Anti-Corruption and Anti-Money Laundering Policy CORPORATE POLICY – JULY / 2025
"There can be no crime more serious than corruption. Other offenses violate a law, while corruption violates the foundation of all laws.
There can be no greater crime than that in which an elected representative sells this sacred trust for his own benefit and enrichment; nor is there a lesser crime committed by one who corrupts. This is worse than a thief, for the thief robs an individual, while the corrupt politician plunders an entire city or state.
He is as evil as the murderer, for the murderer takes a life against the law, while the corrupt and the one who corrupts him have as their objective the murder of the democratic State itself.
(…) If we fail to do everything we can to stem corruption, we will not escape our share of the blame (…)”
26th President of the United States
Compliance: derives from the English verb “to comply”, which means the duty to comply, that is, to be in compliance with and enforce laws, decrees, regulations and instructions applicable to MatrixGO's activity, which, in the event of non-compliance, may result in sanctions, financial loss and damage to reputation/image.
This Anti-Corruption Policy (hereinafter referred to as the "Policy") primarily addresses compliance with anti-corruption legal requirements and the development, among other things, of the general principle of integrity enshrined in MatrixGO's Business Principles, as a fundamental standard that demonstrates the company's commitment to acting in accordance with the highest ethical principles, conveying the importance of corporate integrity to all of its board members, directors, and employees. These principles encourage the company to make a public commitment to responsible management that goes beyond legal compliance, as well as to foster and ensure respect for the values embodied therein among its board members, directors, employees, and business partners.
In accordance with the main international references on corporate responsibility and anti-corruption—such as the OECD recommendations; the US Foreign Corrupt Practices Act (FCPA); the UK Bribery Act; This Policy is also fully aligned with Law No. 12,846/2013 (Corporate Anti-Corruption Law) and its complementary regulations, or the criminal law reforms of Brazil and other countries—and in accordance with the aforementioned Business Principles, it is important for the company to ensure that certain conducts that undermine corporate integrity, which may influence a business decision or incur potential conflicts of interest that may override personal priorities, are not permitted within its scope. This ensures that all individuals involved in its activities behave with integrity, without seeking, under any circumstances, illegitimate benefits for the company, either for themselves or for third parties, through the improper use of their position or contacts.
This Policy establishes guidelines for the acceptance or offering of gifts or invitations, prohibiting any type of bribery. It is not permitted to promise, offer, or give any benefit or advantage of any nature, directly or indirectly (through a third party), for the purpose of influencing decisions of any kind (including governmental, administrative, or judicial) or obtaining undue advantages for the company. It is also prohibited to accept any benefit or advantage that could result in a breach of the obligations and duties of the company's directors, officers, and employees.
MatrixGO, although not operating as a bank or financial institution, but as a telecommunications engineering service provider, also has Money Laundering Prevention measures in place, in an effort to preserve basic security requirements and maintain responsible standards in its administrative operations with clients.
This Policy serves as a minimum parameter and must be observed by all of the company's advisors, directors, employees and interns, in any of the territories in which it is present, as well as by third parties who intermediate, collaborate and/or participate in business on behalf of the company.
All MatrixGO professionals, within their activities and regardless of their hierarchical positions, have roles and responsibilities related to money laundering prevention. The organizational structure mentioned below is directly identified with the responsibilities of each professional regarding money laundering prevention and compliance with the law.
Object of Value: any tangible or intangible item of value, broadly defined, in any form, including, but not limited to: cash, cash equivalents (such as gift cards and product discounts), loans, gifts, invitations, real or personal property, services, employment for family members, travel, accommodations, entertainment, meals, expense reimbursement, favors, business or employment opportunities, fulfillment of a request to deliver something of value to a third party, contributions to charitable or other non-profit organizations, and promotional sponsorships.
Public Official/Employee: refers to: (i) any public or elected official, agent, employee (regardless of position) or person acting on behalf of a national, state or municipal government, department, agency, body, state-owned or controlled company, public international organization, political party or entity financed primarily by public funds, which is generally perceived as performing governmental functions, or which has key executives or directors appointed by a government; and (ii) any political party, political candidate for office or any person acting on behalf of the party or candidate for political office. By way of example, these include: issuers of government licenses, approvals or permits (whether at the international, national, regional, municipal, etc. level), airport authorities, employees and directors of state-owned companies, customs, immigration or tax agents, or ministers or representatives of national or foreign governments.
Business Partner: third parties acting on behalf of or on behalf of the company or any entity owned or controlled by the company, who may interact with external agents, especially if these are Employees; or any partnership in which the company has economic interests, in which they intervene, among others, for example: agents, brokers, intermediaries, advisors, consultants, representatives, joint venture partners, co-investors, franchisees, authorized suppliers, travel agencies, authorized carriers or customs agents, lawyers or lobbyists acting on behalf of or on behalf of the company.
– any Employee, directors, managers, and interns, or any individual or legal entity (public or private), for the purpose of unduly influencing an Employee's decision, to obtain or retain a business or any other advantage. This prohibition applies regardless of whether the payment is to facilitate, expedite, or expedite procedures.
4.1.3 No manager, director or employee may benefit, in private purchases made from Business Partners or suppliers, from discounts or advantageous conditions that exceed the general conditions applicable in general to employees of the respective company.
4.1.4. It is prohibited to offer, promise, pay, give or authorize the delivery of any Object of Value to third parties, knowing that, with a high probability, the third parties, in turn, will offer, promise or provide any advantage prohibited in this section 4.1.
The use of own funds or third-party funds to circumvent the objectives of this Policy is expressly prohibited.
Business gifts and invitations should never be offered or accepted for illicit purposes and must, in all cases:
The acceptance by the company's managers, directors and employees, within the scope of corporate social practices, of invitations to promotional or business events, in which the organizing entity or company (other than MatrixGO) assumes reasonable travel, accommodation and/or maintenance expenses, will not be considered irregular, provided that the purpose of such invitation is exclusively the presentation of products or services of such organizing entity or company and the invitation is not individual, but rather addressed to a group of customers or potential customers.
It is also acceptable for MatrixGO, within the scope of corporate social practices, to assume expenses directly related to promotional events or demonstrations of products or services that are the subject of the business and, in particular, to invite third parties, assuming the respective reasonable expenses for travel, accommodation and/or maintenance, provided that they are not intended to obtain any advantage prohibited in section 4.1 above.
Likewise, MatrixGO may incur reasonable expenses directly related to training events or training forums, including travel, accommodation and/or maintenance expenses, provided that they are not intended to obtain any advantage prohibited in section 4.1 above.
RACCOUNTING AND FINANCIAL RECORDSANCES
The company requires that a system of adequate internal accounting controls be maintained and that all transactions be reported and reflected fairly, accurately, and in reasonable detail in the company's books and records; therefore, the books of accounts must not contain false or misleading records or statements, such as recording an expense for gifts or invitations as something other than its nature.
Transactions should never be intentionally recorded incorrectly regarding accounting accounts, departments, or accounting periods. Accurate, appropriate, and reasonably detailed documentation will be maintained to support all transactions, and documents will be preserved in accordance with the company's information and document management policies.
All MatrixGO Professionals involved in the stages related to financial operations must observe the aspects aimed at preventing money laundering, as defined in this Policy and in all devices and regulations in force.
MatrixGO will maintain a system of continuous monitoring of its practices and internal controls to prevent and detect risks of corruption, bribery and money laundering, reviewing and improving its procedures whenever necessary.
The company has several regulations that establish mandatory provisions regarding relationships with suppliers and Business Partners.
The Company will not engage or conduct business with a Business Partner if it believes there is a risk that the Business Partner will violate applicable anti-corruption laws or the prohibitions set out in this Policy.
Before establishing a business relationship with any Business Partner that will interact on behalf of the company, especially if it will interact with Employees, the Purchasing area (in the case of negotiations within its scope of activity) or the Management area (in contracts outside the scope of the Purchasing area) must carry out an adequate assessment of the Business Partner in this regard and ensure that:
Cooperation of managers, directors and employees: this Policy is mandatory for all managers, directors and employees of the company, and they must collaborate fully and sincerely in whatever is required of them in this regard.
Training: Depending on your responsibilities, the Company may request the assistance of managers, directors and employees for training related to this Policy. Certifications: Managers and Directors of the company, as responsible for establishing adequate controls and procedures to ensure compliance with this Policy, must certify annually (or, in any case, before terminating their activities within the company or when so requested by the company) compliance with the provisions of this Policy, within their scope of responsibility, in accordance with the model established in Annex 1.
In addition, MatrixGO will provide mandatory periodic training, in person or online, to all employees, partners and third parties, to reinforce the understanding of this Policy and its guidelines, keeping records of participation.
The HR and Customer Service teams will be responsible for ensuring that all other professionals are up-to-date with the information and training MatrixGO deems relevant to maintaining the aforementioned Money Laundering Prevention Policy. Furthermore, the HR and Customer Service department will be responsible for ensuring full service to registered customers, maintaining transparency and ensuring the reasons for requesting information and retaining registration data and data related to any financial transactions/payments.
Information Technology and Support professionals will be responsible for ensuring that all MatrixGO online and offline systems operate fully. In the event of unforeseeable circumstances or force majeure, customers will be notified as soon as possible. Furthermore, in the event of system adjustments and revisions that render services inaccessible or impaired, the support department must be notified so that customers are also informed.
All professionals who are not listed here in any of the aforementioned sectors must respect the rules linked to the others, preserving the validity of this MatrixGO Money Laundering Prevention Policy and, whenever suspicious activity by professionals or clients is identified, immediately report it to the hierarchical superior that concerns them or that is necessary.
It is the responsibility of each and every manager, director and employee to strictly comply with what is established herein and it is the responsibility of the advisors and directors to explain and disseminate this Policy among their employees and to supervise its compliance.
Oversight mechanisms will be implemented to verify compliance with the provisions of this Policy. If there is any evidence of potential noncompliance with the provisions of this document, appropriate investigation will be conducted. Periodic audits will be conducted, and annual reports on the results will be submitted to the respective Audit Committee.
Any violation of the provisions of this Policy will be considered an infraction subject to disciplinary action determined by the Human Resources Department, after due analysis and in accordance with the applicable work regime, with any form of corruption being of the utmost seriousness.
Periodic audits will take place once a year, or whenever necessary, as determined by senior management.
If a manager, director, or employee has questions regarding compliance, application, or interpretation of this Policy, they should send an email to ouvidoria@matrixgo.ai to receive guidance and clarification from the Principles and Practice Department. Anyone aware of any violation or suspected violation of this Policy is expected to report it to the same email address – ouvidoria@matrixgo.ai. We appreciate this cooperation and, in accordance with our policies, prohibit any retaliation against those who make such reports in good faith.
MatrixGO adopts a policy of non-retaliation, ensuring protection against any form of retaliation, punishment or discrimination against employees who, in good faith, make complaints or report suspected violations of this Policy.
The general principles of this Policy will come into effect upon its approval by Matrix.
