Vale S.A.

We have a Code of Conduct that applies to the members of our Board of Directors and our Executive Committee, including the chief executive officer and executive vice-presidents, our employees, interns and to our subsidiaries in Brazil and abroad, as well as and any person acting on behalf of Vale or its subsidiaries. Our suppliers and other third parties that collaborate with us must act in accordance with Vale’s Principles of Conduct for Third Parties.

Our Code of Conduct gathers the fundamental principles that underpin our business, and is part of Vale´s Ethics & Compliance Program, which is monitored by the Audit and Risks Committee and the Conduct and Integrity Committee, and is under the responsibility of the Audit and Compliance Department. Our Code of Conduct is a principle-based document, which connects directly with our company’s purpose and values.

We have published the Code of Conduct on our website, at:https://www.vale.com/en/code-of-conduct. We have not granted any implicit or explicit waivers from any provision of our Code of Conduct since its adoption.

Whistleblower Channel

Any breaches of our policies and standards can be reported by anyone, including employees, contractors, suppliers, members of affected communities and other stakeholders, via our Whistleblower Channel, which is available in 8 languages. Our Whistleblower Channel is managed by our Audit and Compliance Department, an independent department that reports directly to the Board of Directors. Our Whistleblower Channel is structured to guarantee confidentiality and to protect whistleblower anonymity and the rights of the investigated party.

Our employees and contractors in Brazil and Canada also have access to our Respect Channel*(Canal de Acolhimento)*, which is a channel operated by a specialized and independent team to listen, understand and guide anyone reporting harassment or discrimination. By calling this line, the person may decide whether or not to register an allegation, which is then investigated by our Whistleblower Channel team.

In 2025, our Whistleblower Channel received 10,151 reports and closed 10,079 cases, of which (i) 14% referred to queries and reports that were not investigated due to lack of information or pertinence to the scope of the Whistleblower Channel, (ii) 29% were complaints, which were answered by the Whistleblower Channel, but did not lead to an investigation, and (iii) 57% were allegations that led to investigations, which confirmed violations of Vale’s Code of Conduct in 54% of these cases.

All confirmed violations triggered correction plans, which are presented by managers and approved by the Whistleblower Channel. As a general rule, these plans contain measures to promote process improvements, training initiatives and feedback to employees. Depending on the seriousness of the allegations, employees involved may be subject to administrative measures, such as warnings, suspensions or terminations. Suppliers involved in serious violations of the Code of Conduct are also subject to punitive measures, such as fines or contract termination.

Investigations by our Whistleblower Channel in 2025 resulted in 3,968 corrective actions and disciplinary measures, including 257 terminations of employment.

Further information on the Whistleblower Channel is disclosed in our Ethics & Compliance annual report, available on our website, athttps://www.vale.com/esg/ethics-and-compliance. Information on our website is not incorporated by reference in this annual report on Form 20-F.

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