Inter Co Inc

We have adopted a Code of Conduct and Ethics applicable to its board of directors, officers, employees, shareholders, suppliers, business partners and service providers, which covers a broad range of matters, including the handling of conflicts of interest, donations and sponsorship, privacy and information security, prevention of money laundering, prevention of fraud, bribery and corruption, gifts and gratuities and other corporate guidelines, such as insider trading and equal opportunity and non-discrimination standards. All our employees and officers have to read and accept the terms of our Code when they start their employment or are elected, as applicable. We also inform each of our employees of any changes to our Code of Conduct and Ethics. With the purpose of having all of our employees be familiar with our Code, we provide training sessions, related to the topics covered by the Code, for our employees every 12 months and have them take a test which requires them to get 70% of the questions correct in order to pass.

In 2023, we have not granted any waiver, including implicit waiver, from a provision of our Code of Conduct and Ethics to any of our directors or executive officers.

Our whistleblower channel is open both to the general public and our employees and is operated by a third-party service provider. We use an independent provider because we value the anonymity of whistleblowers and we do not tolerate any discrimination or retaliation against them.

All of the reports received through our whistleblower channel are reviewed and investigated by our compliance department. The investigation seeks to ascertain what has happened, while protecting the identity both of the whistleblower and the people involved in any alleged unethical conduct. Once finished, investigation reports are shared with Inter’s Ethics Committee. Whenever necessary, according to the particularities of each case, Compliance can involve the Ethics Committee to assess the matter and recommend whether penalties or other actions should be applied.

In 2023, we have not received tips regarding corruption on our whistleblower channel.

Inter’s Compliance Program was established by means of a set of guidelines and initiatives supported by the pillars of prevention, detection, and response, of any inappropriate or unethical actions, harmful acts, or non-compliance with laws, regulations, and internal rules, which may damage the assets, reputation, and/or image of the company, its investors, clients, and other stakeholders. The first pillar, “prevent”, assists in the training of the personnel involved in the company and in the resolution in advance of possible risks to our Code of Conduct and Ethics by utilizing the compliance risk assessments, Code of Conduct, compliance policies and communication and training systems. Further, the “detect” pillar is guided by three integrated systems of third-party due diligence, monitoring, testing and ethics channel, that actively searches for possible inadequacies. Finally, we have the “respond” pillar, where through reports, non-compliance management and internal investigations we can respond and resolve the problems with efficiency. In each one of those pillars, we have activities, that needs to be fulfilled to achieve the completeness of those principles. To summarize it, we have the following mandala:

The initiatives in each of the program’s pillars are endorsed and supported by senior management and the constant strengthening of the culture of integrity.