Inter & Co, Inc.

Our Code of Conduct and Ethics is applicable to its board of directors, officers, employees, shareholders, suppliers, business partners, service providers and contractors, covering 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 hospitalities, interaction with public officials and other corporate guidelines, such as insider trading, equal opportunity and non-discrimination standards. Our Code of Conduct and Ethics is regularly reviewed and updated to ensure continuous improvement and alignment with best market practices. 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 addition to our Code of Conduct, we 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 secrecy and confidentiality of the whistleblower and the content of the report, Whistleblowers in good faith will not be subject to any form of retaliation and people reported will be treated with respect and discretion.

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 2025, 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 policies, 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 are constant strengthening of the culture of integrity.