AXIA Energia S.A.

We have a Code of Conduct, the main document guiding 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 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 made available to each member of our workforce, and signed 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 Board of Directors Resolution No. 299 dated June 4, 2024. Developed by an internal multidisciplinary team to position us to face new challenges, 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 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, and our excellence makes a difference. These are supported by 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

•Adopting best practices to ensure the protection of workers in our supply chain, including a strengthened commitment to the United Nations Guiding Principles on Business and Human Rights;

•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;

•Taking a proactive role in environmental conservation (protecting biodiversity and historical and natural heritage) and sustainable development;

•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

•Investing in value creation, with a commitment to generating value in our operations, focusing on operational and economic efficiency and the creation of social value;

•Innovating in the energy sector, establishing a commitment to innovation and the transformation of business models to create shared value, including investments in sustainable infrastructure, energy and technology, through scientific research, development, and innovation and digital transformation.

Our Code of Conduct is available on our website (https://www.axia.com.br/en/esg/compliance-program), 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 emails 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 2025, we gathered Compliance, Risk, and Information Security areas, with hybrid lectures and innovative activities such as the Compliance Challenge: Overcoming Risks – a game featuring compliance riddles and puzzles to be solved within a set time. The event was attended by almost 3,160 employees across 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 operated by an external, independent and specialized third party. The anonymity and confidentiality of complaints are ensured, as well as non-retaliation against the whistleblower as stated in the Code of Conduct.

Over the last three years, 1,047 complaints were received through our Whistleblowing Platform (345 in 2023, 408 in 2024 and 780 in 2025). In 2025, 594 of the 780 complaints received were concluded as of December 31, 2025.