An independent and impartial communication tool, where people inside or outside Valid can report, with full confidentiality, any irregularities and/or inappropriate conduct that violates one or more of the following:

• Valid’s Global Code of Ethics and Conduct
• Compliance Manual
• Integrity Program and its related policies
• Global Anti-Corruption Policy
• Applicable laws and regulations

Reports may be submitted anonymously if desired. To do so, select “no” when asked whether you wish to disclose your identity when filing a report.

Employees: staff members, interns, apprentices, administrators, and board members, regardless of their position or role.

Third parties: contractors, external providers, business partners, distributors, service providers, suppliers, agents, representatives, consultants, specialized commercial agents (e.g., customs brokers), and clients.

Anyone may be reported through the Whistleblowing Channel: employees at all hierarchical levels, board or committee members, sales representatives, business partners, suppliers, and clients.

Contato Seguro, an independent company, is responsible for managing the receipt of reports made through the Whistleblowing Channel. It ensures the confidentiality and anonymity of the whistleblower. Reports are forwarded to the Compliance & Integrity team for investigation and follow-up.

If the report involves someone from this team, the investigation will be carried out by a representative of Senior Management, without the Compliance & Integrity team’s involvement, to avoid conflicts of interest.

Some reports involving members of Senior Management are also forwarded to at least one other Senior Management member. Such cases are overseen by the Legal, Governance, and Controls Department.

If you identify or become aware of any irregularity:

• Visit contatoseguro.com.br/en/valid

• Call toll-free:
South Africa 080 098 0477
China 400 120 0168
Denmark 80 82 60 18
United Arab Emirates 800 0321198
Mauritius 8020490001
India 000 800 9190 269
Indonesia 0018030152025463
Nigeria 0708 060 1097
Singapore 800 492 2631
Taiwan 00801-13-6871
USA 1 (800) 741-8516

• Or contact us by downloading the Contato Seguro app on your mobile device: Google Play or Apple Store

• Acts or suspicions of corruption, fraud, and other irregularities covered by Law No. 12.846/2013 or the Brazilian Penal Code.
• Evidence of illegal or unethical practices that may affect Valid’s reputation or that of its stakeholders.
• Workplace bullying/harassment by leaders, subordinates, or colleagues.
• Sexual harassment, sexual misconduct, or inappropriate sexual behavior.
• Misconduct by Valid’s partners, clients, or related third parties.
• Any type of discrimination (color, ethnicity, origin/nationality, gender, age, sexual orientation, disability, religion, pregnancy, illness, among others).
• Conflicts of interest in supplier hiring, personal relationships, or other matters concealed from Valid that may affect the company’s interests.
• Leakage or misuse of confidential information.

The investigation depends on information such as:

• The fact/event that occurred or is ongoing.
• Approximate date of the occurrence.
• Work unit, department/sector of the occurrence (when possible, include time, nearby cameras, and their numbers).
• Full names of reported and involved individuals (preferably including job title and department).
• Names of people who are/were victims and/or witnesses of the situation.

All reports are investigated and handled impartially and ethically. If additional information is needed to proceed, the investigator will request it via the Whistleblowing Channel. The whistleblower must respond using the protocol number received when submitting the report.

For anonymous reports, communication occurs only through the Whistleblowing Channel (phone, app, or website). If further information is required but not provided, the case will be closed. This does not prevent a new report on the same matter from being filed with complete information.

Certain cases may require external professionals or companies to conduct the investigation. Some matters may also be reviewed by internal committees that assist in determining the best way to handle the report, always upholding confidentiality. Timelines for investigation and resolution may vary depending on case complexity.

When filing your report, you will receive a protocol number. Use this number whenever you wish to communicate with the investigator, provide new facts/evidence, or simply check the status.

Never share your protocol number with anyone!

Do not be afraid to speak up.

Your identity and the reported matter are kept confidential throughout the process. Only those responsible for the investigation and handling of the report will have access to the reported facts. Third parties are only involved if and when necessary, even if a court order requires disclosure.

Valid is committed to maintaining a healthy and respectful work environment, and therefore does not tolerate any form of retaliation against whistleblowers. You will not face persecution or punishment for filing a report, even if it proves unfounded.

We ensure the confidentiality of the investigation process. However, we cannot control what happens if you disclose the information yourself. That is why it is important not to share details with anyone who is not directly involved in handling the case, as doing so could expose those involved and compromise the investigation.