HOLDING SIX CORPORATION

HOLDING SIX CORPORATION, a private legal entity, registered with the CNPJ under No. 32.803.097/0001-67, with headquarters at Alameda Xingu, 350, 14th floor, Alphaville, Barueri/SP, hereinafter referred to simply as HOLDING SIX or CONTROLLER, hereby adopts this Compliance Policy, in observance of the best corporate governance practices, Law No. 12.846/2013 (Anti-Corruption Law), Law No. 13.709/2018 (LGPD), the Consumer Protection Code, CONAR standards, and other applicable legislation.

HOLDING SIX reaffirms its commitment to the ethical, sound, and transparent conduct of its activities, promoting an organizational culture based on legality, prevention of unlawful acts, anti-corruption, personal data protection, socio-business responsibility, and regulatory compliance.

The purpose of this Policy is to guide administrators, employees, suppliers, partners, and third parties regarding the expected standards of conduct, the mechanisms for preventing and detecting irregularities, and the governance instruments intended to ensure the integrity of HOLDING SIX's operations.

1. Objective

1.1. Establish integrity, transparency, and compliance guidelines applicable to HOLDING SIX's activities, especially with regard to paid traffic practices, digital marketing, and online advertising, preventing legal, regulatory, financial, and reputational risks.

1.2. Ensure that all communication campaigns and actions are aligned with legal standards, internal policies, and the institutional values of HOLDING SIX.

2. Scope of Application

2.1. This Policy applies to:

administrators and members of senior management;

employees and service providers;

suppliers, marketing agencies, affiliates, digital partners;

any third parties that act, directly or indirectly, in advertising, paid traffic, or digital marketing campaigns linked to HOLDING SIX.

2.2. Compliance with this Policy is an essential condition for maintaining any contractual or commercial relationship with HOLDING SIX.

3. Fundamental Principles
   3.1. Responsible Advertising

The publication of misleading, abusive, discriminatory, or consumer-deceptive advertisements is prohibited, pursuant to the Consumer Protection Code and CONAR standards.

3.2. Data Protection (LGPD)

All campaigns must strictly comply with Law No. 13.709/2018 (LGPD), including:

use of an appropriate legal basis for data processing;

obtaining valid consent when required;

transparency in the use of cookies, pixels, remarketing, and tracking technologies;

purpose limitation and data minimization.

3.3. Compliance with Digital Platforms

Compliance with the policies and terms of use of the platforms used, such as Google Ads, Meta Ads, TikTok Ads, and similar platforms, is mandatory.

3.4. Transparency and Good Faith

Communication must be clear, objective, verifiable, and compatible with the products, services, or operations disclosed, and any promise of results, profitability, or benefit not proven is prohibited.

4. Partner Due Diligence

4.1. Before hiring agencies, lead suppliers, affiliates, freelancers, or digital partners, HOLDING SIX may conduct a due diligence procedure, which may include:

reputational analysis;

verification of compliance history;

assessment of data protection practices;

absence of convictions for fraud, corruption, or abusive advertising.

4.2. The hiring may be refused or terminated if relevant risks to HOLDING SIX's integrity, reputation, or compliance are identified.

5. Responsibilities
   5.1. Administrators and Employees

Fully comply with this Policy;

Report irregularities through the appropriate internal channel;

Ensure the truthfulness and appropriateness of the information conveyed in campaigns;

Refrain from approving content or strategies that violate legal or ethical standards.

5.2. Paid Traffic Partners and Agencies

Fully observe the CDC, CONAR, LGPD, and digital platform policies;

Keep organized records of campaigns for audit purposes;

Cooperate with internal audits or requests for clarification;

Assume contractual responsibility for any non-compliance.

5.3. Compliance Department

Monitor digital campaigns and advertising actions;

Investigate complaints or suspicions of irregularities;

Determine adjustments, suspension, or cancellation of campaigns;

Promote periodic training on ethics, digital advertising, and data protection;

Recommend disciplinary measures when necessary.

6. Expressly Prohibited Conduct

It is expressly prohibited to:

Publish misleading, abusive, or fraudulent advertising;

Use unfounded promises or unverifiable information;

Buy or use leads obtained unlawfully;

Use spam, bots, artificial clicks, or any fraudulent technique;

Share personal data without a legal basis;

Fail to comply with digital platform policies;

Engage in any act that constitutes fraud, corruption, or violation of regulatory standards.

7. Sanctions

7.1. Failure to comply with this Policy shall subject the offender, as applicable, to the following measures:

formal warning;

suspension of campaigns;

blocking of access or activities;

immediate termination of the contract for cause;

application of contractual penalties;

notification of the competent authorities in the event of indications of civil or criminal wrongdoing.

7.2. The application of sanctions does not exclude any civil, administrative, or criminal liability.

8. Final Provisions

8.1. This Policy shall enter into force on the date of its approval by the Senior Management of HOLDING SIX.

8.2. Compliance with it is mandatory and constitutes an indispensable condition for maintaining contractual, commercial, or institutional ties with HOLDING SIX.

8.3. HOLDING SIX may review and update this Policy at any time, aiming at its improvement and adaptation to the current legal and regulatory standards.