TIM S.A.

Code of Ethics

We believe that ethics in conducting business is always important for a company’s success. Accordingly, we adopted a Code of Ethics that applies to our Chief Executive Officer, Chief Financial Officer, Principal Accounting Officer and persons performing similar functions, as well as to our other Directors, Statutory Officers, controlling shareholders, members of our boards and committees, all employees and suppliers. Our Code of Ethics is filed as an exhibit to this annual report. It can also be requested, free of charge, by email or telephone at the address set forth in the second paragraph of “Item 4. Information on the Company—A. History and Development of the Company—Basic Information” The Code of Ethics was updated at the Board of Directors’ meeting held on December 6, 2023.

Our Code of Ethics addresses most of the principles set forth by the Brazilian Anti-Corruption Law No. 12,846/2013, by the Brazilian Federal Decree No. 11,129/2022, by the Foreign Corrupt Practices Act (FCPA), by the SEC in Section 406 of Sarbanes-Oxley Act, and, pursuant to section 156 of Brazilian Corporate Law No. 6,404/1976, establishes that an officer or a board member is prohibited from taking part in any corporate transaction in which he has an interest that conflicts with the interests of the Company, and is required to disclose to the board the conflict of interest. Any contract can only be entered into under reasonable and fair conditions. Contracts with a related party must be entered into on an arm’s-length basis.

The Code of Ethics also requires all adherents to immediately report any situation that is illegal and/or that may have a negative impact on the Company’s interests including any violation or incentive for violations of (a) laws or regulations, (b) the provisions of the Code of Ethics or (c) other internal regulation or occasional irregularities or negligence in the maintenance, information and management of accounting reports. The Code of Ethics also requires the maintenance of the related documentation and compliance with obligations related to accounting or internal management reports.

Anti-Corruption Policy

In order to ensure compliance with existing applicable Brazilian and international anti-corruption laws and minimize the risks associated with the same, we have adopted an Anti-Corruption Policy (Política Anticorrupção).

Our Anti-Corruption Policy was approved by our Board of Directors on February 27, 2023, and focuses on internal mitigating controls to be followed to avoid vulnerability to corrupt practices, including our relationship with public officials. In conjunction with the adoption of this Anti-Corruption Policy, we also provide anti-corruption training courses to our managers, directors and employees.

In December 2019, TIM Participações, which was subsequently merged into us in September 2020, was included on thePró-Ética Company List for the 2018-2019 period by the Brazilian Federal Ministry of Transparency and the Comptroller General of the Federal Government, which promotes ethical business conduct throughout Brazil, granting the inclusion on thePró-Ética List to companies that demonstrate lawful business practices and operate with the highest level of fairness, transparency and integrity. We were the first Brazilian telecom company nominatedPró-Ética. In November 2023, we were included for the third consecutive time on thePró-Ética Company List, now for the 2022-2023 period.

In this perspective, our Integrity Program aims to identify processes and controls to mitigate corrupt practices in order to generally promote honest and ethical conduct and deter wrongdoing within the Company. We believe that the provisions of the Integrity Program is aligned with the Brazilian Anti-Corruption Law and international standards on anti-corruption, such as the Foreign Corrupt Practices Act, the Legislative Decree No. 231/01 of Italy and the ISO 37001: Anti-bribery management systems.