Code of Ethics and Conduct

Version 1.0 · October 2026 · approved by the partners of Solidy Consulting

This is a translation provided for convenience. In case of any discrepancy, the Portuguese version prevails.

A message from our partners

Since 2006, Solidy has been responsible for numbers that underpin important decisions for our clients: balance sheets, taxes, payroll, cash and growth plans. That work is only worth something if it is done with integrity. That is why this code is not meant to sit in a drawer. It describes how we work, what we expect from the people who work with us and what we will not accept under any circumstances.

If you are ever unsure about the right thing to do, ask. And if you see something wrong, speak up. You will find how to do so at the end of this document.

Rocélio Tenório and Adriana da Ponte
Partners, Solidy Consulting

Who this code applies to

This code applies to everyone who acts on Solidy’s behalf, regardless of position, role or length of service: partners, employees, interns and apprentices, service providers, consultants and partner professionals, including those working as CFO as a Service (fractional CFOs). We expect our suppliers and business partners to follow the same principles in their dealings with Solidy and with our clients.

Our principles

The principles below are based on the IBGC (Brazilian Institute of Corporate Governance) Code of Best Practices of Corporate Governance, 6th edition, and on the Code of Professional Ethics for Accountants issued by the CFC (Brazil’s Federal Accounting Council).

• Integrity: acting honestly and making sure what we do matches what we say, even when no one is watching.
• Transparency: communicating clearly and in a timely manner, without leaving out anything relevant to the client or to the firm.
• Equity: treating clients, colleagues and partners fairly and respectfully, without favoritism or discrimination.
• Accountability: taking responsibility for our own work and for the consequences of our own decisions.
• Sustainability: considering the long-term effect of our choices on clients, people and society.
• Professional secrecy: keeping confidential what we learn through our work, except in the cases provided for by law.
• Competence: taking on only work for which we have the technical capability, and continuously keeping our knowledge up to date.

Our clients

• Confidentiality: client information, documents and data are used only for the engagement and are not shared with third parties without authorization or a legal obligation to do so.
• Compliance with the law: we do not take part in fraud, tax evasion, sham transactions or any practice that violates tax, labor or corporate law. For us, tax planning means using the options the law provides, never circumventing it.
• Accurate records: financial statements, tax calculations and reports reflect the facts as they are. We do not alter numbers to serve anyone’s interests.
• Honest selling: proposals clearly describe the scope, timelines and price. We do not promise results we cannot guarantee.
• Responsible refusal: we decline or end engagements when we lack the necessary technical capability or when a client asks for something that is contrary to the law or to this code.
• Anti-money laundering: we do not accept clients, transactions or funds of questionable origin, and we meet our legal anti-money laundering obligations, including reporting to the competent authorities when required.

Our workplace

• Respect: everyone deserves to be treated with courtesy and dignity, at every level of the organization.
• Harassment: we do not tolerate bullying (moral harassment), sexual harassment or any form of violence, intimidation or humiliation, whether in person or online.
• Discrimination: we do not accept discrimination based on gender, race, color, origin, religion, sexual orientation, gender identity, age, disability, marital status, social status or political opinion.
• Health and well-being: we organize work with people’s physical and mental health in mind, including psychosocial risks such as work overload and unclear targets.
• Diversity: we value diverse teams and decisions informed by different points of view.

Conflicts of interest, gifts and hospitality

A conflict of interest exists when a personal interest may influence, or appear to influence, a professional decision. Examples include hiring a supplier owned by a relative, providing services on your own account to a Solidy client, or holding an interest in a competitor or client company.

• Potential conflicts must be disclosed to the partners before any decision is made.
• Gifts, giveaways and invitations may be accepted or offered only when they are of token value, occasional and unrelated to any pending decision. If in doubt, consult the partners first.
• We never offer, promise or accept any improper advantage, whether in cash or in any other form.

Dealing with government and anti-corruption

• We comply with anti-corruption laws: it is prohibited to offer, promise or give any improper advantage to a public official, directly or indirectly, including through third parties.
• We do not make payments to “speed up” proceedings, inspections, certificates or services at government agencies.
• All interactions with government agencies on behalf of clients take place through official channels and are documented.
• Solidy does not make contributions to political parties or election campaigns. Each person is free to take part in politics, but always in a personal capacity, without using the firm’s resources, time or name.

Information, personal data and technology

• Data protection: we process the personal data of clients, employees and partners in accordance with data protection law (Brazil’s LGPD) and our Privacy Policy.
• Security: passwords, digital certificates and access credentials to portals and systems are personal and non-transferable and must be protected. Incidents or suspected data leaks must be reported immediately.
• Artificial intelligence: AI tools may be used with client data only when approved by Solidy and with appropriate confidentiality and data protection safeguards. AI-generated output is always reviewed by a person before it reaches the client.
• Social media and communications: we do not disclose client information, including in anonymized form that would still allow clients to be identified, and we speak on Solidy’s behalf only when authorized.

Suppliers and partners

We select suppliers and partners based on technical, price and reputational criteria. We expect them to respect the law, decent working conditions, the confidentiality of information and the principles of this code. Relationships that run contrary to these principles may be terminated.

How to report misconduct

Anyone who becomes aware of or suspects a violation of this code, the law or Solidy’s policies must report it through the Ethics Hotline. Reports may be made anonymously.

• Non-retaliation: no one who reports a concern in good faith will be punished, persecuted or otherwise disadvantaged for doing so, even if the investigation does not substantiate the facts.
• Confidentiality: reports and investigations are handled confidentially and are accessible only to those conducting the investigation.
• Impartiality: reports are investigated by the Ethics Committee, made up of the partners. If a report involves one of the partners, the investigation is conducted solely by the other.
• Bad faith: reports known to be false and made to harm someone are also violations of this code.

Investigation and disciplinary measures

Every report is reviewed and, where there is evidence, investigated, with the people involved given the right to present their side. If a violation is confirmed, the measures taken are proportionate to its seriousness and may include guidance, a warning, suspension, dismissal or termination of contract, as well as reporting to the authorities when an unlawful act is involved.

Questions, review and effective date

Questions about this code may be raised with the partners or sent to etica@solidy.consulting. This code takes effect on the date of its publication and will be reviewed whenever necessary, and at least every two years. Everyone who acts on Solidy’s behalf must know and follow it.