Institutional Compliance Program

FINETAX Global Alliance ("FINETAX") — The Global Alliance in Capital Markets, Corporate and Taxation — is committed to conducting all of its activities in strict compliance with applicable laws and regulations in the United States of America and Brazil, with its internal regulations, and with the highest standards of ethical conduct and institutional integrity.

This Institutional Compliance Program represents the structured set of policies, controls, procedures, and mechanisms adopted by the organization to prevent, detect, and remediate misconduct, irregularities, and violations of law or internal norms that may compromise its mission, reputation, and the trust of its members, partners, and the broader community.

Compliance at FINETAX Global Alliance is not an isolated or merely bureaucratic function: it is a shared responsibility of every member of the organization, exercised in an integrated manner with governance, management, and institutional culture, and grounded in a genuine commitment to ethics, transparency, and legality. As a nonprofit organization operating under Section 501(c)(3) of the Internal Revenue Code, FINETAX Global Alliance recognizes that its compliance obligations extend beyond mere legal conformity to encompass the highest standards of public accountability and fiduciary responsibility.

TITLE I — GENERAL PROVISIONS

Chapter I — Program Objectives

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Section 1 The Institutional Compliance Program of FINETAX Global Alliance has the following objectives:

I — ensure the conformity of the organization's activities with applicable laws and regulations in the United States of America and Brazil, as well as with internal regulations and relevant sector-specific standards;

II — prevent the occurrence of irregularities, fraud, corruption, and ethical violations within the organization;

III — detect, in a timely manner, any deviations of conduct or normative violations;

IV — establish effective response and remediation mechanisms in the face of identified irregularities;

V — foster an organizational culture of ethics, integrity, and compliance at all levels of the organization;

VI — protect the reputation and institutional interests of FINETAX Global Alliance;

VII — ensure the confidence of members, partners, donors, regulators, and the broader community in the organization's activities.

Chapter II — Scope of Application

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Section 2 This Program applies to all members of FINETAX Global Alliance, in both jurisdictions of operation, including members, directors, mentors, collaborators, service providers, and partners acting on behalf of the organization.

Section 3 The Program is applicable to all institutional activities, including academic programs, partner relations, financial management, selection processes, relations with governmental authorities, and any other operations conducted by FINETAX Global Alliance.

Chapter III — Regulatory Framework

Section 4 This Program was developed in compliance with the following regulatory framework, without prejudice to other applicable norms:

In the United States of America:

I — Foreign Corrupt Practices Act (FCPA) — 15 U.S.C. §§ 78dd-1 et seq.;

II — Internal Revenue Code, Section 501(c)(3), and applicable IRS regulations governing tax-exempt nonprofit organizations;

III — Bank Secrecy Act (BSA) and applicable anti-money laundering regulations;

IV — USA PATRIOT Act — anti-terrorism financing provisions;

V — Sarbanes-Oxley Act (SOX) — applicable provisions relating to financial reporting and internal controls;

VI — New York Not-for-Profit Corporation Law;

VII — California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA);

VIII — New York SHIELD Act and other applicable state breach notification laws;

IX — Title VII of the Civil Rights Act of 1964 and applicable federal and state employment discrimination laws;

X — Americans with Disabilities Act (ADA) and applicable state equivalents;

XI — All applicable federal and New York State laws governing nonprofit organizations.

In Brazil:

I — Law No. 12.846/2013 — Brazilian Anti-Corruption Act (Lei Anticorrupção);

II — Law No. 8.429/1992 — Administrative Improbity Act;

III — Brazilian Civil Code (Law No. 10.406/2002);

IV — Law No. 13.709/2018 — Brazilian General Data Protection Law (LGPD);

V — Applicable tax legislation and the Brazilian Tax Code;

VI — All applicable laws governing nonprofit civil associations (associações civis sem fins lucrativos).

TITLE II — COMPLIANCE PROGRAM STRUCTURE

Chapter I — Program Pillars

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Section 5 The Institutional Compliance Program of FINETAX Global Alliance is structured upon the following fundamental pillars:

I — Tone at the Top: the FINETAX Global Alliance Council and the Executive Board unequivocally demonstrate and communicate their commitment to ethics, integrity, and regulatory compliance, allocating adequate resources to the Program and consistently modeling behavior aligned with the organization's values. Compliance starts with leadership.

II — Continuous Risk Assessment: systematic identification, assessment, and periodic monitoring of the compliance risks to which the organization is exposed, taking into account its institutional context, areas of operation, and the jurisdictions in which it operates, in accordance with best practices recognized by the U.S. Department of Justice and the Securities and Exchange Commission.

III — Policies and Procedures: existence of clear, accessible, and up-to-date internal standards that guide the conduct of all members in relation to the main areas of compliance risk, covering all jurisdictions and operational contexts.

IV — Training and Communication: promotion of a compliance culture through regular training, effective communication, and broad dissemination of the values and standards of the Program to all members of the organization.

V — Reporting Channels and Investigation: availability of secure, confidential, and accessible channels for reporting suspected irregularities, and existence of appropriate procedures for the investigation and remediation of cases, consistent with applicable law and best practices.

VI — Monitoring and Auditing: implementation of mechanisms for continuous monitoring of the Program's effectiveness and periodic audits of the highest-risk areas.

VII — Remediation and Continuous Improvement: adoption of effective remediation measures in response to identified irregularities and periodic review of the Program for its continuous improvement.

Chapter II — Compliance Governance

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Section 6 The governance of the Compliance Program is exercised by the following bodies and functions:

I — FINETAX Global Alliance Council: the highest supervisory body of the Program, responsible for approving compliance policies, periodically assessing their effectiveness, and ensuring the resources necessary for their implementation;

II — Executive Board: responsible for implementing and operationally managing the Program, designating the Compliance Officer, and ensuring the integration of compliance into institutional management;

III — Compliance Officer: a professional designated by the Executive Board with adequate functional autonomy and seniority, responsible for coordinating, implementing, monitoring, and reporting on the Institutional Compliance Program, with direct access to the FINETAX Global Alliance Council when necessary;

IV — All members of the organization: each member is individually responsible for knowing, observing, and contributing to the effectiveness of the Compliance Program, and for promptly reporting any suspected irregularity through the available channels.

Section 7 The Compliance Officer shall have direct access to the FINETAX Global Alliance Council, being able to report to it directly in cases involving the Executive Board or matters of special institutional relevance. This independence of reporting is essential to the effectiveness and credibility of the Program.

TITLE III — COMPLIANCE POLICIES

Chapter I — Anti-Corruption Policy

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Section 8 FINETAX Global Alliance adopts a policy of zero tolerance for corruption, prohibiting, under any circumstances and in all jurisdictions of operation, in full compliance with the Foreign Corrupt Practices Act (FCPA) and the Brazilian Anti-Corruption Act (Law No. 12.846/2013):

I — offering, promising, giving, authorizing, soliciting, or receiving, directly or indirectly, any improper advantage to government officials, domestic or foreign, with the aim of obtaining or maintaining business, an advantage, or any benefit for the organization;

II — making facilitating payments, even of small value, to government officials for the purpose of expediting routine governmental actions;

III — using intermediaries, partners, service providers, or any other persons to make payments or offer improper advantages that the organization itself could not make or offer directly.

Section 9 The anti-corruption policy of FINETAX Global Alliance applies to all relationships with Brazilian and foreign government officials and entities, in strict conformity with the FCPA, which prohibits corrupt payments to foreign officials in connection with obtaining or retaining business, and with the Brazilian Anti-Corruption Act.

Section 10 Private-sector corruption is equally prohibited, including:

I — offering or receiving improper advantages from partners, suppliers, universities, or any other private entities with which the organization maintains institutional relationships;

II — making payments, concessions, or favors with the aim of obtaining competitive advantage or undue preferential treatment.

Chapter II — Gifts, Entertainment, and Hospitality Policy

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Section 11 FINETAX Global Alliance adopts the following guidelines regarding gifts, entertainment, and hospitality:

I — the offering and receiving of gifts and promotional items of symbolic value, of an exclusively promotional or courtesy nature, is permitted, provided they do not create an expectation of reciprocity and are consistent with market practices and applicable law;

II — cash gifts or cash equivalents (including gift cards) are not permitted under any circumstances;

III — the receipt of gifts of significant value shall be communicated to the Compliance Officer, who shall determine the appropriate procedure in each case;

IV — hospitality expenses, such as meals and events, are permitted when reasonable, proportionate, properly recorded, and related to legitimate institutional purposes;

V — gifts, entertainment, or hospitality offered to government officials must strictly comply with all applicable legal restrictions in the relevant jurisdiction, and shall in any event comply with the FCPA and applicable state and federal law.

Chapter III — Anti-Money Laundering and Counter-Terrorism Financing Policy

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Section 12 FINETAX Global Alliance adopts measures to prevent money laundering and terrorism financing, in compliance with the Bank Secrecy Act, the USA PATRIOT Act, and other applicable federal and state laws, as well as applicable Brazilian legislation, including:

I — adequate know-your-partner (KYP) procedures for institutional partners, donors, and collaborators, proportionate to the identified risk;

II — monitoring of the sources of funds received by the organization, refusing contributions or donations whose origin cannot be adequately verified;

III — reporting to relevant authorities, in the forms required by applicable law, any suspicious transactions or situations identified;

IV — periodic training of all members on anti-money laundering and counter-terrorism financing obligations and best practices.

Chapter IV — Financial Management and Internal Controls Policy

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Section 13 FINETAX Global Alliance adopts the following principles of financial management and internal controls, consistent with its obligations as a 501(c)(3) organization and applicable law:

I — all revenues and expenses of the organization shall be accurately, completely, and timely recorded in its accounting, in accordance with applicable accounting standards in each jurisdiction, including U.S. Generally Accepted Accounting Principles (GAAP) or applicable equivalents;

II — the creation or maintenance of unofficial, off-the-books, or concealed accounts, funds, or accounting records is prohibited;

III — any significant financial transaction requires approval from at least two authorized members of the Executive Board, in accordance with internal regulations;

IV — institutional expenses must be properly documented, justified, and approved by the competent authorities before being incurred;

V — the organization shall undergo independent external audits on a periodic basis, the results of which shall be submitted to the FINETAX Global Alliance Council;

VI — no resources of the organization shall be used for personal benefit, without explicit and duly justified authorization under internal regulations;

VII — the organization shall comply with all IRS reporting and disclosure requirements applicable to 501(c)(3) organizations, including timely filing of Form 990 and any other required filings.

Chapter V — Third-Party and Partner Due Diligence Policy

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Section 14 Before establishing relationships with new institutional partners, suppliers, service providers, or any other entity acting on behalf of FINETAX Global Alliance, due diligence procedures proportionate to the identified risk shall be conducted, including:

I — verification of the entity's integrity and reputation, and that of its principal directors and beneficial owners;

II — assessment of the entity's legal and regulatory compliance history;

III — verification of the absence of involvement in corruption, money laundering, sanctions violations, or any other conduct incompatible with the values of the organization, including screening against applicable sanctions lists, such as those maintained by the U.S. Office of Foreign Assets Control (OFAC);

IV — analysis of the compatibility of the entity's values and practices with the principles of the FINETAX Global Alliance Compliance Program.

Section 15 Contracts with partners and third parties shall include compliance clauses that:

I — impose on the counterparty the obligation to observe integrity and compliance principles equivalent to those adopted by FINETAX Global Alliance;

II — provide FINETAX Global Alliance with the right to terminate the contract in the event of a violation of compliance obligations;

III — establish the right of FINETAX Global Alliance to audit the counterparty's compliance with its compliance obligations, where appropriate and proportionate.

Chapter VI — 501(c)(3) Governance and Tax-Exempt Status Compliance Policy

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Section 16 As a nonprofit organization exempt from federal income tax under Section 501(c)(3) of the Internal Revenue Code, FINETAX Global Alliance adopts the following specific compliance obligations:

I — the organization shall operate exclusively for educational, scientific, and charitable purposes consistent with its tax-exempt status, as declared to the IRS;

II — no part of the net earnings of the organization shall inure to the benefit of, or be distributable to, its directors, officers, members, or other private persons, except as reasonable compensation for services rendered;

III — the organization shall not carry on any activities not permitted to be carried on by an organization exempt from federal income tax under Section 501(c)(3);

IV — the organization shall not participate in, or intervene in, any political campaign on behalf of (or in opposition to) any candidate for public office;

V — no substantial part of the activities of the organization shall constitute the carrying on of propaganda or otherwise attempting to influence legislation, unless the organization has made the election under Section 501(h) of the Internal Revenue Code;

VI — the organization shall maintain accurate financial records and file all required returns and reports with the IRS and applicable state authorities on a timely basis;

VII — the organization shall implement and maintain a conflict of interest policy and document its application in connection with all relevant decisions by the Board and the Executive management.

Chapter VII — Transparency and Accountability Policy

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Section 17 FINETAX Global Alliance commits to the highest standards of transparency and accountability, adopting the following practices:

I — preparation and disclosure of periodic activity reports and financial statements, submitted to the FINETAX Global Alliance Council for review and approval;

II — submission to independent external audits, the results of which shall be made available to the competent governance bodies;

III — full compliance with all reporting and disclosure obligations to governmental authorities in each jurisdiction, including the IRS (Form 990), applicable state attorneys general, and the Brazilian Receita Federal;

IV — transparency about the organization's governance structure, institutional programs, and sources and uses of funds, within the limits of applicable law;

V — maintenance of all records required to demonstrate compliance with applicable law, including records of Board decisions, financial transactions, and conflicts of interest disclosures.

Chapter VIII — Equal Opportunity and Non-Discrimination Policy

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Section 18 FINETAX Global Alliance is committed to providing equal opportunity to all individuals, regardless of race, color, national origin, sex, gender identity, sexual orientation, age, disability, religion, veteran status, or any other characteristic protected by applicable federal and state law, including Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Age Discrimination in Employment Act, and applicable New York State and City laws.

Section 19 Harassment of any kind, including sexual harassment, is strictly prohibited within the organization and in any context related to its activities, and shall be subject to the disciplinary procedures set forth in the Institutional Code of Ethics and Conduct and applicable law.

TITLE IV — TRAINING AND COMMUNICATION

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Section 20 FINETAX Global Alliance shall maintain a structured compliance training program, including:

I — mandatory training of all new members on the Compliance Program, the Code of Ethics and Conduct, and relevant institutional policies, to be completed at the time of onboarding;

II — periodic refresher training, conducted at least once per year, for all members;

III — specialized training for members operating in higher-risk compliance areas, such as financial management, partner relations, and institutional representation before governmental authorities;

IV — records of participation in training sessions, with issuance of completion certificates.

Section 21 Communication of the Compliance Program shall be carried out through:

I — making this Program and related policies available on an accessible channel for all members;

II — periodic communications from the Executive Board and the Compliance Officer on compliance topics relevant to the organization;

III — ethics and integrity awareness campaigns, adapted to the cultural and linguistic contexts of both jurisdictions.

TITLE V — MONITORING, AUDITING, AND CONTINUOUS IMPROVEMENT

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Section 22 The Compliance Officer shall conduct continuous monitoring of the Program's effectiveness, including:

I — periodic assessment of the compliance risks to which the organization is exposed, with updates to the risk mapping at least annually;

II — monitoring of compliance with the Program's policies and procedures by members of the organization;

III — analysis of reports received through the whistleblowing channel and any compliance incidents that occur;

IV — preparation of periodic compliance reports, submitted to the Executive Board and, where pertinent, to the FINETAX Global Alliance Council.

Section 23 FINETAX Global Alliance shall undergo compliance audits conducted by an internal team or independent external auditors at least once per year, covering the principal risk areas identified in the risk assessment.

Section 24 The Compliance Program shall be reviewed annually by the Compliance Officer, with the participation of the Executive Board, to incorporate lessons learned, changes in the regulatory environment, and the results of audits conducted, and shall be submitted for approval to the FINETAX Global Alliance Council.

TITLE VI — WHISTLEBLOWING CHANNEL AND REPORTING

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Section 25 FINETAX Global Alliance shall maintain a permanent, accessible, and confidential whistleblowing channel, available to all members, directors, mentors, partners, and collaborators in both jurisdictions of operation, for the reporting of:

I — violations of the Code of Ethics and Conduct or this Compliance Program;

II — administrative, financial, or operational irregularities;

III — discriminatory, harassing, or retaliatory conduct;

IV — unauthorized use of the organization's brand, intellectual property, or resources;

V — violations of applicable law, including anti-corruption, anti-money laundering, or data protection obligations;

VI — any other conduct that may compromise the integrity, mission, or reputation of FINETAX Global Alliance.

Section 26 The whistleblowing channel shall guarantee the option of anonymity to the reporting individual, and the identity of the reporter shall not be disclosed without their express consent, except as required by law.

Section 27 Retaliation against any individual who, in good faith, reports a suspected irregularity through the whistleblowing channel or any other legitimate means is strictly prohibited. Retaliation shall constitute a serious ethical violation, subject to the maximum sanctions provided in the Institutional Code of Ethics and Conduct, and may also give rise to liability under applicable law, including applicable whistleblower protection statutes.

TITLE VII — INVESTIGATION AND REMEDIATION

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Section 28 All reports of suspected irregularities received through the whistleblowing channel or any other means shall be subject to a preliminary assessment by the Compliance Officer, who shall determine whether a formal investigation is warranted.

Section 29 Internal investigations shall be conducted with:

I — impartiality and objectivity, by individuals without a conflict of interest with the subject matter of the investigation;

II — respect for the rights of the investigated parties, ensuring due process in connection with any sanctions imposed;

III — appropriate confidentiality, protecting information generated in the course of the investigation;

IV — adequate documentation of all stages, including evidence gathered, interviews conducted, and conclusions reached.

Section 30 Upon confirmation of an irregularity, FINETAX Global Alliance shall adopt remediation measures proportionate to the gravity of the case, which may include:

I — application of the disciplinary sanctions provided in the Institutional Code of Ethics and Conduct;

II — review and strengthening of the internal controls relevant to prevent recurrence;

III — restitution of any resources improperly used;

IV — voluntary disclosure to competent authorities, where applicable and advisable, including consideration of any applicable cooperation and voluntary disclosure programs;

V — implementation of additional training and awareness measures for organization members.

TITLE VIII — FINAL PROVISIONS

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Section 31 Violations of the norms and policies of this Compliance Program by any member of FINETAX Global Alliance shall subject the violator to the sanctions provided in the Institutional Code of Ethics and Conduct, without prejudice to civil, administrative, and criminal liability under applicable United States and Brazilian law.

Section 32 This Program enters into force upon its approval by the FINETAX Global Alliance Council, revoking any prior instruments that conflict with it, and shall be reviewed annually or whenever relevant changes in the normative environment or in the organization's activities so require.

Section 33 Questions regarding the interpretation and application of this Program shall be addressed to the Compliance Officer, who shall resolve them in consultation with the Executive Board and, where pertinent, with the FINETAX Global Alliance Council.