparent criteria that enhance impartiality in the management of scheduling conflicts, aiming to eliminate the loss of rights and reconcile the interests of related parties.

• Due to the nature of its business, Grupo SEB's educational materials suppliers are approved and managed by Conexia.
• For all other goods and services, supply agreements are based on technical, professional, and ethical criteria, conducted through price quotations and bidding processes, ensuring the best cost-benefit ratio.
• No factors that could constitute privilege or discrimination shall interfere in this process.
• We adopt fair and transparent criteria for supplier selection and contracting through conscious choices guided by predetermined processes, such as competitive bidding or price quotations, in order to engage the best suppliers and ensure the best return for Grupo SEB in terms of quality, cost, and alignment with Grupo SEB's social values.
• We are committed to acting with integrity, providing equal opportunities to all suppliers and partners.
• We seek to develop long-term business relationships, encouraging suppliers to share our philosophy of continuous improvement.

We do not engage suppliers or service providers that:

• Provide products or services without complying with environmental, quality, and safety standards;
• Employ forced, slave, or child labor;
• Use physical, moral, or financial punishment to discipline employees;
• Violate applicable laws and regulations.

Receipt of gifts

• We adopt a policy of reciprocity regarding the acquisition and receipt of gifts or presents by employees.
• We do not receive or offer gifts, favors, or entertainment that may influence any business decision or create any sense of obligation on the part of the recipient.
• Under no circumstances may our employees receive money from customers, suppliers, or third parties as a gratuity.
• Employees may accept or offer, as a courtesy or for institutional purposes, gifts, presents, and entertainment that do not cost, or do not appear to cost, more than BRL 50.00 (fifty Brazilian reais), such as gift baskets, panettones, chocolates, planners, notebooks, pens, pencils, calendars, tickets to concerts, theater performances, movies, sporting events, lunches, and dinners.

Conflicts of interest

• We act with integrity, providing equal opportunities to all suppliers and partners.
• We reject any practice involving corruption, bribery, kickbacks, personal favoritism, or any other unlawful or criminal acts in our operations.
• Our employees must avoid any situation that may create a conflict between their personal interests and those of the company, whether related to financial matters or to gifts, meals, and/or entertainment offered in exchange for any internal business relationship associated with Grupo SEB.

Ethical Conduct Rules of Grupo SEB:

• We reject any form of discrimination or harassment.
• We implement internal policies and practices aimed at preventing and combating degrading forms of labor, including child labor, forced labor, and slavery.
• We respect employees' political and labor rights, including the right to collective bargaining and political or union association.
• We oppose any form of sexual, moral, religious, political, or organizational harassment or intimidation.
• Our people management processes (hiring, transfers, promotions, merit-based salary increases, disciplinary actions, and termination) are conducted with respect, transparency, impartiality, and based on meritocratic principles.

Employees of Grupo SEB shall:

• Perform their duties in accordance with this Policy.
• Comply with and respect SEB's internal Policies and Standards, encouraging and guiding colleagues to do the same.
• Maintain a positive, dignified, loyal, honest, and professional attitude, fostering mutual respect, trust, and collaboration with colleagues.
• Act with impartiality, objectivity, honesty, respect, transparency, loyalty, and courtesy in relationships with managers, employees, suppliers, customers, shareholders, and investors.
• Strictly comply with all applicable laws, including anti-bribery and anti-corruption laws applicable in the jurisdictions where Grupo SEB operates.
• Demonstrate an ownership mindset by performing all activities with accountability for their success, acting with urgency, meeting agreed deadlines and budgets, and ensuring transparency, ethics, quality, and sustainability.
• Continuously pursue excellence in execution, striving for the highest level of performance, improving daily practices, and ensuring the highest quality in every task performed.
• Preserve Grupo SEB's assets, including its image and reputation, facilities, equipment, and materials, using them exclusively for their intended purposes and in compliance with information security policies, especially the Information Security Policy.
• Act diligently and responsibly in dealings with authorities, customers, suppliers, community members, and all other individuals, companies, and organizations with which Grupo SEB interacts, always seeking to preserve the company's reputation, image, and relationships.
• Avoid situations that may result in conflicts of interest involving SEB and immediately report any such situation to their direct supervisor.
• Refuse business relationships with companies and individuals that do not observe ethical, legal, health and safety, and human and social rights standards compatible with those of SEB.
• Comply with the anti-bribery and anti-corruption practices adopted by Grupo SEB in accordance with Law No. 12,846/2013.
• Protect any confidential and sensitive information or strategies of Grupo SEB to which they have access, including in the capacity of a third party, even after termination of their relationship with Grupo SEB, and maintain the confidentiality of privileged information.
• Store confidential documents in protected files and properly destroy them before disposal.
• Act with social responsibility and respect for human dignity.
• Carry out daily activities in compliance with the occupational health and safety requirements established by the company.
• Use social media in accordance with SEB's values and this Policy, avoiding any impact on professional activities or loss of productivity.
• Use mobile devices responsibly during working hours to avoid interference with professional activities and productivity.
• Assist colleagues in performing their duties and patiently support those seeking guidance.
• Avoid misleading others or causing them harm.
• Avoid offensive conduct, whether verbal, physical, or gestural.
• Avoid spreading rumors or engaging in gossip.
• When mistakes occur, act transparently, do not conceal facts, seek to mitigate consequences, and learn from the experience in accordance with Grupo SEB's Mission and Values.
• Practice conscious consumption by avoiding waste of water, energy, paper, plastic items, office supplies, and other resources.
• Maintain an appropriate personal appearance consistent with the duties performed.
• Preserve the image, symbols, distinctive elements, trademarks, logos, and all other intellectual property rights owned by SEB when using any type of media or social network.
• Avoid conflicts of interest arising from family or romantic relationships between employees. For this purpose, the following are considered relatives: children, stepchildren, grandchildren and great-grandchildren; spouses/partners, parents-in-law, siblings-in-law, sons-in-law, and daughters-in-law; parents, stepparents, siblings, nephews and nieces, and grandnephews and grandnieces; grandparents, uncles, aunts, and cousins; great-grandparents and great-uncles/aunts. Family or romantic relationships between employees are permitted provided there is no hierarchical subordination or influence over management decisions. Whenever such a relationship exists within the same reporting line, it must be reported to the immediate manager for evaluation and, if necessary, reassignment.

The following conduct is unacceptable within Grupo SEB and may result in disciplinary measures:

• Moral harassment through verbal abuse, humiliating treatment, or threats.
• Sexual harassment through unwanted advances, requests for sexual favors, or any inappropriate verbal or physical conduct of a sexual nature.
• Disrespectful, threatening, or discriminatory treatment toward any individual, regardless of hierarchical level, position, or function.
• Discrimination based on social origin, race, color, gender, age, religion, physical characteristics, or sexual orientation.
• Use for personal purposes or disclosure to third parties of technologies, methods, or information owned by Grupo SEB or third parties held by Grupo SEB without prior express authorization.
• Engagement in external activities that compete with Grupo SEB's business activities.
• Use of Grupo SEB systems and resources for non-professional activities, or for the dissemination of rumors, pornography, jokes, games, or political-party propaganda.
• Use of IT resources to transmit or access inappropriate content, including pornography, obscenity, activities against public or third-party property, discrimination, terrorism, political-party propaganda, or games of any kind, as such resources are intended exclusively for professional activities and must comply with Grupo SEB's Information Security Policy.
• Sale of personal products or services on Grupo SEB premises.
• Any act that may damage Grupo SEB's assets.
• Offering or receiving gifts in violation of Grupo SEB's policies and standards as a means of exerting undue influence or obtaining personal gain or benefits for oneself or others.
• Hiring relatives for positions involving direct or indirect reporting relationships or potential conflicts of interest with Grupo SEB's interests.
• Working under the influence of alcohol or illegal drugs.
• Use of illegal psychoactive substances on any Grupo SEB premises.
• Misrepresentation of figures or accounting classifications that may affect management reports or Grupo SEB's financial statements.
• Disclosure of Grupo SEB information or comments regarding day-to-day work activities on social media.
• Disclosure of personal data relating to employees, parents, or students to third parties, in violation of privacy principles.
• Making statements on behalf of Grupo SEB, including through social media, blogs, or any other communication channel, without prior authorization.
• Discussing information related to Grupo SEB, its business, or work activities in public in a manner that violates confidentiality obligations.

• We respect our customers' freedom of choice.
• We provide clear and accurate information necessary to support decision-making.
• We do not engage in practices such as tied selling or any other form of imposition or coercion in the conduct of business.
• We serve our customers with professionalism and efficiency, valuing their interests, time, opinions, and feelings.
• Our activities are conducted in accordance with the principles of free competition. Accordingly, anti-competitive practices such as the misuse of privileged information, omission of material facts, manipulation of good faith, and corporate espionage are strictly prohibited.
• We make decisions free from political or partisan influence.
• We establish partnerships and may provide contributions, sponsorships, or donations to the public sector in compliance with applicable laws and Grupo SEB's corporate guidelines, ensuring that such contributions are properly recorded in our financial statements.
• No contribution, sponsorship, donation, or similar initiative shall be made with the purpose of obtaining illegitimate benefits or favors.
• We maintain relationships with the media based on the principles of truthfulness and independence.
• Only previously designated employees are authorized to speak on behalf of SEB to the press and the general public, including through social media. Whenever contacted by representatives of media outlets, employees must refer such requests to the Communications Department. The disclosure of information to the market and the general public, including through social media, shall be carried out exclusively by the Communications Department to ensure transparency, clarity, and equitable communication.
• We exercise sound judgment in determining what information must be disclosed.

• Upon approval of this Policy, the Services Department shall establish a Compliance Committee, which shall serve as the guardian of this instrument.
• The Committee shall be multidisciplinary and capable of supporting all employees in understanding and complying with matters related to this Policy.

The Committee shall be composed of representatives from the following areas:

• Executive Board
• Legal Department
• People Management
• Controllership
• Internal Audit

Each of the departments listed above shall appoint one primary member and one alternate member, both of whom shall attend the Committee's regular monthly meetings. The absence of either the primary or alternate member from more than two consecutive meetings shall result in the mandatory replacement of the respective member.

Frequency:

• Regular Compliance Committee Meetings: held once a month, according to a schedule to be defined and communicated through an events calendar published across all internal communication channels and upon the signing of the appointment term by the primary member and their respective alternate.
• Extraordinary Meetings: held whenever necessary due to the urgency and relevance of reports, irregularities, or facts brought to the Committee's attention through the available reporting channels.

The Compliance Committee shall be responsible for:

• Promoting a culture of respect for the rules and principles established in this Policy through training sessions, courses, lectures, and specific workshops.
• Continuously monitoring compliance with this Policy through audits and specific reviews.
• Receiving reports and investigating any conduct deemed inappropriate and committed by Grupo SEB employees.
• Initiating disciplinary investigation proceedings.
• In carrying out these activities, the Compliance Committee may request support and information from any department within Grupo SEB.
• The Compliance Committee may be composed of both Grupo SEB professionals and external professionals or partners specifically engaged for this purpose.
• Committee members shall be qualified and designated professionals responsible for overseeing compliance with the ethical principles and rules of conduct established herein, as well as maintaining and updating this Policy.

• Employees may use the communication channel via the email address ouvidoria@seb.com.br, which guarantees complete anonymity, to report any violations of this Policy.
• Reports shall be received and, following assessment by the Ombudsman Office, shall be duly forwarded to the Compliance Committee, ensuring procedures designed to safeguard the rights of both the reporting party and the reported party. Under no circumstances shall the reporting of potential violations or misconduct serve as grounds for retaliation or intimidation against any employee.
• A disciplinary investigation process shall be initiated, with a maximum period of sixty (60) days for completion of the investigation and an additional thirty (30) days for resolution.
• In cases involving moral and/or sexual harassment, the timeframe established above shall be reduced by half. The employee under investigation shall have fifteen (15) days, counted from the conclusion of the investigation, to present their defense, ensuring the right to due process and full defense.
• Following the submission of the defense, the Compliance Committee shall conclude the investigation and issue a resolution within thirty (30) days from the date on which the reported party's defense is submitted.
• Violations of the provisions set forth in this Policy shall subject offenders to disciplinary measures, including verbal or written warnings, suspension, and termination for cause, without prejudice to any applicable legal liabilities.
• In the application of disciplinary measures, the nature and severity of the violation shall be taken into consideration.
• In accordance with Grupo SEB's principles, the entire investigation process shall remain confidential and shall only be accessible to the Compliance Committee, the reported party, and their legal representative, if appointed.
• Any breach of confidentiality shall result in civil and criminal liability for the responsible party.
• Once the investigation and resolution process has been completed and inappropriate conduct inconsistent with the guidelines of this Policy has been confirmed, the Compliance Committee may, within ethical limits, use the situation as an example and disseminate it within Grupo SEB to ensure awareness of its inappropriateness.

Any questions or concerns regarding the interpretation, scope, or any provision of this Policy shall be submitted to the Compliance Committee through the communication channels available on Grupo SEB's website, particularly via the email address denuncias@seb.com.br.