1. Why this Code exists
1.1. LEXXEN LTDA, CNPJ 63.987.111/0001-53, operates in a sector where trust is the principal asset. This Code establishes the standards of conduct expected of everyone who acts on behalf of Lexxen.
1.2. This is not a decorative document. The conduct described here is mandatory, and non-compliance has the consequences set out in section 12.
1.3. Lack of awareness of this Code does not excuse non-compliance. If in doubt about how to act, contact the compliance channel before acting.
2. Who it applies to
2.1. All partners (shareholders), officers, employees, interns and apprentices of Lexxen.
2.2. Service providers, consultants, business partners and suppliers, to the extent compatible with the nature of the relationship, by means of a contractual provision.
2.3. In this Code, "Team Member" means any person subject to these rules.
3. Our principles
| Principle | What it means in practice |
|---|---|
| Integrity | Doing the right thing even when no one is watching and even when it is costly |
| Transparency | Communicating clearly, without omitting relevant information |
| Legality | Complying with the law and regulations, without convenient interpretations |
| Respect | Treating everyone with dignity, without discrimination or harassment |
| Accountability | Taking responsibility for the consequences of one's own decisions |
| Diligence | Knowing who you are doing business with before doing business |
4. Zero tolerance
4.1. Lexxen does not tolerate, under any circumstances:
a) corruption, bribery, kickbacks or undue advantage, whether active or passive; b) money laundering, concealment of assets and terrorist financing; c) fraud, forgery of documents, false statements in documents, misappropriation; d) influence peddling and unlawful favoritism; e) child labor, forced labor, slave labor or labor analogous to slavery, at any link in the chain; f) discrimination on the basis of race, color, ethnicity, origin, gender, sexual orientation, gender identity, religion, age, disability, social status or political conviction; g) workplace or sexual harassment, and any form of violence or humiliation; h) use of privileged information for one's own benefit or that of third parties.
4.2. These prohibitions apply even when the conduct would benefit Lexxen. No commercial result justifies a violation of this Code.
5. Anti-corruption
5.1. It is prohibited to offer, promise, give, authorize, request or receive, directly or indirectly, any undue advantage to or from a public official, private company or third party, under Law No. 12.846/2013 and Decree No. 11.129/2022.
5.2. The prohibition extends to payments made through intermediaries: consultants, agents, brokers and partners.
5.3. Facilitation payments (amounts paid to expedite routine acts) are prohibited, regardless of the amount.
5.4. Gifts, presents and hospitality. These are permitted only when, cumulatively, they:
- have symbolic value, as a rule up to R$ 200.00;
- are occasional, without recurrence with the same person;
- neither influence nor appear to influence a decision;
- are customary in an institutional context and could be disclosed publicly without embarrassment.
5.5. It is prohibited to offer or receive gifts in cash or cash equivalents: gift cards, crypto assets, equity interests, high-value tickets.
5.6. Gifts received outside these limits must be refused or, where refusal is not feasible, reported to compliance.
5.7. Donations and sponsorships require prior approval from management, prior verification of the beneficiary and proper accounting records. Electoral donations by legal entities are prohibited under Brazilian law.
6. Conflict of interest
6.1. A conflict of interest exists when the personal interest of the Team Member, or of a person close to them, could influence the impartiality of their actions.
6.2. Situations that require prior disclosure:
a) equity interest in or ties with a competitor, partner, client or supplier; b) hiring or managing family members and persons with whom one has a romantic relationship; c) outside activity that competes with Lexxen or uses its resources; d) receipt of remuneration from third parties for activity related to work at Lexxen; e) a decision in which the Team Member has a direct or indirect economic interest.
6.3. A conflict is not a violation in itself; the violation is failing to disclose it. Report it to compliance, which will provide guidance on recusal from the decision or other measures.
7. Anti-money laundering
7.1. Every Team Member must know and comply with Lexxen's AML/CFT Policy.
7.2. It is a duty to report immediately to compliance any atypical or suspicious transaction or situation, even where there is only an indication.
7.3. It is prohibited to alert a client, partner or third party to the existence of a report to the authorities, as prohibited by Article 11 of Law No. 9.613/1998.
7.4. It is prohibited to facilitate, advise on or tolerate structures that hinder the identification of the person who actually moves the funds.
8. Data protection and confidentiality
8.1. Personal data is processed in accordance with the LGPD and the Privacy Policy. Access follows the principle of need: only those who need access, for what they need it, may access it.
8.2. It is prohibited to look up client data out of curiosity, personal interest or for any purpose unrelated to work. Access is logged and audited.
8.3. Confidential information (strategies, client and partner data, source code, commercial terms) may not be disclosed to third parties or used for one's own benefit.
8.4. The duty of confidentiality continues after the end of the relationship.
8.5. Security incidents must be reported immediately, even in case of doubt or of one's own error. Reporting early reduces harm; concealing it makes it worse.
9. Relationships with third parties
9.1. Lexxen engages partners and suppliers subject to prior due diligence proportionate to the risk, verifying reputation, good standing and track record.
9.2. Contracts include clauses on integrity, data protection and compliance with this Code.
9.3. Lexxen may terminate its relationship with any third party that violates these standards.
9.4. Competition is based on merit. Agreements to fix prices, divide markets or rig competition are prohibited, as is obtaining competitor information by unlawful means.
10. Communication and use of resources
10.1. Public statements on behalf of Lexxen may be made only by those expressly authorized.
10.2. On social media, the Team Member must make clear when speaking in a personal capacity, and must not disclose confidential information or associate the brand with offensive or unlawful content.
10.3. Lexxen's resources (equipment, systems, access credentials, funds) are intended for professional use. Occasional and reasonable personal use is tolerated; use for unlawful purposes is not.
10.4. Accounting records, reports and communications must reflect reality. It is prohibited to record a transaction in a manner that conceals its true nature.
11. Whistleblower Channel
11.1. It is the duty of every Team Member to report any violation of this Code, the law or internal policies.
11.2. Channel: compliance@lexxen.com. Reports may be identified or anonymous.
11.3. Lexxen guarantees confidentiality and adopts an absolute prohibition on retaliation against anyone who reports in good faith, including when the investigation concludes that the report is unfounded.
11.4. Retaliation is, in itself, a serious violation of this Code.
11.5. A report proven to be false and made in bad faith is also a violation.
11.6. The procedure is detailed in the Whistleblower Channel document, published at www.lexxen.com.
12. Non-compliance
12.1. Violations are investigated impartially, with the opportunity to respond guaranteed.
12.2. Applicable measures, according to severity, recurrence and harm:
| Severity | Measures |
|---|---|
| Minor | formal guidance, verbal or written warning |
| Moderate | written warning, suspension, reassignment |
| Serious | termination of the contract, including for cause |
| Third parties | termination of the contract and removal from the partner registry |
12.3. These measures do not exclude civil, administrative and criminal liability, nor reporting to the authorities when the conduct constitutes an offense.
12.4. Enforcement is independent of position or length of service. The Code applies equally to management.
13. Governance
13.1. Senior management approves this Code, provides the resources for its implementation and is responsible for leading by example.
13.2. The Compliance function, exercised with the support of specialized legal counsel, provides guidance, investigates reports, proposes measures and keeps this Code up to date.
13.3. Every Team Member receives training on this Code upon joining and periodically thereafter, with attendance recorded.
13.4. This Code is reviewed at least annually, or whenever there is a relevant legal, regulatory or business model change.
14. Channels
| Purpose | Channel |
|---|---|
| Reports, ethical questions and conflicts of interest | compliance@lexxen.com |
| Client support | support@lexxen.com |
| Data Protection Officer (DPO) | Siffermann Sociedade Individual de Advocacia, Thiago de Oliveira Rocha Siffermann (OAB/GO 40.724), compliance@lexxen.com |
LEXXEN LTDA, CNPJ 63.987.111/0001-53 Goiânia/GO, August 31, 2026, version 1.0