Inter & Co, Inc.

Our Code of Conduct is applicable to its board of directors, officers, employees, shareholders, suppliers, business partners, service providers and contractors, covering covers a broad range of matters, including the handling of conflicts of interest, donations and sponsorship, privacy and data protection, prevention of money laundering, prevention of fraud, bribery and corruption, the offering and receiving of gifts and gratuities, interaction with public officials and other corporate guidelines, such as insider trading, 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, and annually upon its revision. With the purpose of having all of our employees being familiar with our Code, we provide a web training, related to the topics covered by the Code, to 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 2024 we launched a customized training applicable to all board of directors members covering the most relevant topics of our Code of Conduct.

During the Code of Conduct review process in 2024, a series of improvements were implemented, as listed below:

Additional leadership responsibility

Inclusion of a topic directed at managers and leaders, guiding them to assume responsibility for being an example to their teams; committing to the values and principles of the Code; and committing to promoting a respectful, safe, and harmonious work environment.

Diversity and non-discrimination

We reinforce the importance of diversity in our culture and our commitment to preventing discrimination.

Zero tolerance for fraud

We explicitly included a zero tolerance policy for fraud or dishonesty.

Ethics Channel

Guidance on the correct use of the Channel by whistleblowers; Inclusion of an illustrative list of situations within the scope of the Channel; Extension of non-retaliation guarantees to Compliance members and the Ethics Subcommittee.

Artificial Intelligence (AI)

Inclusion of a topic with guidelines on the responsible use of Artificial Intelligence at Inter, addressing the principles that should be observed.

Principles of conduct for Third Parties

Inclusion of a specific topic for Third Parties, aligned with internal guidelines and in compliance with labor law guidance.

In addition to our Code of Conduct, we also maintain a whistleblower channel. 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 as 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 Sub-committee. Whenever necessary, according to the particularities of each case, Compliance can involve the Ethics Sub-committee to assess the matter and recommend whether penalties or other disciplinary actions should be applied.

In 2024, we have not received tips regarding corruption on our whistleblower channel.

Inter’s Compliance Program was developed based on 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”, includes: knowledge dissemination trough communication of Compliance related topics, training of the personnel involved in the company, 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 and testing and ethics channel, actively searching for possible inadequacies. Finally, we have the “respond” pillar, where through reports, non-compliance management and internal investigations we can address 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.