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v1.0 2020

Code of ethics

Code of ethics

v1.0 2020

Code of ethics

INDEX

01 | Message from the Impact Bank team

02 | Mission, vision and values

03 | Target Audience

04 | Ethical Principles

05 | Principles of Regenerative Development

06 | Respect for the Individual

07 | Good Relationship Practices

08 | Conflict of interests

09 | Illustrative example

10 | Ethical Decision

11 | Responsible Use of Digital Media

12 | Impact Bank Assets and Resources

13 | Reports

14 | Additional Provisions

01 | Message from the Impact Bank team

Created from the fusion of external references and the internal perspectives of our team, the Impact Bank Code of Ethics is an organic document, which must be updated periodically through collaborative and inclusive processes, so that together we can advance on this learning journey.

Its greatest mission is to be a conscious guide that guides our daily conduct, based on honesty, ethics, transparency, respect for others, the planet, life, legislation and internal standards.

An important, aligned document that strengthens our purpose of collaborating together to give a new meaning to profit by adding social and environmental value to the circulation of money to accelerate the necessary transformations for a more just and regenerative future.

Impact Bank is committed to regenerative principles and practices, a development model that evolves beyond sustainability - it seeks to reverse environmental and social degradation.

Therefore, a responsible stance for our choices and conduct, aware of the impact of our actions on the planet, the organization and its community, will be decisive for the successful applicability of this Code of Ethics.

It is important to emphasize that each person's effort must go beyond self-responsibility and extend their actions to a non-missing stance, in the face of other conduct that does not meet the ethical principles of this code.

We invite you to dedicate a few minutes to reading this document, so that it provides you with input for reflection and guidance on conduct. Being recognized as an integral, trustworthy, honest and transparent institution depends on unrestricted compliance with this Code of Ethics.

This document also reflects our belief that it is necessary to take advantage of Brazil's current moment so that our society can reinvent itself and be more ethical, fair and regenerative.

Gabriel Ribenboim and Impact Bank team

02 | Mission, vision and values

MISSION

Together, we collaborate to give a new meaning to profit by adding social and environmental value to the circulation of money to accelerate necessary transformations for a more just and regenerative future.

VISION

To be a financial platform that leaves no one behind and that promotes innovation in financial services and ethical and fair business models that contribute to social and environmental regeneration.

VALUES

Ethics and Justice; Honesty and Transparency; Respect and Reciprocity; Collaboration and Inclusion; Harmony and Balance, Based on Nature and the Human Being; Regenerative Impact first.

PRINCIPLES OF THE CODE OF ETHICS

RESPECT

INTEGRITY

HONESTY

TRANSPARENCY

RESPONSIBILITY

HARMONY AND RECIPROCITY

03 | Target Audience

The Impact Bank community

TRANSFORMATION AGENTS

Impact Bank customers, partner third sector organizations and their direct beneficiaries

COLLABORATORS

Interns, apprentices, managers and employees of contracted companies. EMPLOYEES People with labor relations with Impact Bank.

HIGH ADMNISTRATION

President and directors, including of controlled companies.

04 | Ethical Principles

Impact Bank, in turn, undertakes to disseminate the Code of Ethics among all its employees, to ensure that its actions are governed by the principles and commitments contained in this Code of Ethics. Ethical principles are an essential part of our responsibilities and dictate the direction we must take, especially when we experience ethical dilemmas and need to make decisions.

RESPECT

The relationship with the Impact Bank community must always be based on respect, dignity and indiscriminateness of people. We respect and value the ancestral knowledge of past generations and respect the limits of present generations without compromising the ability of future generations to meet their own needs. Impact Bank refuses and repudiates any degrading attitude against the planet and its biodiversity and any hostile or humiliating attitude against people, and does not tolerate disrespect for dignity, equality, diversity, people's privacy and life. The work environment and relationships must be guided by professionalism, respecting different cultures, beliefs and positions.

HONESTY

We expect the conduct of members of the Impact Bank community to be consistent with honesty. We must do and communicate only what is right, we must act in good faith, with integrity and sincerity in matters that affect the duties and interests of the community.

TRANSPARENCY

Impact Bank ensures transparency in its relationships, actions and business. Secrecy and confidentiality of information are required in our routine. The trust of our partners is linked to the access that Impact Bank gives to information, accountability and decision-making. However, actions carried out deliberately in secret are not ethical and accepted.

RESPONSIBILITY

Each member of the Impact Bank community is responsible for their actions and decisions. We must be responsible for creating a transparent, respectful and safe environment, so that relationships and business are ethical and regenerative. It is also our responsibility to know, ensure and comply with established internal policies and procedures.

HARMONY AND RECIPROCITY

Harmony is understood as the combination of elements linked by a relationship of pertinence, which produces a pleasant sensation of pleasure. The concept reflects a culture of peace between the Impact Bank community, our products and services, and the balance between business, people and planet. If a relationship, of any nature, or the perception of any product or service does not sound harmonious, it is a sign to stop, communicate, reflect and co-create solutions, based on listening and collective and inclusive construction. of us, members of the Impact Bank community, contribute to the harmony of the community and the movement in which we choose to be part of, just as the community and the movement as a whole directly contribute to our harmony and prosperity as individuals.

05 | Principles of Regenerative Development

1. Right relationship

Understands that the ecosphere is made up of nested systems, living and non-living. It recognizes that the human economy is embedded in culture and the ecosphere and must operate in a dynamic and cooperative relationship with them, respecting cultural needs and planetary limits. It allows critical value-added exchanges to occur at all scales in the reciprocal relationship, in contrast to commoditized transactions.

How we position ourselves

There is a growing movement of companies that see their role as more than simply maximizing shareholder value. One example is B Corporations, which prioritize environmental and social goals as much as fiscal ones, and understand that they can leave the world a better place than it was when they started - and do so profitably. Impact Bank has already started the certification process as a B Corporation, following in the footsteps of Welight Tecnologia Social, from which we emerged. We operate with a focus on our social and environmental duty in defining policies, standards and procedures to prevent and combat corruption, as well as money laundering and terrorist financing. We reject any form of degrading work. It is part of our institutional culture to develop and support regenerative development initiatives and we value links established with the communities in which we operate and respect their cultural values ​​and knowledge and give back to the community part of the value added to the business.

What can we do as individuals

Notice instances of cooperation around you all the time—in nature, in the business world, and in human culture more broadly. Embody this principle by reflecting on opportunities for cooperation and healthy interactions and taking advantage of them when possible. For example, companies can expand their relationships with local companies and suppliers. As an individual, seek collaboration and advice from neighbors in your projects, such as gardening, creative work, or business ventures. Support organizations, movements and leaders that focus on having a correct relationship with nature and society.

2. See wealth holistically

True wealth is not just money in the bank. It is based on the assumption that wealth is the well-being of the whole, which must be achieved through the harmonization of multiple types of wealth or capital, including social, cultural, living and experiential. It recognizes that numerous dimensions of human and natural capital cannot be measured in monetary terms, but must be nurtured as intrinsic components of holistic wealth. Thus, wealth must be defined by broadly shared prosperity across all the varied forms of capital.

How we position ourselves

Companies that embody regenerative principles know that wealth is more than just financial. Impact Bank values ​​its human capital, in the form of happy, well-cared for employees; values ​​and stimulates their cultural capital by offering a space for positive, diverse and empowering interactions to occur; and values ​​natural capital, creating value chains that improve the health of the planet we share.

What can we do as individuals

Take stock of the various forms of wealth you have, in addition to financial wealth.

Maybe it's a satisfying social network, access to parks and natural spaces, the ability to pursue curiosity and develop intellectually, or spiritual fulfillment. Support community organizations that emphasize multiple forms of capital and seek to build the various types of wealth that can provide deeper fulfillment than money.

3. Innovative, adaptable, responsive

In a world where change is always present, the qualities of innovation and adaptability are essential for the health of the whole. In a comparison with Charles Darwin's theory, the most suitable is the one that fits best, the one that is most adaptable to a changing environment.

How we position ourselves

The application here is clear: humans have a knack for solving problems in creative ways. The companies that do well are the ones that survive. Creative business models are often the best at solving difficult problems in a way that also benefits local communities and the planet.

What can we do as individuals

Everyone has creative abilities, even if they have not been intentionally exercised recently. Challenge your habitual ways of thinking about social problems - be willing to let go of ideas about what should work and what has already been done. Consider solutions or ideas that seem irrational or impossible, as once more options are on the table, innovative solutions may emerge.

4. Empowered participation

All healthy living systems are self-organizing and operate through continuous negotiation with each other and in constant interaction. Likewise, a healthy human economy requires the empowered participation of individuals and groups, negotiating in their own enlightened self-interest as they naturally promote the health of the whole.

How we position ourselves

We adopt a decentralized leadership model as a way to ensure everyone has a voice, ensure adherence to Impact Bank community goals, strengthen professional relationships, and create a healthy and empowering collective.

What can we do as individuals

Recognizing that the best scenarios are those in which everyone benefits, look for ways to strengthen these interactions in the world. Support solutions and policies that are good for people and the planet. Many policies that are good for the planet are also good for people and the economy, and our elected officials need to know that we support them. In business, try to bring as many interested parties into the conversation as possible, rather than restricting decision-making to smaller, closed groups.

5. Honor communities and places

Each human community consists of a mosaic of peoples, traditions, beliefs, and institutions uniquely shaped by long-term pressures of geography, human history, culture, the local environment, and changing human needs. Honoring this fact, a regenerative economy nurtures healthy, resilient communities and regions, each uniquely informed by the essence of their individual history and place.

How we position ourselves

In a world seemingly dominated by large companies, small companies may have important collaborative advantages that should be strengthened. Traditional and indigenous communities in Brazil and local populations have a vast collection of specific knowledge about their territory, culture, economy, wildlife, biodiversity, climate and soil conditions specific to their area. Those with this knowledge can often be more successful than larger companies trying to apply off-the-shelf solutions. Likewise, in partnership with organizations and groups operating in different territories, we seek to catalyze local energy and knowledge to adapt solutions that would not be possible without special place-based knowledge.

What can we do as individuals

Think about how your location is unique and worth celebrating. Take pride in your place by being a patron and promote, encourage and participate in activities that regenerate your region and its people.

6. Plenty of Edge Effect

Creativity and abundance flourish synergistically at the “edges” of systems, where the ties that hold the dominant pattern in place are weakest. For example, there is an abundance of interdependent life in salt marshes where a river meets the ocean. At these edges, opportunities for innovation and cross-fertilization are greater. Working collaboratively across borders - with continuous learning and development coming from the diversity that exists there - is transformative for both the communities where exchanges are happening and the individuals involved.

How we position ourselves

Companies with greater diversity are more innovative, generate more profits and have happier employees. Diverse perspectives help groups make decisions, lead to greater creativity and promote respectful environments. This business “edge effect” is a characteristic of more regenerative economic systems.

What can we do as individuals

Notice the ways in which diversity in its many forms—in your social network, the cultures you've experienced, the ideas you consider, the foods you try—can enrich your life. In your workplace, see if there are ways to present unconventional perspectives or bring in people who have them. While specialists have some strengths, generalists who are well-versed in a variety of topics can often have creative insights or valuable ideas. Look for connections between disparate areas of your knowledge.

7. Robust circular flow

A regenerative economy mimics the metabolic process found in resilient living systems, harnessing what we now discard as “waste” into a continuous, productive, circulatory, and valorizing flow. Likewise, the regenerative model promotes the circular flow of appreciation of money, information, efficient use and reuse of materials and are particularly important for individuals, companies and economies to achieve the expected regenerative potential.

How we position ourselves

As it is a movement primarily guided by digital, our parallel is made with the circulation of money. We design solutions based on guiding questions such as "How to mobilize capital to finance transformations for a more just and regenerative future?", "How can we maximize the positive impact of the circulation of money?" and "What are the most efficient strategies and vehicles to finance initiatives with social and environmental impact?". Nevertheless, we seek to incorporate the circular economy of energy and materials as much as possible, reducing, reusing, recovering and recycling. One example is the next version of our Impact Bank Card, which we are working with suppliers to offer a recycled plastic card taken from the oceans.

What can we do as individuals

Find ways to reduce or reuse “waste” in your own life. Reflect, everyone benefits from the absence of waste - and so does the planet! Discover the YAM content platform - the voice of the heart, as another way to get closer to a sustainable lifestyle.

Food: reduce your consumption of animal protein, plan your purchases and try to buy from small local producers, plant at home, eliminate the concept of waste by reusing leftovers, and have a compost bin at home for what cannot be used as food. There are several tutorials on the internet for you to create your own compost bin at home and contribute to this cycle. To find out much more, see here a YAM guide with 10 steps to avoid food waste.

Plastics: eliminate those that are not necessary, reuse and recycle, keeping them in the economy and out of the environment. Find out more in the Reciclando de Verdade guide, on the YAM platform.

Fashion: try to ensure that clothes and accessories are used more often, can be transformed into new pieces and are made from safe and renewable materials.

Finance: seek to support companies in their transition to circular business models and support movements, NGOs and leaders that develop circular economy solutions.

8. Search for balance

Being in balance is more than just a pleasant way of being. It is, in fact, essential for systemic health. Like an Indian woman paddling her fine canoe in turbulent waters, regenerative systems are always engaged in this delicate dance in search of balance. Achieving this requires them to harmonize multiple variables rather than optimizing a single one. A regenerative economy seeks to balance efficiency and resilience, collaboration and competition, diversity and coherence, and the needs of small, medium and large organizations.

How we position ourselves

Business has often been a force pushing natural and social systems into imbalance - but many are now shifting their priorities to help restore balance. System B Corporations and regenerative business models balance the profit motive with equal emphasis on people and planet. Impact Bank was conceived as a movement that puts first your contribution to ensuring that social, ecological and economic systems operate in a healthy balance.

What can we do as individuals

Balance is a theme that permeates each of the Regenerative Principles. Things simply work better when they are in balance. Consider the things in your own life that seem out of balance and look for ways to restore balance. Support movements, NGOs, companies, policies and politicians that aim to restore balance and help create systems but that provide shared prosperity on a prosperous planet.

06 | Respect for the Individual

Relationships in the workplace and in all interactions within the Impact Bank community must be guided by mutual respect and courtesy, valuing ethics, integrity and transparency. Any type of discrimination, or intimidating attitudes regarding differences in race, origin, color, physical conditions, gender, sexual orientation, religious beliefs or political convictions will not be tolerated.

• We respect the diversity of the people who form the work environment and who maintain relationships with Impact Bank.

• We encourage a culture of respect and repudiate violence.

• We ensure the establishment of a dignified and healthy work environment, basing relationships on respect and cordiality, regardless of the position held in the organization or role within the Impact Bank community.

• We must prevent embarrassment and damage to the image of Impact Bank and the employee himself.

• Moral harassment is understood as all abusive conduct, such as gestures, words and attitudes that are repeated systematically, affecting the dignity or psychological or physical integrity of the worker.

• We repudiate conduct that may constitute harassment of any nature, discrimination or induction thereof; coercion, persecution or embarrassment; disrespect for functional duties; public disqualification, offense or threat.

The definition of harassment is described in art. 216-A of the Penal Code: "Embarrassing someone with the intention of obtaining sexual advantage or favor, taking advantage of the agent's status as hierarchical superior or ancestry inherent to the exercise of employment, position or function".

07 | Good Relationship Practices

Impact Bank's Code of Ethics defines guidelines that must be observed by its community:

MANAGERS

• We expect our managers to be developer leaders, inspiring teams and stimulating engagement, with a view to training successors for current and future challenges.• We determine that managers do what is right, be a reference for appropriate posture and encourage teamwork as practice of collaboration and sharing of knowledge and experiences.• We believe that corporate ethics is mainly related to everyone's behaviors, practices, beliefs and values. Therefore, it seeks to promote a corporate culture, based on solid pillars in which people come first, whether they are employees, suppliers, customers or society in general.• Managers must act with transparency, be open to dialogue and interact with their employees. employees in order to share actions and objectives that lead to the common good, always in an ethical manner.• Cultivate environments that encourage the performance of high quality work, relevant to those who perform it, to the institution and society.• We advise that the manager , in addition to having ethical conduct, disseminate the organization's values ​​and precepts of the Code of Ethics, contributing to the application of this document.

SUPPLIERS

We guide suppliers to follow the guidelines of this Code of Ethics. We must demand from suppliers:

• Social security and tax compliance; labor legislation;

• Compliance with legislation and regulations relating to preventing and combating corruption;

• No use of child or slave labor; adoption of good environmental preservation practices;

• Non-adoption of acts of corruption against Brazilian or foreign governments and public administration. document.

COMPETITORS

• We define that ethics, integrity and civility must be guiding principles in our relations with competitors. Exchanges of information can only occur in a lawful and transparent manner, preserving our principles and the interests of Impact Bank.

• We prohibit inappropriate practices in the offering of products and services, including imposition on the execution of business.

• We are transparent and agile in providing information, observing rules of secrecy and confidentiality.

GOVERNMENTS

• We must act in relations with public authorities in accordance with international guidelines with regard to preventing and combating tax evasion, corruption, money laundering and terrorist financing.

• We must establish, regardless of individual ideological convictions, a courteous relationship with the Brazilian public authorities and with those of the countries in which we operate. • We repudiate acts of corruption committed against Brazilian or foreign governments and public administration.

• We prohibit giving, offering, promising or authorizing the giving of anything of value to a Brazilian or foreign government official, directly or through an intermediary, in order to influence action to obtain an undue advantage.

BENEFICIARIES

The beneficiaries of the Impact Bank Transformation Fund, whether they are legal entities or individuals, are its main reason for existence. For this reason, All principles set out in this Code of Ethics apply to Impact Bank's relationship with its beneficiaries. Impact Bank understands that it must always make every effort to ensure that the actions carried out in favor of its beneficiaries are increasingly effective and efficient, paying attention to:

• Treating and offering solutions with quality, respect and honesty in its actions, aiming to satisfy beneficiaries;

• Transparency in the planning and execution of actions, with the participation of beneficiaries in all stages of the process;

• The deadlines and values ​​established in the plans;

• Compliance with all principles of this Code of Ethics.

08 | Conflict of interests

We warn that the actions exemplified below constitute a conflict of interest:

• Conduct matters or business with a public agent with decision-making power within the scope of government bodies and entities with whom they have a kinship relationship, in a direct or collateral line, by consanguinity or affinity, up to the 3rd degree.

• Use privileged information about a material act or fact not yet disclosed in the market to which you have had access due to your position or function.

• Use internal information to carry out personal business with third parties, such as customers, suppliers, service providers, and partners.

• Carry out external activities that may constitute harm or competition for Impact Bank.

• Cases of conflict of interest involving members of the Executive Board (President and Directors) must be forwarded to the Ethics and Compliance Committee for analysis.

09 | Illustrative example

We warn that the actions exemplified below constitute a conflict of interest:

• Conduct matters or business with a public agent with decision-making power within the scope of government bodies and entities with whom they have a kinship relationship, in a direct or collateral line, by consanguinity or affinity, up to the 3rd degree.

• Use privileged information about a material act or fact not yet disclosed in the market to which you have had access due to your position or function.

• Use internal information to carry out personal business with third parties, such as customers, suppliers, service providers, and partners.

• Carry out external activities that may constitute harm or competition for Impact Bank.

• Cases of conflict of interest involving members of the Executive Board (President and Directors) must be forwarded to the Ethics and Compliance Committee for analysis.

10 | Ethical Decision

1. Does your decision comply with Impact Bank's code of ethics, current legislation and internal regulations?

2. Does your decision serve the interests of the Impact Bank community?

3. Can this decision be justified to your colleagues and superiors?

4. Except in situations where there is a need for secrecy and confidentiality, can your decision be public?

5. If you answer NO to any of these questions, then seek help!

11 | Responsible Use of Digital Media

• We strive for inclusive communication that creates favorable conditions for negotiating action and carrying out work, with a focus on transparency, clarity and objectivity.

• We must use digital media responsibly and apply good communication practices aligned with the principles of integrity, transparency and respect.

• We understand that internal communication must contribute to strengthening the relationship between the Company and employees.

• We value expressions in the digital environment that respect the diversity of ideas and the Company's positioning.

• We prohibit Impact Bank from linking to comments and postings of offensive information or images and/or that violate the privacy of employees and third parties on digital media and social networks.

• We prohibit the issuance or dissemination of offensive criticism or slander that exposes the image or honor of the Bank, its units or its employees.

• Before writing on social media, remember that all content added is public. Think about the impact on your professional life, your privacy and that of others.

12 | Impact Bank Assets and Resources

• We prohibit the use for private purposes of goods or services exclusive to the performance of our duties. • We must protect the assets and image of Impact Bank and disseminate this care.

• We prohibit the use of facilities, equipment, work materials and electronic communications network for political-partisan, religious matters or for our own or third party's commercial interests.

• We must preserve the institutional identity, avoiding using the Company's name, brands and private symbols without authorization.

• We must be aware of the responsibility in handling corporate information.

• We must preserve the institutional identity, avoiding using the Company's name, brands and private symbols without authorization.

• We prohibit employees from dealing with confidential matters and matters for internal use of Impact Bank in conference rooms conversation, social networks and applications with internet access.

• We must protect the confidentiality of information relating to a relevant act or fact to which we have privileged access due to the position or function we occupy.

• We must observe intellectual property standards for books, texts, images and other products protected by copyright.

• We treat internal and external data collected responsibly and ethically, in accordance with legislation, throughout the information life cycle.

• We must carry out our activities respecting customer privacy and legislation relating to the subject, including the use and processing of analytical databases.

13 | Reports

• We value your expression. If you notice something that violates Impact Bank's Code of Ethics, it is your duty to report it. The Ombudsman's Office or bodies eventually responsible for processing reports of ethical transgressions will preserve the anonymity of the whistleblower, in order to avoid retaliation against them and will inform them of the measures adopted.

• Complaints must be forwarded to the Internal Ombudsman: ouvidoria@impactbank.com.br

• Cases of this nature will be evaluated from an ethical perspective and may be referred for disciplinary treatment.

14 | Additional Provisions

We understand that failure to comply with the guidelines of this Code of Ethics represents a serious manifestation against the ethics and administrative principles of Impact Bank. Anyone who fails to comply with the Code of Ethics is subject to the penalties of the normative instructions and may be held liable in court.

INDEX

01 | Message from the Impact Bank team

02 | Mission, vision and values

03 | Target Audience

04 | Ethical Principles

05 | Principles of Regenerative Development

06 | Respect for the Individual

07 | Good Relationship Practices

08 | Conflict of interests

09 | Illustrative example

10 | Ethical Decision

11 | Responsible Use of Digital Media

12 | Impact Bank Assets and Resources

13 | Reports

14 | Additional Provisions

01 | Message from the Impact Bank team

Created from the fusion of external references and the internal perspectives of our team, the Impact Bank Code of Ethics is an organic document, which must be updated periodically through collaborative and inclusive processes, so that together we can advance on this learning journey.

Its greatest mission is to be a conscious guide that guides our daily conduct, based on honesty, ethics, transparency, respect for others, the planet, life, legislation and internal standards.

An important, aligned document that strengthens our purpose of collaborating together to give a new meaning to profit by adding social and environmental value to the circulation of money to accelerate the necessary transformations for a more just and regenerative future.

Impact Bank is committed to regenerative principles and practices, a development model that evolves beyond sustainability - it seeks to reverse environmental and social degradation.

Therefore, a responsible stance for our choices and conduct, aware of the impact of our actions on the planet, the organization and its community, will be decisive for the successful applicability of this Code of Ethics.

It is important to emphasize that each person's effort must go beyond self-responsibility and extend their actions to a non-missing stance, in the face of other conduct that does not meet the ethical principles of this code.

We invite you to dedicate a few minutes to reading this document, so that it provides you with input for reflection and guidance on conduct. Being recognized as an integral, trustworthy, honest and transparent institution depends on unrestricted compliance with this Code of Ethics.

This document also reflects our belief that it is necessary to take advantage of Brazil's current moment so that our society can reinvent itself and be more ethical, fair and regenerative.

Gabriel Ribenboim and Impact Bank team

02 | Mission, vision and values

MISSION

Together, we collaborate to give a new meaning to profit by adding social and environmental value to the circulation of money to accelerate necessary transformations for a more just and regenerative future.

VISION

To be a financial platform that leaves no one behind and that promotes innovation in financial services and ethical and fair business models that contribute to social and environmental regeneration.

VALUES

Ethics and Justice; Honesty and Transparency; Respect and Reciprocity; Collaboration and Inclusion; Harmony and Balance, Based on Nature and the Human Being; Regenerative Impact first.

PRINCIPLES OF THE CODE OF ETHICS

RESPECT

INTEGRITY

HONESTY

TRANSPARENCY

RESPONSIBILITY

HARMONY AND RECIPROCITY

03 | Target Audience

The Impact Bank community

TRANSFORMATION AGENTS

Impact Bank customers, partner third sector organizations and their direct beneficiaries

COLLABORATORS

Interns, apprentices, managers and employees of contracted companies. EMPLOYEES People with labor relations with Impact Bank.

HIGH ADMNISTRATION

President and directors, including of controlled companies.

04 | Ethical Principles

Impact Bank, in turn, undertakes to disseminate the Code of Ethics among all its employees, to ensure that its actions are governed by the principles and commitments contained in this Code of Ethics. Ethical principles are an essential part of our responsibilities and dictate the direction we must take, especially when we experience ethical dilemmas and need to make decisions.

RESPECT

The relationship with the Impact Bank community must always be based on respect, dignity and indiscriminateness of people. We respect and value the ancestral knowledge of past generations and respect the limits of present generations without compromising the ability of future generations to meet their own needs. Impact Bank refuses and repudiates any degrading attitude against the planet and its biodiversity and any hostile or humiliating attitude against people, and does not tolerate disrespect for dignity, equality, diversity, people's privacy and life. The work environment and relationships must be guided by professionalism, respecting different cultures, beliefs and positions.

HONESTY

We expect the conduct of members of the Impact Bank community to be consistent with honesty. We must do and communicate only what is right, we must act in good faith, with integrity and sincerity in matters that affect the duties and interests of the community.

TRANSPARENCY

Impact Bank ensures transparency in its relationships, actions and business. Secrecy and confidentiality of information are required in our routine. The trust of our partners is linked to the access that Impact Bank gives to information, accountability and decision-making. However, actions carried out deliberately in secret are not ethical and accepted.

RESPONSIBILITY

Each member of the Impact Bank community is responsible for their actions and decisions. We must be responsible for creating a transparent, respectful and safe environment, so that relationships and business are ethical and regenerative. It is also our responsibility to know, ensure and comply with established internal policies and procedures.

HARMONY AND RECIPROCITY

Harmony is understood as the combination of elements linked by a relationship of pertinence, which produces a pleasant sensation of pleasure. The concept reflects a culture of peace between the Impact Bank community, our products and services, and the balance between business, people and planet. If a relationship, of any nature, or the perception of any product or service does not sound harmonious, it is a sign to stop, communicate, reflect and co-create solutions, based on listening and collective and inclusive construction. of us, members of the Impact Bank community, contribute to the harmony of the community and the movement in which we choose to be part of, just as the community and the movement as a whole directly contribute to our harmony and prosperity as individuals.

05 | Principles of Regenerative Development

1. Right relationship

Understands that the ecosphere is made up of nested systems, living and non-living. It recognizes that the human economy is embedded in culture and the ecosphere and must operate in a dynamic and cooperative relationship with them, respecting cultural needs and planetary limits. It allows critical value-added exchanges to occur at all scales in the reciprocal relationship, in contrast to commoditized transactions.

How we position ourselves

There is a growing movement of companies that see their role as more than simply maximizing shareholder value. One example is B Corporations, which prioritize environmental and social goals as much as fiscal ones, and understand that they can leave the world a better place than it was when they started - and do so profitably. Impact Bank has already started the certification process as a B Corporation, following in the footsteps of Welight Tecnologia Social, from which we emerged. We operate with a focus on our social and environmental duty in defining policies, standards and procedures to prevent and combat corruption, as well as money laundering and terrorist financing. We reject any form of degrading work. It is part of our institutional culture to develop and support regenerative development initiatives and we value links established with the communities in which we operate and respect their cultural values ​​and knowledge and give back to the community part of the value added to the business.

What can we do as individuals

Notice instances of cooperation around you all the time—in nature, in the business world, and in human culture more broadly. Embody this principle by reflecting on opportunities for cooperation and healthy interactions and taking advantage of them when possible. For example, companies can expand their relationships with local companies and suppliers. As an individual, seek collaboration and advice from neighbors in your projects, such as gardening, creative work, or business ventures. Support organizations, movements and leaders that focus on having a correct relationship with nature and society.

2. See wealth holistically

True wealth is not just money in the bank. It is based on the assumption that wealth is the well-being of the whole, which must be achieved through the harmonization of multiple types of wealth or capital, including social, cultural, living and experiential. It recognizes that numerous dimensions of human and natural capital cannot be measured in monetary terms, but must be nurtured as intrinsic components of holistic wealth. Thus, wealth must be defined by broadly shared prosperity across all the varied forms of capital.

How we position ourselves

Companies that embody regenerative principles know that wealth is more than just financial. Impact Bank values ​​its human capital, in the form of happy, well-cared for employees; values ​​and stimulates their cultural capital by offering a space for positive, diverse and empowering interactions to occur; and values ​​natural capital, creating value chains that improve the health of the planet we share.

What can we do as individuals

Take stock of the various forms of wealth you have, in addition to financial wealth.

Maybe it's a satisfying social network, access to parks and natural spaces, the ability to pursue curiosity and develop intellectually, or spiritual fulfillment. Support community organizations that emphasize multiple forms of capital and seek to build the various types of wealth that can provide deeper fulfillment than money.

3. Innovative, adaptable, responsive

In a world where change is always present, the qualities of innovation and adaptability are essential for the health of the whole. In a comparison with Charles Darwin's theory, the most suitable is the one that fits best, the one that is most adaptable to a changing environment.

How we position ourselves

The application here is clear: humans have a knack for solving problems in creative ways. The companies that do well are the ones that survive. Creative business models are often the best at solving difficult problems in a way that also benefits local communities and the planet.

What can we do as individuals

Everyone has creative abilities, even if they have not been intentionally exercised recently. Challenge your habitual ways of thinking about social problems - be willing to let go of ideas about what should work and what has already been done. Consider solutions or ideas that seem irrational or impossible, as once more options are on the table, innovative solutions may emerge.

4. Empowered participation

All healthy living systems are self-organizing and operate through continuous negotiation with each other and in constant interaction. Likewise, a healthy human economy requires the empowered participation of individuals and groups, negotiating in their own enlightened self-interest as they naturally promote the health of the whole.

How we position ourselves

We adopt a decentralized leadership model as a way to ensure everyone has a voice, ensure adherence to Impact Bank community goals, strengthen professional relationships, and create a healthy and empowering collective.

What can we do as individuals

Recognizing that the best scenarios are those in which everyone benefits, look for ways to strengthen these interactions in the world. Support solutions and policies that are good for people and the planet. Many policies that are good for the planet are also good for people and the economy, and our elected officials need to know that we support them. In business, try to bring as many interested parties into the conversation as possible, rather than restricting decision-making to smaller, closed groups.

5. Honor communities and places

Each human community consists of a mosaic of peoples, traditions, beliefs, and institutions uniquely shaped by long-term pressures of geography, human history, culture, the local environment, and changing human needs. Honoring this fact, a regenerative economy nurtures healthy, resilient communities and regions, each uniquely informed by the essence of their individual history and place.

How we position ourselves

In a world seemingly dominated by large companies, small companies may have important collaborative advantages that should be strengthened. Traditional and indigenous communities in Brazil and local populations have a vast collection of specific knowledge about their territory, culture, economy, wildlife, biodiversity, climate and soil conditions specific to their area. Those with this knowledge can often be more successful than larger companies trying to apply off-the-shelf solutions. Likewise, in partnership with organizations and groups operating in different territories, we seek to catalyze local energy and knowledge to adapt solutions that would not be possible without special place-based knowledge.

What can we do as individuals

Think about how your location is unique and worth celebrating. Take pride in your place by being a patron and promote, encourage and participate in activities that regenerate your region and its people.

6. Plenty of Edge Effect

Creativity and abundance flourish synergistically at the “edges” of systems, where the ties that hold the dominant pattern in place are weakest. For example, there is an abundance of interdependent life in salt marshes where a river meets the ocean. At these edges, opportunities for innovation and cross-fertilization are greater. Working collaboratively across borders - with continuous learning and development coming from the diversity that exists there - is transformative for both the communities where exchanges are happening and the individuals involved.

How we position ourselves

Companies with greater diversity are more innovative, generate more profits and have happier employees. Diverse perspectives help groups make decisions, lead to greater creativity and promote respectful environments. This business “edge effect” is a characteristic of more regenerative economic systems.

What can we do as individuals

Notice the ways in which diversity in its many forms—in your social network, the cultures you've experienced, the ideas you consider, the foods you try—can enrich your life. In your workplace, see if there are ways to present unconventional perspectives or bring in people who have them. While specialists have some strengths, generalists who are well-versed in a variety of topics can often have creative insights or valuable ideas. Look for connections between disparate areas of your knowledge.

7. Robust circular flow

A regenerative economy mimics the metabolic process found in resilient living systems, harnessing what we now discard as “waste” into a continuous, productive, circulatory, and valorizing flow. Likewise, the regenerative model promotes the circular flow of appreciation of money, information, efficient use and reuse of materials and are particularly important for individuals, companies and economies to achieve the expected regenerative potential.

How we position ourselves

As it is a movement primarily guided by digital, our parallel is made with the circulation of money. We design solutions based on guiding questions such as "How to mobilize capital to finance transformations for a more just and regenerative future?", "How can we maximize the positive impact of the circulation of money?" and "What are the most efficient strategies and vehicles to finance initiatives with social and environmental impact?". Nevertheless, we seek to incorporate the circular economy of energy and materials as much as possible, reducing, reusing, recovering and recycling. One example is the next version of our Impact Bank Card, which we are working with suppliers to offer a recycled plastic card taken from the oceans.

What can we do as individuals

Find ways to reduce or reuse “waste” in your own life. Reflect, everyone benefits from the absence of waste - and so does the planet! Discover the YAM content platform - the voice of the heart, as another way to get closer to a sustainable lifestyle.

Food: reduce your consumption of animal protein, plan your purchases and try to buy from small local producers, plant at home, eliminate the concept of waste by reusing leftovers, and have a compost bin at home for what cannot be used as food. There are several tutorials on the internet for you to create your own compost bin at home and contribute to this cycle. To find out much more, see here a YAM guide with 10 steps to avoid food waste.

Plastics: eliminate those that are not necessary, reuse and recycle, keeping them in the economy and out of the environment. Find out more in the Reciclando de Verdade guide, on the YAM platform.

Fashion: try to ensure that clothes and accessories are used more often, can be transformed into new pieces and are made from safe and renewable materials.

Finance: seek to support companies in their transition to circular business models and support movements, NGOs and leaders that develop circular economy solutions.

8. Search for balance

Being in balance is more than just a pleasant way of being. It is, in fact, essential for systemic health. Like an Indian woman paddling her fine canoe in turbulent waters, regenerative systems are always engaged in this delicate dance in search of balance. Achieving this requires them to harmonize multiple variables rather than optimizing a single one. A regenerative economy seeks to balance efficiency and resilience, collaboration and competition, diversity and coherence, and the needs of small, medium and large organizations.

How we position ourselves

Business has often been a force pushing natural and social systems into imbalance - but many are now shifting their priorities to help restore balance. System B Corporations and regenerative business models balance the profit motive with equal emphasis on people and planet. Impact Bank was conceived as a movement that puts first your contribution to ensuring that social, ecological and economic systems operate in a healthy balance.

What can we do as individuals

Balance is a theme that permeates each of the Regenerative Principles. Things simply work better when they are in balance. Consider the things in your own life that seem out of balance and look for ways to restore balance. Support movements, NGOs, companies, policies and politicians that aim to restore balance and help create systems but that provide shared prosperity on a prosperous planet.

06 | Respect for the Individual

Relationships in the workplace and in all interactions within the Impact Bank community must be guided by mutual respect and courtesy, valuing ethics, integrity and transparency. Any type of discrimination, or intimidating attitudes regarding differences in race, origin, color, physical conditions, gender, sexual orientation, religious beliefs or political convictions will not be tolerated.

• We respect the diversity of the people who form the work environment and who maintain relationships with Impact Bank.

• We encourage a culture of respect and repudiate violence.

• We ensure the establishment of a dignified and healthy work environment, basing relationships on respect and cordiality, regardless of the position held in the organization or role within the Impact Bank community.

• We must prevent embarrassment and damage to the image of Impact Bank and the employee himself.

• Moral harassment is understood as all abusive conduct, such as gestures, words and attitudes that are repeated systematically, affecting the dignity or psychological or physical integrity of the worker.

• We repudiate conduct that may constitute harassment of any nature, discrimination or induction thereof; coercion, persecution or embarrassment; disrespect for functional duties; public disqualification, offense or threat.

The definition of harassment is described in art. 216-A of the Penal Code: "Embarrassing someone with the intention of obtaining sexual advantage or favor, taking advantage of the agent's status as hierarchical superior or ancestry inherent to the exercise of employment, position or function".

07 | Good Relationship Practices

Impact Bank's Code of Ethics defines guidelines that must be observed by its community:

MANAGERS

• We expect our managers to be developer leaders, inspiring teams and stimulating engagement, with a view to training successors for current and future challenges.• We determine that managers do what is right, be a reference for appropriate posture and encourage teamwork as practice of collaboration and sharing of knowledge and experiences.• We believe that corporate ethics is mainly related to everyone's behaviors, practices, beliefs and values. Therefore, it seeks to promote a corporate culture, based on solid pillars in which people come first, whether they are employees, suppliers, customers or society in general.• Managers must act with transparency, be open to dialogue and interact with their employees. employees in order to share actions and objectives that lead to the common good, always in an ethical manner.• Cultivate environments that encourage the performance of high quality work, relevant to those who perform it, to the institution and society.• We advise that the manager , in addition to having ethical conduct, disseminate the organization's values ​​and precepts of the Code of Ethics, contributing to the application of this document.

SUPPLIERS

We guide suppliers to follow the guidelines of this Code of Ethics. We must demand from suppliers:

• Social security and tax compliance; labor legislation;

• Compliance with legislation and regulations relating to preventing and combating corruption;

• No use of child or slave labor; adoption of good environmental preservation practices;

• Non-adoption of acts of corruption against Brazilian or foreign governments and public administration. document.

COMPETITORS

• We define that ethics, integrity and civility must be guiding principles in our relations with competitors. Exchanges of information can only occur in a lawful and transparent manner, preserving our principles and the interests of Impact Bank.

• We prohibit inappropriate practices in the offering of products and services, including imposition on the execution of business.

• We are transparent and agile in providing information, observing rules of secrecy and confidentiality.

GOVERNMENTS

• We must act in relations with public authorities in accordance with international guidelines with regard to preventing and combating tax evasion, corruption, money laundering and terrorist financing.

• We must establish, regardless of individual ideological convictions, a courteous relationship with the Brazilian public authorities and with those of the countries in which we operate. • We repudiate acts of corruption committed against Brazilian or foreign governments and public administration.

• We prohibit giving, offering, promising or authorizing the giving of anything of value to a Brazilian or foreign government official, directly or through an intermediary, in order to influence action to obtain an undue advantage.

BENEFICIARIES

The beneficiaries of the Impact Bank Transformation Fund, whether they are legal entities or individuals, are its main reason for existence. For this reason, All principles set out in this Code of Ethics apply to Impact Bank's relationship with its beneficiaries. Impact Bank understands that it must always make every effort to ensure that the actions carried out in favor of its beneficiaries are increasingly effective and efficient, paying attention to:

• Treating and offering solutions with quality, respect and honesty in its actions, aiming to satisfy beneficiaries;

• Transparency in the planning and execution of actions, with the participation of beneficiaries in all stages of the process;

• The deadlines and values ​​established in the plans;

• Compliance with all principles of this Code of Ethics.

08 | Conflict of interests

We warn that the actions exemplified below constitute a conflict of interest:

• Conduct matters or business with a public agent with decision-making power within the scope of government bodies and entities with whom they have a kinship relationship, in a direct or collateral line, by consanguinity or affinity, up to the 3rd degree.

• Use privileged information about a material act or fact not yet disclosed in the market to which you have had access due to your position or function.

• Use internal information to carry out personal business with third parties, such as customers, suppliers, service providers, and partners.

• Carry out external activities that may constitute harm or competition for Impact Bank.

• Cases of conflict of interest involving members of the Executive Board (President and Directors) must be forwarded to the Ethics and Compliance Committee for analysis.

09 | Illustrative example

We warn that the actions exemplified below constitute a conflict of interest:

• Conduct matters or business with a public agent with decision-making power within the scope of government bodies and entities with whom they have a kinship relationship, in a direct or collateral line, by consanguinity or affinity, up to the 3rd degree.

• Use privileged information about a material act or fact not yet disclosed in the market to which you have had access due to your position or function.

• Use internal information to carry out personal business with third parties, such as customers, suppliers, service providers, and partners.

• Carry out external activities that may constitute harm or competition for Impact Bank.

• Cases of conflict of interest involving members of the Executive Board (President and Directors) must be forwarded to the Ethics and Compliance Committee for analysis.

10 | Ethical Decision

1. Does your decision comply with Impact Bank's code of ethics, current legislation and internal regulations?

2. Does your decision serve the interests of the Impact Bank community?

3. Can this decision be justified to your colleagues and superiors?

4. Except in situations where there is a need for secrecy and confidentiality, can your decision be public?

5. If you answer NO to any of these questions, then seek help!

11 | Responsible Use of Digital Media

• We strive for inclusive communication that creates favorable conditions for negotiating action and carrying out work, with a focus on transparency, clarity and objectivity.

• We must use digital media responsibly and apply good communication practices aligned with the principles of integrity, transparency and respect.

• We understand that internal communication must contribute to strengthening the relationship between the Company and employees.

• We value expressions in the digital environment that respect the diversity of ideas and the Company's positioning.

• We prohibit Impact Bank from linking to comments and postings of offensive information or images and/or that violate the privacy of employees and third parties on digital media and social networks.

• We prohibit the issuance or dissemination of offensive criticism or slander that exposes the image or honor of the Bank, its units or its employees.

• Before writing on social media, remember that all content added is public. Think about the impact on your professional life, your privacy and that of others.

12 | Impact Bank Assets and Resources

• We prohibit the use for private purposes of goods or services exclusive to the performance of our duties. • We must protect the assets and image of Impact Bank and disseminate this care.

• We prohibit the use of facilities, equipment, work materials and electronic communications network for political-partisan, religious matters or for our own or third party's commercial interests.

• We must preserve the institutional identity, avoiding using the Company's name, brands and private symbols without authorization.

• We must be aware of the responsibility in handling corporate information.

• We must preserve the institutional identity, avoiding using the Company's name, brands and private symbols without authorization.

• We prohibit employees from dealing with confidential matters and matters for internal use of Impact Bank in conference rooms conversation, social networks and applications with internet access.

• We must protect the confidentiality of information relating to a relevant act or fact to which we have privileged access due to the position or function we occupy.

• We must observe intellectual property standards for books, texts, images and other products protected by copyright.

• We treat internal and external data collected responsibly and ethically, in accordance with legislation, throughout the information life cycle.

• We must carry out our activities respecting customer privacy and legislation relating to the subject, including the use and processing of analytical databases.

13 | Reports

• We value your expression. If you notice something that violates Impact Bank's Code of Ethics, it is your duty to report it. The Ombudsman's Office or bodies eventually responsible for processing reports of ethical transgressions will preserve the anonymity of the whistleblower, in order to avoid retaliation against them and will inform them of the measures adopted.

• Complaints must be forwarded to the Internal Ombudsman: ouvidoria@impactbank.com.br

• Cases of this nature will be evaluated from an ethical perspective and may be referred for disciplinary treatment.

14 | Additional Provisions

We understand that failure to comply with the guidelines of this Code of Ethics represents a serious manifestation against the ethics and administrative principles of Impact Bank. Anyone who fails to comply with the Code of Ethics is subject to the penalties of the normative instructions and may be held liable in court.

Abra sua conta agora

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Certification

Impact not a Bank Payments SA, registered under CNPJ/MF, under no. 40,059,045/0001-56, is not a financial institution and does not directly carry out credit operations. It acts as a payment institution, governed by Law No. 12,865, of October 9, 2013, and regulated by Circular of the Central Bank of Brazil (“Bacen”) No. 3,885, of March 26, 2018, and as a banking correspondent under the terms of art. 2, of CMN Resolution 3,954, of February 24, 2011 (“Resolution 4,656/2018). Impact Bank enables services for buying, selling, and moving funds, within a payment arrangement, and operates as an authorized exchange correspondent by the Central Bank of Brazil of eFX Corretora de Câmbio Ltda., CNPJ 94,968,518/0001-67, headquartered at Avenida São Luis, 192, sobreloja 25, República, Centro, CEP 01046-913, São Paulo-SP, phone (11) 3156-2166, ombudsman 0800 770 5422 | ombudsman@efxcambio.com.br to facilitate the process of buying and selling foreign currency ("Impact Bank Exchange"). Some services provided, such as transferring funds from Impact Bank payment accounts to other banks, are carried out through partnerships with financial institutions duly authorized by Bacen. The Impact Bank Investment Platform is developed by Órama Distribuidora de Títulos e Valores Mobiliários S.A. ("Órama"), an institution integrated into the securities distribution system duly established and operational in Brazil, duly authorized to operate by the Central Bank of Brazil ("BACEN") and by the Securities and Exchange Commission ("CVM"). Órama is responsible for the distribution of investment products. All operations carried out on the Impact Bank Investment Platform are executed and monitored through Órama's control systems. Impact Bank is not authorized to provide any activity related to the distribution of investments provided for in a specific norm and regulated by a regulating body, including, but not limited to, activities regulated by CVM under the terms of CVM Resolution No. 19, of February 25, 2021, which deals with the activity of securities consultancy; CVM Resolution No. 16, of February 9, 2021, which deals with the activity of independent investment agent; CVM Resolution No. 21, of February 25, 2021, relating to the activity of managing a portfolio of securities; and CVM Resolution No. 20, of February 25, 2021, which deals with the activity of securities analyst. Before making any investment decision, the investor must analyze if the investment product is compatible with their profile and contact their securities intermediary and/or investment advisor.

© 2024 Impact not a Bank. All rights reserved.

Award

Our seals

Certification

Impact not a Bank Payments SA, registered under CNPJ/MF, under no. 40,059,045/0001-56, is not a financial institution and does not directly carry out credit operations. It acts as a payment institution, governed by Law No. 12,865, of October 9, 2013, and regulated by Circular of the Central Bank of Brazil (“Bacen”) No. 3,885, of March 26, 2018, and as a banking correspondent under the terms of art. 2, of CMN Resolution 3,954, of February 24, 2011 (“Resolution 4,656/2018). Impact Bank enables services for buying, selling, and moving funds, within a payment arrangement, and operates as an authorized exchange correspondent by the Central Bank of Brazil of eFX Corretora de Câmbio Ltda., CNPJ 94,968,518/0001-67, headquartered at Avenida São Luis, 192, sobreloja 25, República, Centro, CEP 01046-913, São Paulo-SP, phone (11) 3156-2166, ombudsman 0800 770 5422 | ombudsman@efxcambio.com.br to facilitate the process of buying and selling foreign currency ("Impact Bank Exchange"). Some services provided, such as transferring funds from Impact Bank payment accounts to other banks, are carried out through partnerships with financial institutions duly authorized by Bacen. The Impact Bank Investment Platform is developed by Órama Distribuidora de Títulos e Valores Mobiliários S.A. ("Órama"), an institution integrated into the securities distribution system duly established and operational in Brazil, duly authorized to operate by the Central Bank of Brazil ("BACEN") and by the Securities and Exchange Commission ("CVM"). Órama is responsible for the distribution of investment products. All operations carried out on the Impact Bank Investment Platform are executed and monitored through Órama's control systems. Impact Bank is not authorized to provide any activity related to the distribution of investments provided for in a specific norm and regulated by a regulating body, including, but not limited to, activities regulated by CVM under the terms of CVM Resolution No. 19, of February 25, 2021, which deals with the activity of securities consultancy; CVM Resolution No. 16, of February 9, 2021, which deals with the activity of independent investment agent; CVM Resolution No. 21, of February 25, 2021, relating to the activity of managing a portfolio of securities; and CVM Resolution No. 20, of February 25, 2021, which deals with the activity of securities analyst. Before making any investment decision, the investor must analyze if the investment product is compatible with their profile and contact their securities intermediary and/or investment advisor.

© 2024 Impact not a Bank. All rights reserved.

Award

Our seals

Certification

Impact not a Bank Payments SA, registered under CNPJ/MF, under no. 40,059,045/0001-56, is not a financial institution and does not directly carry out credit operations. It acts as a payment institution, governed by Law No. 12,865, of October 9, 2013, and regulated by Circular of the Central Bank of Brazil (“Bacen”) No. 3,885, of March 26, 2018, and as a banking correspondent under the terms of art. 2, of CMN Resolution 3,954, of February 24, 2011 (“Resolution 4,656/2018). Impact Bank enables services for buying, selling, and moving funds, within a payment arrangement, and operates as an authorized exchange correspondent by the Central Bank of Brazil of eFX Corretora de Câmbio Ltda., CNPJ 94,968,518/0001-67, headquartered at Avenida São Luis, 192, sobreloja 25, República, Centro, CEP 01046-913, São Paulo-SP, phone (11) 3156-2166, ombudsman 0800 770 5422 | ombudsman@efxcambio.com.br to facilitate the process of buying and selling foreign currency ("Impact Bank Exchange"). Some services provided, such as transferring funds from Impact Bank payment accounts to other banks, are carried out through partnerships with financial institutions duly authorized by Bacen. The Impact Bank Investment Platform is developed by Órama Distribuidora de Títulos e Valores Mobiliários S.A. ("Órama"), an institution integrated into the securities distribution system duly established and operational in Brazil, duly authorized to operate by the Central Bank of Brazil ("BACEN") and by the Securities and Exchange Commission ("CVM"). Órama is responsible for the distribution of investment products. All operations carried out on the Impact Bank Investment Platform are executed and monitored through Órama's control systems. Impact Bank is not authorized to provide any activity related to the distribution of investments provided for in a specific norm and regulated by a regulating body, including, but not limited to, activities regulated by CVM under the terms of CVM Resolution No. 19, of February 25, 2021, which deals with the activity of securities consultancy; CVM Resolution No. 16, of February 9, 2021, which deals with the activity of independent investment agent; CVM Resolution No. 21, of February 25, 2021, relating to the activity of managing a portfolio of securities; and CVM Resolution No. 20, of February 25, 2021, which deals with the activity of securities analyst. Before making any investment decision, the investor must analyze if the investment product is compatible with their profile and contact their securities intermediary and/or investment advisor.

© 2024 Impact not a Bank. All rights reserved.