Note: this is a whistleblower channel and a channel for handling complaints as a last resort. It is not an Ombudsman (Ouvidoria) within the meaning of CMN Resolution No. 4.860/2020, which applies to institutions authorized by the Central Bank of Brazil. Lexxen is neither a financial institution nor a payment institution; requests concerning services provided by partner institutions may need to be handled through the channels and ombudsman offices of those institutions, and we will provide guidance on how to proceed.
1. What it is for
1.1. This channel receives reports of:
- violations of the Code of Ethics and Conduct
- corruption, fraud, bribery or undue advantage
- money laundering or terrorist financing
- workplace or sexual harassment, discrimination and violence
- undisclosed conflicts of interest
- misuse of personal data or security incidents
- accounting, tax or corporate irregularities
- complaints not resolved by support
1.2. For operational questions and usage problems, contact support@lexxen.com first; it is faster. This channel is for matters that support cannot resolve or should not handle.
2. Who can use it
Anyone: Team Members, clients, partners, suppliers, job applicants, former Team Members and third parties. You do not need to have a relationship with Lexxen to file a report.
3. How it works
3.1. Send your report to compliance@lexxen.com.
3.2. For an effective investigation, provide, to the extent possible:
| Item | Why |
|---|---|
| What happened | objective description of the facts |
| Who was involved | allows the right people to be heard |
| When and where | defines the period under investigation |
| How you became aware of it | helps assess the report |
| Evidence | documents, messages, records, screenshots |
3.3. Generic reports, lacking the minimum elements needed for an investigation, may be closed without action, but they will be recorded and taken into account if corroborating reports are received.
4. Anonymity
4.1. A report may be identified or anonymous.
4.2. If you identify yourself, you will receive feedback on the progress and conclusion. Your identity is treated confidentially and disclosed only to those who are indispensable to the investigation.
4.3. In an anonymous report, provide as many elements as possible: since we cannot ask for clarification, the investigation depends entirely on what was submitted.
5. Non-retaliation
5.1. Lexxen prohibits any form of retaliation against anyone who reports in good faith: dismissal, demotion, isolation, punitive transfer, reduction of responsibilities, embarrassment or any other detriment.
5.2. This protection applies even if the investigation concludes that the report is unfounded, provided the report was made in good faith.
5.3. This protection extends to anyone who cooperates with the investigation as a witness.
5.4. Retaliation is a serious violation, subject to the measures of the Code of Ethics, including termination for cause.
5.5. Have you suffered retaliation? Report it through this same channel, referring to the original report.
6. Timeframes
| Stage | Timeframe |
|---|---|
| Acknowledgment of receipt | up to 5 business days (when identified) |
| Admissibility review | up to 10 business days |
| Conclusion of the investigation | up to 60 days from admission, extendable once for an equal period with justification |
| Communication of the conclusion | up to 10 business days from closure (when identified) |
6.1. Cases of imminent risk (safety of persons, ongoing data incident, significant financial risk) receive immediate treatment, regardless of these timeframes.
7. How we investigate
7.1. Registration: every report is registered with its own identifier.
7.2. Admissibility: we verify whether the report contains the minimum elements and whether it is within scope.
7.3. Investigation: conducted by the Compliance function, with the support of specialized legal counsel, through analysis of documents and system records and through interviews.
7.4. Impartiality: anyone with any involvement in the facts does not take part in the investigation. Where a member of management is involved, the investigation is conducted with independent external support.
7.5. Right to respond: the person named has the opportunity to respond before any measure is taken.
7.6. Decision and measures: in accordance with section 12 of the Code of Ethics.
7.7. Reporting to authorities: where an offense is identified, the facts are reported to the competent authorities. In cases of suspected money laundering, reporting to COAF (Brazil's financial intelligence unit) is mandatory and may not be disclosed to the person reported, under Article 11 of Law No. 9.613/1998 (the Brazilian Anti-Money Laundering Law).
8. Confidentiality and personal data
8.1. Reports are treated confidentially. Access is restricted to those taking part in the investigation.
8.2. Personal data contained in the report is processed for the purposes of investigation and compliance with legal obligations, in accordance with the Privacy Policy, and retained for the legally required periods.
8.3. The identity of the whistleblower is not disclosed to the person reported, except where required by law or by court order, in which case, where possible, the whistleblower will be notified.
9. Records and improvement
9.1. Reports are consolidated in a periodic report to management, with the number of cases, categories, timeframes and measures, without identifying whistleblowers.
9.2. This data guides the review of controls, training and policies. A report that exposes a process failure leads to correction of the process, not just of the individual case.
10. Channels
| Purpose | Channel |
|---|---|
| Reports and complaints as a last resort | compliance@lexxen.com |
| Support and operational questions | support@lexxen.com |
| Personal data subjects (LGPD) | compliance@lexxen.com |
LEXXEN LTDA, CNPJ 63.987.111/0001-53 Goiânia/GO, August 31, 2026, version 1.0