TELEFONICA BRASIL SA

Although adoption of a code of ethics is not required by Brazilian Corporate Law, we implemented a code of business conduct and ethics called the Telefónica Responsible Business Principles (Princípios de Negócio Responsável), which regulates the conduct of our employees in general (including senior financial officers and executive officers) to comply with the requirements of the Sarbanes-Oxley Act and NYSE rules.

The Telefónica Responsible Business Principles are reviewed periodically and approved by the board. Its global guidelines define the way we do business with all stakeholders and generate long term value. In addition, the Telefónica Responsible Business Principles set forth mechanisms for decision making when facing ethical dilemmas and situations that eventually can be considered not in accordance with the law. We promote periodical training to our employees aiming to reinforce our code of ethics concepts and principles reaching 98.2% of our personnel.

The Compliance Department’s mission is to be a role model in ensuring the applicability of anti-corruption compliance law and corporate ethics, generating value to stakeholders, protecting the company and its employees, reducing risks of non-compliance and bolstering our culture, which is based on ethics and integrity. The Compliance Department works together with other areas of the company to maintain our business best practices and provides updates on our compliance program to the Audit Committee.

At Telefônica Brasil, the compliance program, named as #VivoDeAcordo, has important pillars to its solid implementation: total commitment from top management; a robust structure of highly qualified and skilled employees responsible for the program’s actions; regular analysis and evaluation of business risks; internal policies addressing diverse subjects, such as prevention of corruption, conflict of interests, gifts and entertainment, information security, among others, in line with global guidelines and internal regulations well-structured and available to all employees; periodic compliance training for current and new employees and an active channel to answer questions about the entire program.

The program applies to all employees (including directors and executive officers) and also to allies. To enhance integrity culture, initiatives of prevention, detection, remediation and integrity are constantly released, such as: regular communication on ethics topics; anticorruption training; promotion of compliance channel “Fale com #VivoDeAcordo” and our policies, which are available in our intranet policy portal.

As a result of the company's commitment to maintaining an excellent Compliance Program, since 2020 Telefônica Brasil obtained the DSC 10,000 certificate (Guidelines for the Compliance System), with an expiration date of 14/12/2024, which demonstrates the excellence of its Compliance Program (#VivoDeAcordo) in accordance with the requirements of DSC 10,000/2015 and Brazilian legislation on integrity (anti-corruption).

In addition, in 2023 Telefônica Brasil was recognized as a Pro-Ethics company 2022-2023, an initiative from Controladoria Geral da União - CGU aimed to companies that are committed to the voluntary adoption of integrity measures intended for preventing, detecting and remediating acts of corruption and fraud.

Obtaining these important certification and recognition reinforces that Telefônica's Brasil Compliance Program has evolved in recent years through its internal mechanisms for preventing and combating corruption, evidenced by the perception of ethics and integrity that employees, customers and partners have in relation to Telefônica Brasil.

The company is aware of the importance of its supply chain for its international presence, the impact and involved values in its business transactions volume. For this reason, our company promotes, establishes and maintains high level of responsible behavior with respect of its suppliers, promoting among them not only compliance quality/service standards, but also ethical, social, environmental and privacy standards in any relationship with our supply chain.

Stimulating sustainability throughout the supply chain is an important challenge for the telecommunications sector. At the Company, this business relationship, guided by ethics and transparency, is based on the guidelines of the Sustainability Policy for the Supply Chain, implemented since 2016 and revised in 2019. The document establishes the Principles and Minimum Criteria for Responsible Business that suppliers must follow.

As one of the pillars of our code of ethics (Princípios de Negócio Responsável), the respect and commitment to human rights guide the regular and periodic evaluation of the impacts in our value chain. Since 2010, we have been signatories to the Global Compact, a UN initiative to encourage companies to follow corporate social responsibility and sustainability policies through the adoption of ten principles related to human rights, labor, environment and corruption.

Corporate social responsibility has always been present in our agenda, and, in 2020, we adopted the ISO 26000 (Guidance on Social Responsibility) management model. Through the ISO 26000 guidelines, we improve our organizational culture, minimizing the risks of our business, and ensuring an increasingly sustainable performance through ethical and transparent behavior.

The Telefónica Responsible Business Principles are available and open to consultation for employees on the Telefónica Intranet site as well as for the general public on the Telefónica external website (https://www.telefonica.com/en/sustainability-innovation/how-we-work/business-principles/). These Responsible Business Principles were modified in 2022 in order to include and/or update our commitments. Currently, the principles mainly involve: ethical and responsible management, corporate governance, human rights and digital rights, commitment to the environment, innovation and responsible use of technology, responsible communication, commitment to the customer, employees and societies in which we operate and responsible supply chain management. No waivers were granted in 2023.