Approved by Management · current version: September 2026
This Code brings together the principles and conduct rules that guide officers, staff, service providers and partners of Finadi Capital Securitizadora de Créditos S.A. It applies to all of the company’s relationships — with noteholders, assignors, regulators, suppliers and society.
This English version is a professional translation of the original Portuguese text, intended for human legal review. In case of conflict, the Portuguese text prevails.
1. Our principles
- Integrity — we act with honesty and consistency, even when no one is watching.
- Transparency — we provide clear, complete and timely information, especially about the collateral of our issuances.
- Fiduciary duty — in issuances under a fiduciary regime, investors’ interests guide the administration of the segregated estate.
- Compliance — we comply with applicable law and regulation, including CVM and Central Bank rules and the LGPD.
- Respect — we treat all people with dignity, without discrimination of any kind.
2. Conflicts of interest
2.1. Situations in which personal interests may interfere, or appear to interfere, with decisions taken on behalf of the company must be reported immediately to Management.
2.2. Related-party transactions — including with companies in the Finadi ecosystem — must observe arm’s-length terms, be duly documented and be disclosed to investors when material, as provided in the indenture.
3. Confidential and inside information
3.1. Information about investors, assignors, obligors and transactions is confidential and may be used only for the purpose for which it was obtained.
3.2. It is forbidden to use material non-public information to obtain an advantage, for oneself or for third parties.
3.3. Personal data are processed in accordance with the Privacy Policy and the LGPD.
4. Relationship with investors
4.1. We do not make yield promises or present information that may mislead the investor.
4.2. We strictly observe the distribution rules applicable to our issuances, including the restrictions of private placement, with no public selling effort.
4.3. All communication about issuances must be consistent with the respective indenture.
5. Anti-money laundering and counter-terrorist financing
We maintain procedures to identify and qualify customers and counterparties (KYC), monitor transactions and report to competent authorities, under Law No. 9.613/1998 and CVM Resolution No. 50/2021. No staff member may facilitate, conceal or fail to report suspicious transactions.
6. Anti-corruption
It is prohibited to offer, promise, give, solicit or receive an undue advantage, directly or indirectly, to public or private agents, under Law No. 12.846/2013. Gifts and hospitality are admitted only when of symbolic value, with no expectation of a counterpart and duly recorded.
7. Suppliers and partners
We select suppliers and originators on technical and ethical criteria. We expect our partners to adopt integrity standards consistent with this Code.
8. Workplace
We do not tolerate moral or sexual harassment, discrimination or any form of intimidation. We care for the health, safety and well-being of everyone.
9. Ethics Channel
Suspected breaches of this Code, of laws or of internal rules may be reported through the Ethics Channel, including anonymously. All reports are treated confidentially, and retaliation against anyone who reports in good faith is forbidden.
10. Non-compliance
Breaches of this Code subject those involved to disciplinary and contractual measures proportionate to the seriousness of the conduct, without prejudice to applicable legal sanctions.