Code of Conduct

INTRODUCTION

Wildlife is committed to ensuring our employees are working in compliance with our values and have the highest standards of ethical conduct. The Wildlife Code of Conduct aims to create a healthy work environment that encourages actions based on ethics and mutual respect.

Our employees must always ensure, in their own actions:

Everyone is responsible and expected to adhere to this Code of Conduct, incorporating it into their work assignments, workplace, and behavior.

FOLLOWING THE CODE

This Code aims to provide the highest standards of integrity and help guide your conduct. You are always representing the company regardless of the setting.

We expect every Wildlife employee to dedicate themselves to complying with this Code, company policies and procedures, and applicable laws and regulations. Failure to comply may result in disciplinary action, including but not limited to termination of employment or contract.

REPORTING VIOLATIONS

If you ever find yourself questioning some type of behavior, ask yourself:

If even so you continue in doubt and thinking that such conduct may somehow violate the Code of Conduct, any law, regulation and/or other Wildlife policy, or if you have any doubts regarding this Code of Conduct, or if you see any behavior that somehow violates the Code of Conduct, a policy, laws or regulations related to Wildlife, we kindly ask you report it anonymously or not through the Talk to Us website.

All reports made through the Talk to Us channel are confidential and will be fully addressed by the Integrity Committee. They will review the report promptly and thoroughly to determine the appropriate action to be taken and warrant an investigation.

NO RETALIATION

We do not tolerate retaliation. Wildlife prohibits any and all types of retaliation against any employee or contractor who in good faith reports or participates in an investigation of a possible violation of our Code of Conduct, policies, applicable law, and regulations.

Retaliation against anyone who provides information or assists in an investigation or proceeding will be treated as a violation of this Code of Conduct. If you believe you are being retaliated against, don’t hesitate to contact us through the Talk to Us channel.

SUPPORTING EACH OTHER

Wildlife values its reputation as a great work environment. Therefore, prizes that the relationship between its employees, regardless of any hierarchical position, or function, is one of cordial treatment, trust, safety, support, and collaboration, allowing everyone the opportunity to reach their full potential.

Every Wildlife employee is responsible for ensuring that Wildlife’s culture is one of acceptance and respect, and never represented by harassment, bullying, discrimination, bias, or violence.

HARASSMENT AND BULLYING

Everyone in Wildlife has the right to work in an environment free of harassment of any kind and form (verbal, physical, or visual) and bullying, regardless of whether the harasser or bully is a co-worker, direct or indirect superior, executive, contractor, or visitor.

Harassment happens when an employee humiliates, disrespect or embarrass another employee, repeatedly and for a long time, during the working day,in the exercise of their work assignments or in company happy hours and team events.

It can happen either in a moral or sexual aspect. Moral harassment happens when there are vexing, embarrassing, and humiliating events (not necessarily during working hours), and sexual harassment is characterized by any unwanted behavior of a sexual nature, the objective of which may include but is not limited to annoy, embarrass, humiliate and/or intimidate a person. An act of sexual harassment can be physical or verbal. What characterizes sexual assault is an attack on someone’s sexual freedom.

Bullying, on the other hand, happens when an employee intentionally makes physical and/or verbal attacks directed at another employee and continues to cause suffering, intimidation, and decrease of self-esteem to the victim.

Any of the situations mentioned above, whether related to color, gender identity, sexual identity, age, competence, medical condition, religion, political ideology, nationality or social status, will be considered as a violation of the Code of Conduct by Wildlife

If you believe you’ve been harassed or bullied by anyone from or at a Wildlife event, or within Wildlife’s perimeters, we strongly encourage you to report the incident to the Talk to Us channel immediately.

Similarly, managers who learn of any such incident must immediately report it to the channel. In case you witness any harassing or bullying behavior, you have the responsibility to report it immediately. The Integrity Committee will promptly and thoroughly investigate any complaints and take the appropriate action.

DISCRIMINATION

We believe in people’s potential and respect individuals from all backgrounds, abilities, orientations, and opinions. We value diversity and encourage an inclusive work environment capable of promoting expression, creativity, innovation, and encouraging individual achievements. Diversity of people and ideas is essential to Wildlife’s success, and we are committed to the principles of equal opportunity and creating an environment that accommodates such diversity.

For that reason, we are committed to developing and retaining a workforce of diverse backgrounds, experiences, approaches and ideas, and NOT TOLERATING, to any extent, discrimination against anyone on the basis of race, color, religion, nationality, age, disability, sexual orientation, gender identity, or marital status.

Never retaliate against anyone who, in good faith, believes that unlawful discrimination has occurred.

DRUGS AND ALCOHOL

The consumption of drugs and alcohol at Wildlife facilities, during the commute to or from the work place or in any work situation, is strictly forbidden. It not only compromises and threatens our employees’ health but also harms the work environment.

Wildlife solely allows the consumption of alcohol in its facilities and during company events, provided that the employee uses its good judgment and never drinks in a way that impairs its performance or judgment, leads to inappropriate behavior, or puts others at risk.

If you have a reasonable suspicion to believe that an employee’s use of drugs or alcohol may adversely affect the employee’s job performance or the safety of others in the workplace, directly contact us through the Talk to Us channel. Reasonable suspicion may be based on physical symptoms such as variations to the employee’s appearance, behavior, or speech.

SAFE WORKPLACE

We are committed to maintaining a work environment free of violence and/or abuse – verbal, physical, and emotional. Thus, we do not tolerate any level of violence to any employee and at any type at Wildlife or company events. The presence of any kind of weapon, in any of Wildlife’s premises, is strictly forbidden.

Also, WL has zero tolerance toward forced labor and child labor or any type of modern slavery.

AVOIDING CONFLICTS OF INTEREST

During the performance of our activities, conflicts of interest between the employee and the company will inevitably be identified. Therefore, Wildlife kindly asks you to always comply with the rules set forth herein in order to reduce the chance of potential or current conflicts arising.

ACCEPTING GIFTS, ENTERTAINMENT, AND OTHER BUSINESS COURTESIES

If you receive gifts, favors, entertainment, offers or other business courtesies from Wildlife’s current or future business partners or competitors that are:

Promotional items that are insignificant in market value, such as company branded pens, hats, mugs, moleskins, earphones, etc., generally are allowed regardless of the U$S 100 limit, in the extent to which these are maintained within the usual parameters and never appear to be able to influence decisions or compromise those who receive them. Remember, if in doubt, contact us through Talk to us.

WL employees can send gifts and entertainment with a limit of up to US$100 or the equivalent in local currency if the action is for legitimate business purposes.

We can’t’ receive gifts from suppliers, customers, or competitors when you are in a position in which you can influence decisions of the company that may affect or seem to affect the company.

Wildlife expressly forbids its employees from offering any gift, apps credits, or entertainment to customers, suppliers, or others from whom you wouldn’t be able to accept gifts, except if there is a formal written approval issued by both the Legal Department and a supervisor especially assigned to the case.

HIRING FAMILY MEMBERS OR SIGNIFICANT OTHERS

Hiring relatives to the same work environment can present, at the same time, an advantage and a disadvantage. In order to avoid harmful situations that may impair Wildlife’s development, such as promotions made with suspected favoritism, and maintain a healthy work environment, Wildlife now undertakes to adopt the proper technical criteria in its admission procedures. In the criteria, all decisions shall be made without consideration of the candidate’s level of family relationship with any Wildlife employee, and through an equitable hiring process.

Pre-existing family relationships must also be observed. Thus, all employees must be transparent about their relationship with any candidate or employee in order to help Wildlife avoid current or potential conflicts of interest in the workplace.

In case any type of conflict arises due to a family relationship between Wildlife employees, they must immediately report it to the responsible manager so that the situation can be properly handled. The company will use its best endeavors to soften the impacts of such conflict on the work environment, seeking for solutions, such as analyzing the possibility of relocating one of the relatives.

If the conflict remains, please consult your HRBP.

ROMANTIC RELATIONSHIPS

While this Code of Conduct does not prevent the development of friendships or romantic relationships between co-workers, it does set boundaries on how those relationships shall be conducted during working hours and in the work environment.

Individuals who perform supervisory or management roles and those with authority over other people’s terms and conditions of employment are subject to more stringent requirements under this Code of Conduct due to status, access to confidential information, and the capability to influence the terms, and conditions of employment of their subordinates.

Any manager in a close friendship, kinship, or romantic relationship with a subordinate must report it through the Talk to Us channel.

In that case, considering that such relationships can lead to potential conflicts of interest, undermine job performance, affect the employee’s work environment and/or pose a risk, Wildlife will try to identify if there are any other positions available to relocate one of the affected parts.

Having a conflict of interest does not necessarily represent a violation of this Code of Conduct, but not reporting it does.

USE OF THE PRODUCTS AND SERVICES OF WILDLIFE

To avoid potential conflicts of interest, do not use Wildlife products, internal tools, or data in a way that inappropriately benefits you or someone you know, or makes it seem like you have an unjust preference for users outside of Wildlife.

For instance, you should never give access to Wildlife products, data, or credits to yourself, friends, or family members. Likewise, you should never use Wildlife tools, information, or access for personal ends or to financially benefit yourself or others.

PROTECTING WILDLIFE’S ASSETS

Wildlife cultivates transparency with our products and information. This practice depends on how well we preserve our resources and protect assets and information.

INTELLECTUAL PROPERTY

Wildlife’s intellectual property rights are among our most valuable assets. Intellectual properties are creations by the human mind that are protected by different national laws and international treaties. Our (and of our licensors’, where applicable) intellectual property includes name, logo, product, expertise, copyright, and other immaterial intellectual, industrial or commercial property. Improper and unauthorized use of any of them can lead to their loss or significant loss of value Always consult the Legal Department before using Wildlife’s and its products’ protected property or information for business purposes.

In the same way, respect third parties’ intellectual property rights. We should never infringe upon others’ intellectual property rights and must appropriately attribute credits when needed. Failure to do so may lead to legal claims against Wildlife as well as hinder our reputation and community.

Report any suspected improper use of our intellectual property to our Legal Department.

CONFIDENTIALITY

Information classified as confidential must be exclusively handled for professional purposes. It is strictly forbidden to use it for your own benefit or for the benefit of third parties for any purpose other
than that for which the information was disclosed/received.

All employees with access to confidential information undertake the responsibility to preserve Wild- life’s strategic information and ensure the absolute secrecy of the information obtained and generated during the performance of their work assignments.

Everyone at Wildlife has a non-disclosure obligation regarding confidential information during and after the termination of their employment relationship with Wildlife.

Also, everyone in Wildlife has the same goal: to build a better company. We expect the employee to respect not only other employees and partners but also Wildlife’s image, by not making any comment or statement that may damage our business.

WORK RESOURCES

Wildlife provides its employees with all the tools and equipment necessary to perform their work assignments.

Our employees must make responsible use of these tools and equipment, ensuring their conservation, as if they were their own.

Please note that we are not only referring to equipment for individual use, but to all the equipment that compound Wildlife’s structure, including, for example, the responsible use of a printer, office supplies and toilets’ hygiene items, among others.

FOOD

To make the work environment more pleasant and productive for our employees, Wildlife provides assorted food items daily.

We kindly recommend the sensible consumption of these foods, avoiding any waste. They should be consumed solely within the workplace and at the appropriate facilities.

PROPER USE OF THE NETWORK, INTERNET AND ELECTRONIC MEDIA

Electronic communications and resources are part of our daily routine. Hence, it is important to use them considering Wildlife’s reputation and in a cost-effective manner.

Keep in mind that it is forbidden to use Wildlife’s network to store personal files.

The exchange of messages, via e-mail, and access to the internet for personal matters are allowed, provided no internal rules are contraindicated in such activities and that the procedures used for such conducts do not, in any way, impair the employee’s professional performance.

Harassment and disturbance of other employees, whether through the language, frequency, or size of messages, however, is forbidden.

Any pornographic, distasteful, racially, ethnically, or otherwise objectionable material cannot be watched, exposed, stored on the network, distributed, edited, or recorded through the network’s computer resources.

It is also forbidden to proceed with any attempt to obtain unauthorized access or interfere with the services, server or network of any other employee.

We provide legitimate software programs to all our employees and prohibit any use of deployed software at Wildlife.

All access to the Internet and Wildlife’s network is subject to being monitored, without the need for prior authorization from the employees.

Furthermore, be mindful when showing or mentioning Wildlife, our resources, and information on social media. The messages sent or posted on tools like blogs, Facebook, Twitter, Instagram, or wikis are permanent and easily transferable and them can influence Wildlife’s reputation and relationships.

HEALTH

We want our employees to always be in their best condition. Therefore, if you are not feeling physically or psychologically well, please follow the protocol set out below:

Whenever possible, and subject to your personal judgment, go to a doctor’s appointment to ensure that you are able to work.

If, at the doctor’s discretion, you are not able to perform your work assignments, please request the respective medical certificate, send it to the Payroll Team on the same day, and follow the doctor’s instructions. And of course, do not work on that day (not even from home).

If, by the doctor’s judgment, you are able to work, but you believe that working from home would be the best solution until you feel better (due to contamination risks or for your own comfort), please talk to your leader. Keep in mind that working from home is not possible for all teams.

FINANCIAL RESPONSIBILITY

Financial integrity and responsibility must be core characteristics to every corporation. More than reporting our expense reports accurately and in a timely manner, it is essential to remember that the money we spend on behalf of Wildlife belongs to Wildlife. Every Wildlife employee has the responsibility to ensure Wildlife money is being properly used and allocated, and that the financial records are accurate, complete, and sent to the Finance Team.

If you are not sure on the following topics or Finance processes, reach out to the Finance Team or file a report on the Talk to Us channel.

SPENDING WILDLIFE’S MONEY

Be respectful of the money you spend on Wildlife’s behalf, including in case of reimbursement events. Always check and double-check the receipt to en- sure that the charges are correct. When submitting a refund request, make sure the cost is reasonable, directly related to Wildlife’s business, and accompanied with proper documentation.

On the refund request form or note justifying the expense, include the detailed business purpose and the fiscal note of the expense.

If you aren’t sure if your expense is eligible for reimbursement, ask your manager before submitting the request. Managers are responsible for their direct reports’ expenditures and must review their expenses before approval.

If you receive an extra amount of money or benefit in error from WL that was offered to you incorrectly, report it immediately to your manager or via Talk to us. Do not use company money until you make sure that you are allowed to do so.

THIRD PARTY RELATIONSHIPS

All our relationships are based on honesty, integrity, and transparency, as we believe them to be essential values for building an upright company.

SIGNING A CONTRACT

All business transactions with a third party on behalf of Wildlife must be formalized in writing through a contract, agreement, or any other type of legal doc- ument previously approved by the Legal Team in the Ironclad management system and signed in accordance with the most updated version of Wildlife’s by-laws (by the people who has the delegation of authority to conclude business on behalf of the com-
pany, within the financial cap attributed to them)

HIRING SUPPLIERS

The hiring of suppliers and/or service providers for Wildlife shall take into consideration the following criteria: quality, suitability, reliability, performance, service, technology, price, and the terms and con- ditions proposed. This will require that you request competing bids and benchmarks to guarantee we are getting the best offer. Feel free to reach out to the Procurement Team if you have any questions regarding the procedures for hiring suppliers and/or service providers.

VIOLATION OF THESE PROVISIONS

The violation of any provisions of this Code of Conduct, policies, laws, or standards related to our activities, as well as failure to cooperate with an internal investigation may result in disciplinary measures, such as, but not limited to oral and written warnings, suspension or even the dismissal of the infringing employee.

According to the level of such violation and after the respective investigation is concluded, the Integrity Committee will be responsible for deciding the most appropriate disciplinary measure to each case, among the options described above.

Finally, the use of internal disciplinary measures does not, in any way, restrict the implementation of applicable legal measures to repair any damage caused to Wildlife or its customers, who may also take the appropriate measures for an eventual re- imbursement, including monetary compensation (if applicable).

CONCLUSION