Social, Environmental and Climate Responsibility Policy - PRSAC

CORP-POL-401

Publication date: 09/12/2024

Effective date: 09/12/2029

Information Classification:
☒ Public
☐ Internal
☐ Restricted
☐Confidential

OBJECTIVE

This policy aims to comply with Resolution No. 4.327 of the Central Bank of Brazil, dated April 25, 2014, which establishes the guidelines that must be observed in the establishment and implementation of the Social, Environmental, and Climate Responsibility Policy (PRSAC) by financial institutions and other institutions authorized by the Central Bank of Brazil (BACEN). It also aims to demonstrate, establish, and guide processes focused on ESG practices, preventing potential negative impacts and promoting positive impacts on the environment and society, contributing to the achievement of the objectives established in our mission and reinforcing the strategic importance of the topic.creditwe focus on technology as a catalyst for change. The mission of Dock Our mission is to democratize the financial universe, promoting the inclusion of millions of unbanked and underbanked people in Latin America. We want to dematerialize finance to unlock business potential and spread financial power. This direction is the guiding principle of our ESG actions. We are committed to acting responsibly in the environmental, social, and governance spheres, generating value for customers, suppliers, and investors and contributing to society as a whole. Embedded finance is the next frontier in financial services and can be an important enabler of true financial inclusion, especially in disadvantaged regions like Latin America, benefiting the entire ecosystem:

• End consumers
• Companies
• And society in general

COVERAGE

This Policy is applicable and must be complied with by all employees of Dock and its subsidiaries (collectively, “Dock”), as well as third parties and service providers.
NOMES AND CERTIFICATIONS
☒ BACEN
☐ PCI
☐ SOX
☐ ISO 27.001
☐ NONE OF THE RULES

REFERENCE DOCUMENT

Diversity, Inclusion and Equity Policy Code of Ethics

GENERAL PROVISIONS

Employees involved in this process are aware that the guidelines defined in this document may be audited. Therefore, it is recommended not to save copies of these regulations to the desktop/network directories or print them. Employees should always access the tools provided by Dock.

GUIDELINES

We are committed to acting responsibly in all areas (Environmental, Social, and Governance) to ensure the company's sustainability in the face of major global trends and challenges, delivering value to our team, customers, suppliers, investors, and society.

We operate in line with three guidelines:
I. The future we want;
II. Current movements that point to the future;
III. How we are building the future.

The following definitions are contained in our future vision and mission related to sustainability (guideline I):

• Technology as an enabler of socio-environmental transformations;
• Cooperation ecosystem for innovation.

The following definitions are contained in the main themes at present that direct us to what thecreditwe will in the future (guideline II):

• Decarbonization;
• Positive social impact solutions;
• Solutions with positive environmental impact;
• Digital transformation (financial inclusion).

The following definitions are contained in the existing project fronts, in addition to values ​​that direct our actions (guideline III):

• Transparency;
• Multi-stakeholder partnership;
• Investment in social or impact businesses;
• Innovation roadmap focused on minority inclusion;
• Open innovation;
• Social investment;

We're working to ensure our projects align with the UN Sustainable Development Goals (SDGs), given the company's focus on the crucial 2030 Agenda, which guides and defines priorities for sustainable development. Our work focuses on the following:

1. Eradication of poverty
1.4 – By 2030, ensure that all men and women, particularly the poor and vulnerable, have equal rights to economic resources, as well as access to basic services, ownership and control over land and other forms of property, inheritance, natural resources, appropriate new technologies and financial services, including microfinance.

2. Zero hunger and sustainable agriculture
2.3 – By 2030, double the agricultural productivity and incomes of small-scale food producers, particularly women, indigenous peoples, family farmers, pastoralists and fishers, including through secure and equal access to land, other productive resources and inputs, knowledge, financial services, markets and opportunities for value addition and non-agricultural employment.

3. Gender equality
5.a – Carry out reforms to give women equal rights to economic resources, as well as access to ownership and control over land and other forms of property, financial services, inheritance, and natural resources, in accordance with national laws.

5.5 – Ensure the full and effective participation of women and equal opportunities for leadership at all levels of decision-making in political, economic and public life.

4. Decent work and economic growth
8.10 – Strengthen the capacity of national financial institutions to encourage the expansion of access to banking, insurance and financial services for all.

5. Industry, innovation and infrastructure
9.3 – Increase access of small industries and other enterprises, particularly in developing countries, to financial services, including affordable credit and their integration into value chains and markets.

6. Reducing inequalities
10.c – By 2030, reduce migrants’ remittance transaction costs to less than 3% and eliminate remittance corridors with costs above 5%.

A. INTERESTED PARTIES
Our goal is to ensure that all stakeholders feel included in the development of actions and projects, demonstrating transparency and identifying potential socio-environmental risks and opportunities.creditWe rely on technology as the primary driver of our clients' growth and the transformation of the role of financial services, thus driving society forward. This relationship is built on ethics as its core pillar, but also supported by a culture where we consider:

• Safe and inclusive environment, with affirmative actions so that candidates and employees feel safe expressing their identity and diversity.
• Diversity as an essence, in building an environment with equity, inclusion, exchange and learning, enhancing the exchange of ideas.
• Contribution to the education and information of employees and other stakeholders, aiming to break down biases, barriers and prejudices, to transform behaviors.
• The evolution of the supply chain, with the alignment of requirements for ESG-related topics, reducing reputational risks and raising the level of practices related to the topic.
• Continuous contribution aligned with the company's values ​​to public interest initiatives through projects, investments, accelerations, and donations.
• Guidance for changing employee behavior regarding emissions arising from our operations, seeking alignment and adoption of necessary measures for the continuous reduction of greenhouse gases.
• Continuous internal training, seeking to enhance and broadly disseminate the culture, in addition to the possibility of sharing knowledge.

B. TRAINING
The company seeks to train and broadly inform its employees and other stakeholders regarding ESG issues through:

• Communications on the topic on its communication channels, disseminating knowledge and enabling debate and the exchange of experiences.
• Dissemination of actions and strategies related to the topic with stakeholders, seeking awareness and transparency in the actions developed.

C. LEGISLATION AND COMMITMENTS
A Dock seeks compliance with Brazilian legislation applicable to its business and alignment with commitments, agreements, and actions that correlate with its values. With this in mind, it carries out actions such as:

• Constant updating regarding legislation and other regulations in the socio-environmental area.
• Practice of the guidelines indicated in its Code of Conduct and Ethics and other guidelines related to compliance, privacy, regulatory and ESG issues.

We emphasize that this policy is in full compliance with Resolution 4.327, approved by the National Monetary Council on April 25, 2014, and should be reviewed and updated whenever necessary, considering new information and alignments related to the topics contained therein.

D. SOCIAL AND ENVIRONMENTAL RISK MANAGEMENT
The company understands and recognizes potential social and environmental risks, and is also aware of other types of risk to which it is exposed. Therefore, it manages social and environmental risk in its activities and operations within three pillars:

a. Environmental

• Waste Management, especially of electronic devices – prioritizing the recycling, reuse, and upcycling processes of the most diverse materials resulting from operations, with the aim of minimizing the negative environmental impacts resulting from the incorrect disposal of waste.
• Continuous improvement of mechanisms and processes for managing potential impacts arising from operations and the work model currently practiced within the company.
• Reduction of greenhouse gas emissions, seeking to achieve the “NET ZERO” objective by 2030, through the improvement of internal processes and the reduction – and postsuperior neutralization – of the use of non-renewable natural resources, which cause negative impacts on the environment and society as a whole.
• Alignment with agreements, commitments, and obtaining certifications that can guide the company toward best market practices regarding this topic.
• Contribution to mitigating and minimizing negative effects resulting from climate change, as well as encouraging awareness of energy and water efficiency and the use of renewable energy in our operations.

b. Social

• Promoting a safe and inclusive environment, with affirmative action, so that candidates and employees feel free to express themselves as they are, in addition to internal research and surveys that provide a snapshot of the company and thus better direct the implementation of diversity and inclusion practices.
• Support and encouragement for businesses that facilitate access to financial inclusion, credit, and financial education, contributing to the reduction of social and economic inequalities.
• Employee training and engagement to incorporate a sustainable culture and socially and environmentally responsible practices, both within and outside the corporate environment.
• Provision of an ombudsman and ethics channel for the protection of customers and employees, respectively, thus guaranteeing the principle of defending their rights, impartially and totalmente independent.

c. Governance

• Monitoring of ESG performance indicators, with disclosure to the parties involved.
• Encouragement and support for the purchasing department to adapt the supplier registration and approval process, considering ESG guidelines, thus ensuring that all suppliers are aligned with best practices.
• Preparation and review of this and other policies, with the aim of raising awareness in other areas so that, in the preparation process, they consider and implement sustainable measures and criteria.

RESPONSIBILITIES

In order to disseminate and correctly allocate the resources involved in this policy, considering the main levels of governance, we have the following related attributions:

1. ESG Director

• Ensure the publication of this Policy (to the internal and external public), keeping all documents related to this Policy available to the Central Bank of Brazil (BACEN).
• Define the corporate sustainability strategy, seeking a balance between socio-environmental responsibility and economic development.
• Monitor the ESG strategy, implementation and compliance with the items contained in this Policy.

2. ESG Department

• Develop and implement initiatives outlined in strategic planning, as well as support the development of products and services that include environmental criteria.
• Work on defining and implementing ESG indicators, involving stakeholders in this process.
• Define projects connected to the corporate sustainability strategy, seeking a balance between socio-environmental responsibility and economic development.
• Responsible for preparing the original version and, every 5 (five) years, or when there are relevant changes to be included in the PRSAC, reviewing and maintaining this policy.

3. Legal Department

• Manage legal and administrative processes related to socio-environmental risks that involve its stakeholders.
• Support the inclusion and review of contractual clauses that enable risk mitigation and encourage compliance with socio-environmental obligations, considering social factors.
• Responsible for reviewing this policy every 5 (five) years, or when there are relevant changes to the PRSAC within that period.

4. Human Resources Department

• Develop and implement Diversity and Inclusion initiatives, as well as their indicators, seeking balance between the Company's actions and economic development.
• Support and facilitation of initiatives related to socio-environmental programs, providing resources and knowledge that enable, together with other areas, to expand the culture of socio-environmental responsibility among employees.

5. Department of Internal Controls

• Perform analysis and monitoring of the Company's socio-environmental and/or ESG risks, based on risk management and internal governance guidelines.

6. Compliance Department

• Conduct an analysis of the Company's stakeholders to consider possible socio-environmental and/or ESG risks, based on internal governance guidelines and monitoring of negotiations.
• Receiving and analyzing complaints related to possible infractions or irregularities committed by the company or stakeholders and monitoring negotiations.
• Responsible for, every 5 (five) years, or when there are relevant changes within that period, requesting a review of this policy.

7. Risks

• Responsible for reviewing this policy every 5 (five) years, or when there are relevant changes to the PRSAC within that period.

8. DEFINITIONS

• Activities/Processes: internal practices that aim to have a positive impact on the company's socio-environmental aspects.
• BACEN: Brazilian central bank.
• Organization/Company/Enterprise: Dock and its subsidiaries.
• Interested Parties/Stakeholders: customers, employees, suppliers, investors and society that relate, directly or indirectly, to the company.
• PRSAC: refers to this document – ​​Social, Environmental and Climate Responsibility Policy.
• Collaborators: all individuals who maintain a statutory or employment relationship with the Dock. They are the members of the Board of Directors, statutory or non-statutory Committees and the Statutory and non-Statutory Board of Directors, as well as all full-time and temporary employees, outsourced employees and interns.

9. VIOLATIONS, REPORTING, AND NON-RETALIATION
Violation of the principles and rules established in this Policy subjects offenders to disciplinary action, which may include a warning, suspension, or dismissal in the case of Employees, and termination of the contract in the case of Customers, Suppliers, or Partners. If youcreditand that someone has violated this policy or any other relevant policy, a law or the Code of Ethics of Dock, you should report it in the channel: https://admin.safe.space/. The Dock will keep the report confidential and will take appropriate action, and will not tolerate retaliation for the report. If a member feels they have been retaliated against, they must report it.
immediately, as instructed in the Code of Ethics.

10. REVISION CONTROL

This regulation comes into force upon publication and must be reviewed whenever supervening events alter the provisions.postin this document or up to 30 days before the end of its validity.

BACEN/PCI/SOX: Annual review, except PRSAC review every 5 years.
ISO and other regulations: Review every 2 (two) years.
Responsible Board: Communication and ESG.
Responsible Area: ESG.