TELEFONICA BRASIL SA

Responsible Business Principles

We have implemented a code of business conduct and ethics called the Telefónica Responsible Business Principles. These principles guide the conduct of all company employees, including members of the Board of Directors. These 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 2024. A copy of the Telefônica Responsible Business Principles is available at https://www.telefonica.com.br/a-telefonica/vivosustentavel/principios-de-negocio-responsavel.

The 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 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 98.28% of our personnel.

The mission of the Compliance and DPO Department is to ensure the applicability of laws, anti-corruption compliance, and corporate ethics, thereby generating value for stakeholders, protecting the company and its employees, reducing risks of noncompliance, and strengthening our culture of integrity. The Compliance and DPO Department collaborates with other areas of the company to uphold best ethical business practices and provides updates on the compliance program to the Board of Directors through the Audit and Control Committee.

At Telefônica Brasil, the compliance program, called #VivoDeAcordo, applies to all employees of the company, including members of the Board of Directors, representatives and service providers of the Company and has important pillars for its solid implementation: i. full commitment of senior management; ii. regular analysis and assessment of business risks; iii. code of ethics and conduct; iv. internal policies and standards addressing various subjects (available on our intranet policy portal), such as prevention of corruption, conflicts of interest, gifts and hospitality; v. periodic training and communications on ethical and anti-corruption issues to all employees; vi. communication channels to clarify doubts about the entire program; vii. integrity due diligence; viii. monitoring and auditing; and ix. reporting channel.

As part of its commitment to maintaining a robust Compliance Program, the Company has received the DSC 10,000 certification annually since 2020, which is currently valid until December 12, 2025. In 2024, the Company was also recognized at the first edition of the Leaders League Compliance Summit & Awards Brazil for having the best Compliance Department in Telecom and Technology. Additionally, in 2023, it was recognized as a Pro-Ethics company, an initiative by the Comptroller General of the Union (CGU) and the Ethos Institute, which highlights companies voluntarily adopting integrity measures to prevent, detect, and remediate acts of corruption and fraud.

These certifications and recognitions underscore that Telefônica Brasil’s Compliance Program has significantly evolved in recent years. The program’s robust mechanisms for preventing and combating corruption have enhanced the perception of ethics and integrity among employees, customers, and partners, solidifying Telefônica Brasil’s reputation as a company committed to ethical practices.

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, the 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 2024. This policy, approved by the board, establishes the Principles and Minimum Criteria for Responsible Business that suppliers must follow.

As one of the pillars of our code of ethics, 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.

Code of Ethics and Conduct Policy - Rules of Conduct for the Financial Executives

In addition to our Responsible Business Principles, we have adopted a code of ethics and conduct policy applicable to the chairperson, chief executive officer and vice presidents of the Company and its subsidiaries, and to any executives of the Company or its subsidiaries that work in the areas of finance, capital markets, treasury, financing, investor relations, accounting and accounting consolidation. A copy of such policy is included as Exhibit 11.1 to this annual report. Since its effective date, we have not waived compliance with our code of ethics and conduct policy.