Vinci Partners Investments Ltd

We have adopted a code of ethics applicable to the board of directors and all employees, which covers a broad range of matters including the handling of conflicts of interest, compliance issues and other corporate policies such as equal opportunity andnon-discrimination standards. In addition, we have also adopted a statement of trading policies that governs the trading in our securities by our directors, officers and certain other covered persons. Since its effective date, we have not waived compliance with our code of ethics or statement of trading policies.