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ITEM 16B. CODE OF ETHICS

The Company maintains a comprehensive code of ethics applicable to all directors, officers, employees and third parties. The code addresses ethical conduct, conflicts of interest, compliance with laws, financial reporting integrity, and mechanisms for reporting concerns. Any amendments or waivers for senior financial officers will be disclosed on the Company’s website in accordance with SEC requirements. We have posted the full text of our code of ethics on the investor relations section of our website, www.patria.com. Our code of ethics is reviewed periodically by the Board of Directors and there have been no material changes made.

We intend to disclose future material amendments to our code of ethics, or any waivers of such code, on our website or in public filings. Our code of ethics is included as Exhibit 11.1 to this annual report. The information on our website is not incorporated by reference into this Annual Report on Form 20-F, and you should not consider information contained on our website to be a part of this Annual Report on Form 20-F.

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