Code of Ethics and Conduct

1. Introduction

Trio was born with the purpose of driving financial innovation, with a mindset fully focused on technological and human development. Trio's commitment goes beyond creating products of excellence and high performance. Trio also seeks to build relationships of trust, grounded in continuous respect and consideration for the needs of its customers, business partners and employees.

The values adopted by Trio guide employees, partners, executives, customers, investors and business partners in pursuing and upholding the Organization's purpose, always with responsibility and commitment. In this context, this Code of Ethics and Conduct (the “Code”) establishes the principles and guidelines that govern everyone's conduct, ensuring alignment with ethical practices and the strengthening of the corporate culture.

We are guided by development: Everything begins with an understanding of the engineering and technological progress that underpin every decision we make. This commitment to technical excellence creates an environment in which we value continuous growth and the pursuit of innovative solutions, always grounded in sound scientific knowledge. We recognize technology as the fundamental instrument for fulfilling our organizational purpose and for creating sustainable value.

We make the customer experience count: We build relationships based on a genuine understanding of our customers' needs. Our experience has shown us that effective solutions are born from active listening and a deep understanding of the challenges faced. We stay constantly close, offering dedicated support that turns innovative ideas into practical and accessible tools. We believe that the success of technology lies in its ability to simplify and enhance people's work. We are by and for businesses: Small businesses, startups and large corporations are the engines of the Brazilian economy, responsible for generating jobs and for the socioeconomic development of our cities. Our commitment is to deliver tangible benefits to those who start businesses, face challenges and transform markets. Our business positioning stems from an understanding of the strategic role that organizations play in society, as well as of the complex responsibilities they bear. That is why we devote our technological expertise to optimizing processes, increasing operational efficiency and enhancing the results of our corporate partners.

We stand for regulatory commitment and best practices: Trio maintains strict alignment with all rules and guidelines established by the regulatory bodies of the national financial system. Our commitment goes beyond mandatory compliance: we continually seek to adopt market best practices and to raise our compliance standards. Transparency guides every internal and external process, while information security remains a non-negotiable pillar of all our operations.

By respecting this Code of Ethics and Conduct, everyone contributes to protecting Trio's fundamental values and to preserving both personal and professional integrity within the Organization.

In a constantly changing environment, this Code serves as a guide to ethical conduct, establishing clear guidelines that steer our business decisions and corporate relationships. These standards must be incorporated and practiced consistently in day-to-day activities by all of Trio's employees, business partners and stakeholders.

2. Terms and definitions

2.1. The terms below, when referred to in this Code, have the following meanings:

2.1.1. Ethics: A set of principles and values that guide the conduct of employees, with a view to integrity, respect and responsibility.

2.1.2. Conduct: The behavior expected of all employees, partners, executives and third parties that deal with the Organization, which must reflect the values, principles and guidelines established in this Code.

2.1.3. Conflict of Interest: A situation in which personal, professional, financial, family or third-party interests may compromise or unduly influence an employee's decisions.

2.1.4. Moral Harassment: Abusive, repeated or systematic conduct that exposes an employee to humiliating or embarrassing situations in the workplace.

2.1.5. Sexual Harassment: Any unwanted manifestation of a sexual nature that causes embarrassment or intimidation.

2.1.6. Discrimination: The act of treating someone unequally or unfairly on the basis of personal characteristics, such as gender, age, race, color, ethnicity, religion, nationality, sexual orientation, disability or political belief.

2.1.7. Bribery/Corruption: Offering, promising, requesting or receiving an undue advantage to influence someone's decision or actions by virtue of their position.

2.1.8. Gifts and Hospitality: Any benefit, gift, invitation, entertainment or hospitality, offered or received, that may affect, or appear to affect, the employee's independence and objectivity.

2.1.9. Confidential Information: Non-public strategic, financial, technological, commercial or personal data or knowledge which, if improperly disclosed, may cause harm to the Organization or to the parties involved.

2.1.10. Personal Data: Personal data concerning racial or ethnic origin, religious belief, political opinion, trade union membership, data concerning health or sex life, and genetic or biometric data, as defined by the LGPD.

2.1.11. Sensitive Personal Data: Personal data concerning racial or ethnic origin, religious belief, political opinion, trade union membership, data concerning health or sex life, and genetic or biometric data, as defined by the LGPD.

2.1.12. Intellectual Property: Intangible assets such as trademarks, patents, software, projects, trade secrets and other creations developed by the Organization or by its employees.

2.1.13. Healthy Work Environment: A safe, inclusive and respectful workplace, free from discrimination, harassment, violence or any abusive practice.

3. Scope

3.1. This Code applies to the entire Trio Group, covering all products, companies and locations. Compliance with it is mandatory for partners, shareholders, officers, members of the Board of Directors, employees, temporary employees, third parties, interns and apprentices, hereinafter referred to as “employees”. All persons and companies that maintain business relationships with Trio must fully respect this Code.

3.2. All stakeholders must adopt conduct consistent with the letter and spirit of this Code, avoiding even the mere appearance of improper behavior. Well-intentioned actions that are nonetheless contrary to the law or to this Code may have negative consequences for the organization and the individuals involved. In addition, any Trio entities that may be subject to the supervision of national regulatory authorities must observe the applicable rules and regulations.

3.3. Each person involved in Trio's activities is responsible for reading, understanding and observing this Code. Trio undertakes to present this material to all applicable audiences, raising their awareness of the importance of respecting its values and rules, and to communicate any updates. After reading it, everyone must complete and sign the Commitment Statement as evidence that they have understood it and have committed to applying the principles set forth herein in their day-to-day activities.

4. Guidelines

4.1. Supplementary topics

4.1.1. To ensure complete understanding and compliance by all Trio employees, there are specific Policies and Standards that supplement this Code of Ethics and Conduct.

4.1.2. These documents will be integrated into Trio's Compliance Program whenever a specific topic requires additional specifications, as applicable, including:

Standard on Promotional Items, Gifts and Hospitality for third parties;
Compliance Policy;
Policy for the Prevention of Money Laundering and Combating the Financing of Terrorism;
Anti-Bribery and Anti-Corruption Policy;
Cybersecurity Policy;
Privacy Policy;
Disciplinary Measures Policy.

4.2. Work environment

4.2.1. Trio cultivates a strong culture, bringing together people who respect differences and foster a way of working together based on independence and collaboration. Developing a healthy interdependence between departments requires independence, which also reinforces the use of agile methodologies. We encourage proactivity within the boundaries of the work environment, aiming for a better future for all.

4.2.2. Trio conducts its business in compliance with all laws and regulations, establishing guidelines so that the actions of all employees provide a safe and healthy work environment for everyone.

4.2.3. Relations among employees are based on respect, transparency and team spirit. Therefore, it is everyone's responsibility to:

I. Work in such a way that, in the pursuit of results, respect and interpersonal collaboration prevail;
II. Value diversity, respecting differences and avoiding discrimination based on religion, color, ethnicity, nationality, age, sexual orientation, political views or any form of prejudice or hate speech;
III. Combat and report any type of sexist intimidation and/or any conduct that may be seen as sexual or moral harassment;
IV. Respect human rights and labor relations;
V. Preserve the integrity of their work, never using it, or the information gathered by virtue of their professional activity, to influence decisions that may favor private or third-party interests;
VI. Respect intellectual property, recognizing the value and authorship of projects, ideas, proposals and initiatives;
VII. Keep all of Trio's internal processes and documents secure and confidential at all times;
VIII. Use internal communication channels exclusively for professional matters and in a constructive manner;
IX. Use all materials provided responsibly and appropriately, exclusively in work-related activities, ensuring that equipment is kept secure and well maintained; and
X. Help apply this Code of Ethics and Conduct, as well as clarify questions about its use.

4.3. It is everyone's responsibility not to:

I. Use drugs during working hours, on Trio's premises or while working from home;
II. Use any nicotine products of any kind and/or other toxic substances on Trio's premises;
III. Commit any acts of hostility, intimidation or violence against other people in the workplace and in places where Trio's business is being conducted; and
IV. Bring firearms, explosives or any other weapons onto Trio's premises or into any work-related environment, even if the bearer holds a license to do so.

5. Conflict of interest

5.1. According to the Anti-Bribery Compliance Management Systems Certification Standard (NBR ISO 37001:2016), a conflict of interest occurs when professional, financial, family, political or personal matters may interfere with an employee's judgment in performing their duties within the organization.

5.2. All employees have a duty to strive to avoid situations that present a potential or actual conflict between their own interests and those of Trio, always acting honestly and ethically and always keeping the Organization's best interests in mind.

5.3. Some examples of prohibited situations include:

I. Using Trio's assets and resources, such as facilities, equipment, email accounts, software, etc., for personal benefit. All employees must protect assets against loss, theft or other misuse. Any suspected loss, misuse or theft must be reported;
II. Accepting high-value gifts, personal discounts not offered to the public or other benefits arising from their position in the organization, from competitors, customers or suppliers.
III. Sharing confidential information or knowledge at external events or activities;
IV. Favoring merchants, customers, suppliers, competitors or business partners out of personal interest;
V. Working for a competitor, customer or supplier while engaged by Trio, whether as a young apprentice, intern, employee, temporary employee, third party, partner or officer;
VI. Holding an equity interest in competitors (not including routine investments in publicly traded companies).
VII. Receiving a loan or a guarantee of an obligation as a result of their position at Trio;
VIII. Directing business to a supplier owned or managed by, or that employs, a relative or friend;
IX. Reporting relationships between family members (spouse, domestic partner or relatives, such as: father; mother; children, grandparents, grandchildren, nephews and nieces, cousins, uncles and aunts, parents-in-law and siblings-in-law);
X. Taking for themselves business opportunities discovered through the use of corporate property, information or position. No employee may use corporate property, information or positions for their own personal gain or to compete with Trio.

5.4. Should an actual or apparent conflict of interest arise, the conflict must be handled ethically, in accordance with this Code. Any actual or apparent conflict identified must be reported to the Compliance department by email at: compliance@trio.com.br .

6. Information protection

6.1. Protecting Trio's confidential information, whether written or verbal, is the duty of all employees. All of Trio's documents and information must have their confidentiality classification properly filled in. All employees have a duty not to disclose confidential information, whether or not it bears the “Confidential” classification.

6.2. Confidential information is data, knowledge or details that, due to their sensitive or strategic nature, must be protected against unauthorized access, disclosure or use. Such information is considered valuable and critical to an Organization, and its improper exposure may cause significant harm, such as financial loss, reputational damage, legal violations or compromised security.

6.3. The nature of confidential information may vary from one Organization to another, but it generally includes:

I. Personal data: Personal information of employees, customers or business partners, such as CPF (individual taxpayer ID) numbers, credit card numbers, addresses, medical information, etc.;
II. Intellectual property: Encompasses trade secrets, patents, copyrights, designs and any other form of intellectual property that is fundamental to the Organization's success;
III. Financial information: Confidential financial data includes account records, financial statements, projections, budgets and information on financial transactions;
IV. Strategic plans: Business strategies, marketing plans, growth objectives and other documents that outline the Organization's future direction;
V. Research and development data: Information related to ongoing research, prototypes, formulas, processes and innovations that the Organization is developing;
VI. Contractual information: Contracts with suppliers, customers or business partners that contain confidentiality clauses or details of strategic agreements;
VII. Internal communications: Emails, memos and internal documents that contain strategic or sensitive information for the Organization;
VIII. Human resources: Information about employees, such as HR records, salaries, performance reviews and hiring documents;
IX. Legal records: Documentation related to ongoing litigation, lawsuits or legal matters the Organization is facing;
X. Information technology: Passwords, access credentials, security settings, network information and details about the IT infrastructure;
XI. Compliance and regulations: Information related to compliance with laws and regulations, as well as internal and external audits.

6.4. Trio has a legal obligation to protect confidential information, especially customers' personal data, under the data privacy rules of Brazil's Personal Data Protection Law (LGPD — Lei Geral de Proteção de Dados Pessoais) and the GDPR (General Data Protection Regulation), a European Union regulation on privacy and the protection of personal data, applicable to all individuals in the European Union and the European Economic Area.

6.5. Proper protection of confidential information within Trio involves security measures such as encryption, access control, the Cybersecurity Policy, employee training and the implementation of rigorous security protocols to ensure that such information remains secure and accessible only to authorized persons.

6.6. In addition, it is important to avoid publicly naming third parties that maintain business relationships with Trio, since confidentiality agreements may have been entered into with these parties.

7. General provisions

7.1. This policy will be reassessed at least annually by the Compliance department and will take into account the reports issued by internal audit and legislative updates.

7.2. If you have any questions about this Code or its application, contact the Compliance department by email at compliance@trio.com.br or through the website trio.com.br.

7.3. If you are aware of, or have any indication of, non-compliance with this Code, contact the Compliance department by email at compliance@trio.com.br.

Not applicable