02/02/2022

To our stakeholders:

I am pleased to confirm that Vezzi Lapolla Mesquita Advogados reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Marcelo Lapolla
Manager and Founding Partner

We make reference to Human Rights in our Code of Conduct, which is written and availabe to all employees, suppliers and clients.
We also have a requirement that our business partners and suppliers must follow principles on Human Rights

Internal researches and suggestion box;
Awareness raising or training of employees;
Consultation with stakeholders and affected parties;
Human resource policies and procedures supporting Human Rights

2 researches per year with all employees;
Individual feedbacks with employees
Not one Human Rights case reported. Nonetheless we have an Ethics Channel where stakeholders can report any misconducts. If any is reported, than the case goes to our Thic's Committee, which conducts investigations and may apply sanctions when necessary (warning, suspension or even termination).
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We make reference to Labor Rights in our Code of Conduct, which is written and availabe to all employees, suppliers and clients.
We also have a requirement that our business partners and suppliers must follow principles on Labor Rights.
As a way of ensuring the comfort, well-being and safety of Associates and clients, Vezzi Lapolla Mesquita Advogados adopts a strict quality in relation to its furniture, work equipment and facilities in general, and the Employees must contribute to the maintenance of such conditions, in addition to reporting in case of any problem or risk got that. Periodically, a satisfaction survey is applied to all People Bound, so that their perception of the measures taken by the Vezzi Lapolla Mesquita Advogados;

Internal researches and suggestion box;
Awareness raising or training of employees;
Consultation with stakeholders and affected parties;
Human resource policies and procedures supporting Labor Rights

2 researches per year with all employees;
Individual feedbacks with employees
We have an Ethics Channel where stakeholders can report any misconducts. If any is reported, than the case goes to our Thic's Committee, which conducts investigations and may apply sanctions when necessary (warning, suspension or even termination).

Aware of the importance of exploring the Environment in a rational and sustainable development, Vezzi Lapolla Mesquita Advogados and Related Persons undertake to avoid the waste of natural resources, as well as to preserve the Environment in the best possible way;
All Related Persons must be concerned about responsible disposal of any material, such as paper or plastic, considering the volume of resources used in everyday life.

Permanent recycling campaign. Awareness of lights and air con on after working hours, among others.

2 researches per year with all employees and clients.
We have an Ethics Channel where stakeholders can report any misconducts. If any is reported, than the case goes to our Thic's Committee, which conducts investigations and may apply sanctions when necessary (warning, suspension or even termination).

We started the presentation of our Program by listing The documents that make up the office's Compliance Program are:

• Code of Conduct (Related Persons version), applicable to all employees and the office's Senior Management, applicable to all areas of the office and all hierarchical levels;
• Code of Conduct (Partners version), applicable to the firm's partners, third parties and clients;
• Policy Regulation, document that determines the procedure for creating new policies and the hierarchy between the Program documents;
• Anti-Corruption Policy;
• Partner Hiring Policy;
• Whistleblower Channel Procedure;
• Conflict of Interest Policy;
• Internal Audit Policy;
• Access Control Policy;
• Fee Pricing Policy;
• Expense Approval Policy;
• Communication Policy;
• Training Policy;
• Information Security Policy;
• Privacy Policy..

Such documents are available to all connected persons, on the office network, on the intranet, in printed version at the physical location of the office. The Codes of Conduct can also be accessed on the website and on the Whistleblower Channel. That is, the documents are widely disseminated and easily accessible to all.

In addition to the documents, we highlight that the office has an independent structure from the Compliance area, formed by a Compliance Officer, with exclusive dedication, responsible for executing the demands of the area. The Compliance Officer receives, handles, investigates and forwards the complaints received for deliberation by the Permanent Compliance Committee, independently in the investigation and verification (except in the case of being reported) and reports to the Permanent Compliance Committee its considerations and proposals. She has access to documents from different departments of the company with autonomy and independence and is also responsible for defining and implementing the communication and training plan and for keeping the Code of Ethics and Conduct and institutional policies duly updated.

Finally, it is also important to point out that the Compliance Officer is also responsible for monitoring the Program and for carrying out periodic inspections, by sampling, to identify new risks, detect the degree of efficiency of current controls and ensure full compliance with the Code of Ethics and Conduct.

Communication and training are two essential topics for the proper functioning and effectiveness of the Compliance Program, and, above all, for keeping alive the culture of integrity that we want to see in the office and in our society. Communication and training Both are topics addressed in specific and separate policies.

The compliance area is responsible for the implementation and supervision of the communication plan, by deliberation of the Permanent Compliance Committee. As an aid, we count on The office has a structured communication area, which works together with the compliance area to disclose all our compliance practices in the area to all related people, partners, third parties and customers. The compliance area is responsible for the implementation and supervision of the communication plan, by deliberation of the Permanent Compliance Committee.

Communication is done through the publication and submission of sentences in the context of ethics and integrity; periodical newsletters disclosing the main points of the Compliance Program; availability of the Code of Ethics and Conduct and office policies on the internet, intranet, Whistleblowing Channel and on the internal virtual network, in addition to physical copies of the Code of Ethics and Conduct and office policies available to everyone at reception; dissemination of bulletins to the internal and external public, with topics related to Compliance and Data Protection; holding a monthly Study Group to expose related topics; internal and external campaigns for the dissemination of information and, in some cases, with a solidary content; dissemination of messages on special dates, such as the International Day against Corruption; among others.

As mentioned earlier, the Compliance Officer is responsible for establishing and implementing the office's training plan. Training is carried out periodically, at all hierarchical levels of the firm, including partners. Compliance training is applied to new employees on a monthly basis. Every six months, the leaders (Senior Management), the administrative staff and partners – legal correspondents who provide services to the firm, are trained. Also every six months, new compliance training is applied to all related people, without exception.
Hiring business partners:

Considering the importance of the topic in our day-to-day activities, H has a specific policy in the Compliance Program that regulates the internal procedure for registration, risk analysis and due diligence of third parties, as well as internal procedures and responsibilities for formalizing negotiations, contracting and partnerships.

Each engagement must be permitted by local and foreign legislation, when applicable; it must have a legitimate purpose and be related to the firm's business and commercial activities; must comply with the principles of the Anti-Corruption Law; and the remuneration involved must not exceed the fair market value for the contracted relationship.

The contracts made go through the due diligence procedure, which includes research, consultation of databases, in addition to questionnaires and are classified by risk category, and may be subject to deliberation by the Permanent Compliance Committee.

In the case of contracting or partnership with a legal entity, the company must be regularly established and proven to be reputable, and must be in good standing with its financial, tax and social security obligations.

The contracting applicant linked to the office is committed to ensuring that contracted third parties do not perform, promise or authorize, directly or indirectly, the making of a payment or the delivery of valuables to a government authority, to induce it in a corrupt way. and improper, to take action or make a decision at the governmental level in order to help the firm obtain or retain business.

COMPLAINT CHANNEL

The office has an outsourced Whistleblower Channel, easily accessible, available on the internet to the internal and external public, with the possibility of submitting any type of complaint.

The possibilities of object of complaint are: discrimination or harassment; questions about the Compliance Program; forgery of documents; fraud and theft; information, suggestions and praise; bribery and corruption; violation of the Code of Ethics and Conduct.

It is essential to point out that the possibility of anonymity of whistleblowers and non-retaliation to the whistleblower in good faith is guaranteed. The whistleblower, when making the complaint using the Channel, will receive a protocol number through which he can follow the progress of the complaint.

Relevant topics of complaints received are the object of targeted training, specific guidance or follow-up by office teams.

The whistleblower flow is available to everyone, with defined deadlines and procedures. Also noteworthy is the existence of a specific flow for receiving and handling complaints involving members of Senior Management, the Permanent Compliance Committee and the Compliance Officer.

MONITORING

The Compliance Program is monitored periodically. In addition to the employees being tested monthly, at random, regarding their knowledge of the provisions of the Program, statistical control is also carried out on participation in training and the effectiveness of the measures taken based on the Compliance Program.

Annual audits are carried out to ensure the functionality of the Program and its continuous improvement.