AXIA Energia S.A.

We have a Code of Conduct, the main document guiding the ethical, honest and transparent conduct at our company, applicable to our employees. The guidelines of the Code of Conduct are also intended for all stakeholders who have some form of relationship with or represent us. Accordingly, our suppliers, service providers and other partners will have specific clauses in their contracts, partnerships, agreements, terms or agreements, including shareholders’ agreements, depending on the business carried out, in which they undertake to observe, where applicable, the Code of Conduct and our Compliance Program.

Reading and assimilating the Code of Conduct is the duty of everyone involved in the activities of our companies. Each new version of the Code of Conduct is available to each member of our workforce, and a signature of a term of acceptance is required. We also require our third-party suppliers and service providers to adhere, to the extent applicable to our Code of Conduct in our agreements with them.

The current version of our Code of Conduct was approved through a Board of Directors Resolution No. 299 dated June 4, 2024. Developed by an internal multidisciplinary team to position us to face the new challenges which lie ahead, the Code of Conduct reiterates our commitment to compliance with (i) local legislation in the countries where we operate, (ii) Brazilian constitutional principles and (iii) international treaties to which Brazil is a signatory, by adopting guidelines that meet the regulations related to ethics and integrity.

We adhere to the following organizational values: life first, our energy comes from people, integrity always, innovate to generate value, our excellence makes a difference, with the following ethical principles: human dignity and respect for people, professionalism, compliance, integrity, transparency and sustainability.

The Code of Conduct expresses our identity as a company and sets out the ethical principles and commitments in alignment with our four key pillars: People, Planet, Governance and Prosperity:

People

●Combating discrimination;

●Reinforcing a robust health and safety culture;

●Promoting greater accessibility within the workplace;

●Investing in the development and recognition of our employees; and

●Protecting our reputation and the reputation of our employees.

Planet

●Promoting environmental education and awareness among our employees and stakeholders;

●Reducing our impact on the environment and its communities; and

●Promoting actions aimed at conserving ecosystems.

Governance

●Adopting a zero-tolerance policy and best practices to prevent fraud and corruption;

●Ensuring the protection of information in respect of personal and company data; and

●Preventing conflicts of interest.

Prosperity

Our Code of Conduct is available on our website (https://eletrobras.com/pt/Paginas/Codigo-de-Etica.aspx), attached hereto as Exhibit 11.1, and periodically posted on social networks, in accordance with our Communication Plan. Information on the Code of Conduct is reinforced to suppliers in training sessions held in partnership with the contracting area, and e-mails are also sent to them and to our business partners. Our Code of Conduct or other contents from our website are not incorporated by reference into this Annual Report.

Following the internalization of an ethical culture, in addition to annual training that addresses the themes contained in the Code, and awareness-raising actions through the dissemination of booklets and educational videos, we held the annual event“Compliance Week.” In 2024, the event addressed all dimensions of behavioral risk related to conflicts of interest, receiving/offering business courtesies, bribery and interactions with public officials, fraud and embezzlement, and leakage of confidential information, as well as its impact on our processes and results, was attended by almost 3,500 employees all over the states where we operate. Since 2020, the event has been held jointly by our companies, in an online format.

Through the Whistleblowing Platform, launched in 2017, anyone can report violations or suspected violations of the Code of Conduct of our companies, the Corporate Compliance Program and anti-corruption laws through a centralized unified channel for our companies operated by an external, independent and specialized third party. The anonymity and confidentiality of the complaints are ensured, as well as non-retaliation to the whistleblower as stated in the Code of Conduct.

In July 2021, the external and independent Whistleblowing Channel of our companies started to be operated by Deloitte Touche Tohmatsu.

Over the last three years, 1,047 complaints were received on our Whistleblowing Platform (294 in 2022, 345 in 2023 and 408 in 2024. In 2024, 331 of the 408 complaints received were concluded as of December 31, 2024.

In the pursuit of continuous development, we have been implementing improvements in the macro process, as well as we have in place the further policies: Compliance Program, Corporate _Courtesies; Culture Integrity; Management of the Complaints Channel and Handling of Manifestations; Due Diligence and Monitoring of Administrators, Leaders and Professionals, Due Diligence and Monitoring of Third Parties; Interactions with Public Officials; Monitoring and Updating the Compliance Program, the Social Responsibility Policy (Política de Responsabilidade Social), The Human Rights Policy (Política de Direitos Humanos)the Communication and Engagement Policy (Política de Comunicação e Engajamento), Sponsorship Policy (Política de Patrocínios), Suly Logistics Policy (Política de Logística de Suprimentos), Environmental Policy (Política Ambiental),P&D Policy (Política de P&D) and the SPE Manual (Manual de SPE).