Code of Conduct
& Ethics.

This Code of Conduct and Ethics ("Code") establishes the principles, values and conduct standards that guide the activities of AHMIA CO. and of all persons acting on its behalf, in the exercise of its international trading activity in agricultural commodities, industrial metals and natural stone.

The Code aims to: (i) translate AHMIA CO.'s institutional mission, vision and values into objective conduct rules; (ii) guide decision-making in situations of ethical uncertainty or potential conflict of interest; (iii) establish minimum integrity standards required of employees, partners, service providers and business partners; and (iv) demonstrate, to clients, suppliers, regulatory bodies and other stakeholders, the company's commitment to governance practices, regulatory compliance and responsible risk management.

01 · Purpose

This Code establishes the principles, values and standards of conduct that guide AHMIA CO.'s activities and those of everyone acting on its behalf in international trading of agricultural commodities, industrial metals and natural stone.

02 · Scope

This Code applies, without exception, to:

• Partners, officers and members of AHMIA CO.'s management, including the Goiânia/GO (headquarters) and Joinville/SC (branch) units;
• Employees, interns and apprentices, regardless of hierarchical level or business vertical (agricultural, metals and natural stone);
• Service providers, consultants and commercial representatives acting on the company's behalf before third parties;
• Suppliers, partner producers and other supply chain members, to the extent they have a contractual relationship with AHMIA CO.;
• Buyers and other international counterparties, with respect to conduct obligations set out in contracts and commercial instruments (Incoterms, letters of credit, international sale and purchase agreements).

Ignorance of this Code's provisions does not exempt any recipient from compliance; formal adherence to this instrument is a condition for the commencement and continuation of any contractual or working relationship with AHMIA CO.

03 · Values and Ethical Principles

AHMIA CO.'s conduct is guided by the following institutional values, which underpin all other provisions of this Code:

• Integrity and Compliance — every transaction must be structured in compliance with Brazilian legislation and destination-market regulation, with complete and traceable documentation;
• Transparency with Partners — a direct relationship, without opaque intermediation, between the trading company, the producer and the buyer;
• Proximity to Origin — operations grounded in direct knowledge of producing regions as a strategic, not merely logistical, asset;
• Responsible Risk Management — structural, not reactive, treatment of the legal, regulatory, currency and operational risks inherent to international trade;
• Data Protection and Confidentiality — handling of personal data and sensitive commercial information under strict confidentiality and LGPD compliance;
• Long-Term Commitment — commercial relationships conceived as ongoing partnerships, not one-off transactions.

04 · Principles of Integrity

Integrity is a non-negotiable premise of AHMIA CO.'s operations and comprises, at minimum:

• Honesty in commercial relationships, with truthful, complete and verifiable information provided to clients, suppliers, public bodies and regulators;
• Consistency between institutional discourse (mission, vision and values) and day-to-day operational practice;
• Prohibition of any form of improper advantage, bribery, kickback or facilitation payment, including in international operations subject to foreign anti-corruption legislation (e.g., U.S. Foreign Corrupt Practices Act — FCPA, UK Bribery Act), where applicable to the counterparty;
• Individual accountability for decisions made in the exercise of company functions or representation;
• Proactive identification and reporting of situations that may constitute a violation of this Code, through the formal channels indicated in Section 11.

Integrity is not limited to the absence of wrongdoing: it presupposes active conduct promoting an ethical business environment across AHMIA CO.'s entire value chain.

05 · Equity

AHMIA CO. bases its internal and external relationships on fair, non-discriminatory treatment, committing to:

• Prohibit any form of discrimination based on origin, race, color, sex, sexual orientation, gender identity, age, religion, disability, social condition or political opinion in hiring, promotion, compensation and third-party relationship processes;
• Ensure objective, uniform criteria in the selection of suppliers and business partners, without favoritism based on undisclosed personal relationships;
• Guarantee equity in commercial terms offered to buyers in equivalent situations, subject to legitimate market differentiations (volume, term, credit risk, applicable Incoterm);
• Promote a work environment free from harassment and abuse of power, as detailed in Section 8(g).

06 · Commitment to Information

Information is a strategic asset for AHMIA CO., especially given the nature of trading activity, in which market intelligence, pricing and production capacity represent direct competitive advantage. This commitment unfolds across three dimensions:

a) Privileged Information

No recipient of this Code may use, for their own benefit or that of third parties, privileged information obtained by reason of their position, function or contractual relationship with AHMIA CO. — including, but not limited to: pricing and volume terms not yet formalized, partners' production capacity, ongoing commercial negotiations, and non-public financial information of the company or its counterparties. This prohibition survives termination of the relationship with the company.

b) Protection of Information Assets

• Respect intellectual property, own and third-party, including trademarks, commercial methodologies, supplier databases and copyrighted materials;
• Establish and observe an effective information asset protection program, comprising access controls, information classification by sensitivity level and incident response procedures;
• Use corporate systems, equipment and communication channels for personal matters only incidentally and reasonably, without prejudice to professional activities or information security;
• Respect and safeguard the confidentiality of client, supplier and employee data, in compliance with Law No. 13,709/2018 (LGPD) and, where applicable, the EU General Data Protection Regulation (GDPR) in relationships with European counterparties;
• Mitigate risks inherent to information assets through periodic vulnerability assessment, continuous training and adoption of risk-proportional controls (risk-based approach, per ISO 31000:2018).

c) Accuracy of Company Information and Reports

All of AHMIA CO.'s accounting, commercial, customs and regulatory records must accurately reflect the transactions carried out, prohibiting any form of fictitious record, under-invoicing, over-invoicing or omission of material information in export documents, commercial invoices, certificates of origin or reports submitted to national and international regulatory bodies.

07 · Valuing People

AHMIA CO. recognizes people as the central element of its business strategy, committing to management practices that ensure dignity, professional development and safety in the exercise of work activities.

a) Duties in the Exercise of a Role or Function

• Perform duties with diligence, care and technical knowledge compatible with the role, reporting to leadership any insufficiency of resources, training or information for adequate performance;
• Observe internal policies, authority limits and approval procedures established for commercial, financial and contractual operations;
• Report, without fear of retaliation, situations posing risk to the company's physical, legal or reputational integrity.

b) Work Environment

• Promote a safe, healthy and respectful work environment, in compliance with applicable labor and occupational safety legislation;
• Prohibit any form of moral or sexual harassment, as detailed in Section 8(g);
• Ensure channels for listening and dialogue between employees and leadership, including through the reporting channels set out in Section 11.

08 · Constructive Relationships

AHMIA CO. bases its external relationships on the creation of mutual, sustainable value, observing the specific guidelines below for each stakeholder group.

a) Clients

Relationships with domestic and international buyers must be based on transparency regarding commercial terms (price, term, Incoterm, technical product specification), fidelity to assumed contractual obligations, and timely communication of any fact that may impact performance of the sale and purchase contract.

b) Suppliers of Products and Services and Business Partners

The selection and maintenance of relationships with producers, suppliers and service providers will observe objective criteria of suitability, technical capacity and regulatory compliance, including, where applicable, integrity due diligence procedures (screening of restrictive lists, international sanctions and Politically Exposed Persons — PEPs) proportional to the risk of the commercial relationship.

c) Government and Regulatory Bodies

Relationships with Brazilian and foreign governmental, customs, tax and regulatory bodies will be based on cooperation, truthfulness of information provided, and an absolute prohibition on any form of improper payment, direct or indirect, to obtain advantage, expedite process, or receive privileged treatment.

d) Money Laundering and Corruption

Given the international nature of its operations, AHMIA CO. adopts a zero-tolerance stance toward corruption and money laundering, committing to:

• Not carry out, offer, promise or accept improper advantage to a public official, domestic or foreign, or to third parties, in compliance with Law No. 12,846/2013;
• Adopt Know Your Counterparty (KYC) procedures and monitor atypical transactions, especially regarding the source of funds, counterparties' corporate structure, and operations with high-risk jurisdictions;
• Internally report any indication of money laundering, terrorism financing, or violation of international sanctions and export control regimes.

e) Press

Statements to the press on behalf of AHMIA CO. are the exclusive responsibility of spokespersons formally designated by Management; unauthorized employees may not provide institutional, commercial or financial information to media outlets.

f) Conduct Outside the Company

The conduct of employees and representatives outside the work environment is not subject to company interference, except where such conduct compromises institutional reputation, constitutes a wrongdoing related to professional activity, or violates contractually assumed confidentiality and non-competition obligations.

g) Harassment and Abuse of Power

Any form of moral harassment, sexual harassment or hierarchical abuse of power is expressly prohibited, including in relationships mediated by digital means. Reports will be investigated with confidentiality, impartiality and a prohibition on retaliation against the whistleblower, under the investigation procedure set out in Section 11.

h) Media and Social Networks

Use of personal social media to comment on matters related to AHMIA CO. must safeguard confidential information, client and supplier data, and avoid positions that could be institutionally attributed to the company without prior authorization.

i) Communities and Integration

AHMIA CO. recognizes its role in the communities where it maintains its headquarters and branch (Goiânia/GO and Joinville/SC), promoting relationships of respect and, where applicable, integration and local development initiatives compatible with its economic activity.

j) Associations and Trade Bodies

Participation by company representatives in trade associations, industry bodies and sector forums must observe applicable competition rules, prohibiting the exchange of sensitive information about prices, volumes or clients with direct competitors (prohibition of cartel practices).

k) Environmental Management and Socio-Environmental Risk

In operations related to agricultural commodities, metals and natural stone, AHMIA CO. will observe production origin traceability criteria, adopting, whenever applicable, supplier socio-environmental verification procedures (e.g., absence of illegal deforestation, labor analogous to slavery, and compliance with environmental and mining licensing).

09 · Responsible Leadership

Formal and informal AHMIA CO. leaders bear heightened responsibility in disseminating a culture of integrity, and are responsible for:

• Serving as an example in observing this Code, including in commercial decisions subject to results pressure;
• Ensuring that commercial goals and incentives do not directly or indirectly encourage conduct contrary to this Code;
• Welcoming, without retaliation, questions or reports from subordinates related to this Code;
• Reporting to Management and the Governance & Compliance area any risk situations identified in the exercise of leadership.

10 · Gifts and Invitations

The offering and receipt of gifts, hospitality and invitations to clients, suppliers and public agents, domestic or foreign, must observe the following parameters:

• Institutional gifts of symbolic value and general distribution (promotional items with logo) are permitted without prior approval;
• Gifts, hospitality or invitations of non-symbolic value must be previously disclosed to leadership and, when intended for a public agent, observe specific applicable legal prohibitions;
• Offering or accepting any advantage linked, directly or indirectly, to an ongoing commercial, contractual or regulatory decision is prohibited;
• Situations of doubt must be submitted to the Governance & Compliance area prior to their occurrence.

11 · Management of this Code of Conduct and Ethics

Management of this Code is the responsibility of AHMIA CO.'s Legal, Governance & Compliance area, responsible for its periodic update, the conduct of training, and the investigation of any violations.

a) Fraud and Diversion of Purpose

The following constitute serious violations of this Code: fraud in commercial, customs or financial documents; diversion of purpose of company funds, information or assets; and use of AHMIA CO.'s corporate or contractual structure for a purpose other than legitimate international trade activity.

b) Conflict of Interest

A conflict of interest arises whenever personal, family or third-party interests could, even in theory, compromise the impartiality of a decision made on behalf of AHMIA CO., including: equity participation in a supplier, client or competitor; a family relationship with a commercial counterparty; and the exercise of a competing or incompatible parallel activity with the role held. Situations of conflict, actual or potential, must be declared in advance to the Governance & Compliance area.

c) Disciplinary Measures

Violations of this Code subject the offender, depending on the severity of the conduct and subject to the right to a defense, to measures ranging from formal warning to termination of the contractual or employment relationship, without prejudice to applicable civil, administrative and criminal liability. Reports may be made through an identified or anonymous communication channel, with a guarantee against retaliation toward good-faith whistleblowers.

12 · General Provisions

• This Code is part of AHMIA CO.'s set of internal policies and must be interpreted together with any specific compliance, personal data protection and risk management policies the company may issue;
• Adherence to this Code is a condition for entering into and maintaining any contractual or employment relationship with AHMIA CO.;
• This Code will be reviewed periodically, at least every two years, or whenever legislative, regulatory or organizational structure changes so require;
• Omitted cases will be resolved by the Legal, Governance & Compliance area, with deliberation, when necessary, by AHMIA CO.'s Management.

13 · Regulatory Basis / Best Practices

This Code was prepared with reference to, among others, the following legal instruments, technical standards and best-practice frameworks:

• Law No. 12,846/2013 — Anti-Corruption Law (administrative and civil liability of legal entities);
• Law No. 13,709/2018 — General Personal Data Protection Law (LGPD);
• European Union General Data Protection Regulation (GDPR), where applicable to European counterparties;
• ISO 37301:2021 — Compliance Management Systems;
• ISO 31000:2018 — Risk Management, Guidelines;
• COSO ERM (2017) — Enterprise Risk Management — Integrating with Strategy and Performance;
• Brazilian Consolidation of Labor Laws (CLT) and occupational health and safety regulations;
• Integrity Program Guidelines from Brazil's Office of the Comptroller General (CGU);
• Incoterms 2020 rules, International Chamber of Commerce (ICC), applicable to the company's foreign trade operations.