1. Purpose

The Code of Conduct is designed to guide the actions and behaviors of all Wise employees, whether within the Company or with Third Parties. At Wise, we value clear and widely communicated principles. These principles guide our actions, inspire our behaviors, and are the foundation for this code, as well as various Company Guidance Materials.

This code does not aim to predict every situation that may occur in daily life. If you find yourself in a doubtful situation or one that may conflict with the company’s principles or situations from this code, it is the duty of any employee to seek guidance from their manager, HR, or company management to make the decision together. Above all, we aim to do the right thing, within the law, ethics, and company principles.

2. Responsibilities

Wise is committed to acting ethically, with integrity and transparency, in compliance with all applicable laws.
All Employees must understand and commit to fully comply with Wise’s Business Conduct Code and must be aware that deviations from its provisions, whether by action, omission, or complacency, harm society, may violate laws, and damage Wise’s image and reputation.

It is expected that each employee will act, encourage other employees, and be proactive if they identify any deviation from this code or the company’s principles. Any Employee who does not adhere to such standards and restrictions is acting outside the scope of their occupation, responsibility, or activity.

Employees who have questions related to applicable law, this Code, other Company Guidance Materials, or who are unsure how to act in specific situations should consult HR or the company’s management for guidance.

2.1 Compliance with laws

In executing their processes, Wise Employees must respect and obey applicable laws and regulations.
Furthermore, Employees must comply with internal rules and regulations applicable in a particular situation. These internal rules are specific to the Company and may go beyond what is required by law.

2.2 Confidentiality

Wise is committed to the appropriate use of information and assets. Employees must protect Wise’s assets, both tangible and intangible. Wise’s assets include, among others, facilities, machinery, equipment, vehicles, furniture, securities, data, information such as brands, knowledge, market information, internal processes, formulas, strategies, and intellectual property. Each Employee is responsible for the proper use of these resources, which must be used exclusively to perform the Company’s responsibilities. If there is any doubt when sharing information with third parties, consult your manager or HR channels.
Wise is committed to protecting Personal Data, based on applicable laws and regulations relating to the protection of Personal Data. Employees or Third Parties acting on behalf of the Company and who need to access or handle Personal Data of Wise Employees or others must act in strict compliance with applicable laws and regulations relating to the protection of Personal Data.

The data, records, and information produced by Employees in the performance of their work responsibilities are the exclusive property of the Company. Employees and partners who have access to Wise information must preserve and ensure the confidentiality of the information, including information that may be useful for investment decisions regarding their business partners.

Furthermore, employees, when participating in any network or social media, whose activity may be linked to the name of Wise, must keep in mind that actions practiced in these channels can negatively affect the reputation and interests of the Company, therefore it is expected that they take the following precautions:

• Remember that your statements, posts, and comments are not anonymous.
• Do not share confidential data or any information that may violate the rights of Wise.

2.3 Health, Safety, and Environment

Wise is committed to compliance with all applicable laws and industry standards on health, safety, and the environment. This means that the Company is committed to the safety of Employees at the workplace, and to preventing environmental pollution and the impact of its operations outside the company gates. Employees must be aware of and comply with requirements related to environmental protection, workplace safety, their own health, and the health of other Employees, and others affected by the company’s business activities.
The use of alcoholic beverages and drugs at the workplace is prohibited, as well as the entry into Wise facilities of people intoxicated or under the influence of substances that alter their behavior and may affect the safety and activities of others.

Employees should not prevent the entry or hinder the work of inspectors or auditors at Wise facilities, when occurring during business hours.

2.4 Child labor and forced labor

Wise respects labor legislation applicable to its activities. Our human resources policy reaffirms our commitment to this issue, therefore child labor, practices that characterize forced labor and/or analogous to slave labor, are not permitted or tolerated in Wise’s activities and in the activities of business partners in its value chain.

3. PEOPLE MANAGEMENT

3.1. Opportunities

We respect and value the diversity of stories and the trajectory of each individual and understand that their entry and progression in the company should be solely based on their professional merit. Everyone should have equal opportunities and evolve according to their professional performance. This is in our principles of Diversity and Integrity and we will not tolerate deviations.
Therefore, the procedures of recruitment, selection, defining responsibilities, opportunities for development and training, performance evaluation, determining compensation and benefits, and other practices, should be executed with impartiality and meritocracy, based on the principles of the company, with strong commitment to honest and ethical, transparent, and fair action.

3.2 Harassment and Discrimination

We value environments rich and diverse in terms of stories, beliefs, and preferences.
We commit to respecting the privacy and personal rights of all Employees, and we are dedicated to cultivating a positive work environment for all those who recognize and value individual contributions within Wise.

Therefore, Employees must not commit or allow any action that characterizes discrimination based on origin, nationality, religion, race, sex, age appearance, disability, social class, political views, sexual orientation, or any other topic that is not strictly professional. All people must be treated with respect and education and we encourage that inappropriate behaviors be exposed anonymously or identified.

Harassment of any nature, such as moral, verbal, sexual, psychological, and economic harassment, is not tolerated at Wise. Also, situations that constitute disrespect, violation of privacy, intimidation, or threat in the relationship between Employees, regardless of their positions and responsibilities, are not tolerated.

Wise does not tolerate behaviors such as insults, sexually explicit content, inappropriate use of personal information, actions that contribute to the creation of a hostile and intimidating environment, isolating or not collaborating with colleagues, or spreading malicious or offensive rumors.

The above topics are against the law, the principles of Wise, and do not contribute to the creative and open environment that we believe in for the Company.

4. Relationship with Stakeholders

4.1 Relationship with Third Parties

Wise expects its Third Parties to conduct their business in compliance with all applicable laws, including, industry codes and Wise’s ethical values. The use of a Third Party to perform any illegal act, including offering, promising, inducing, giving, or authorizing, directly or indirectly, an improper payment is strictly prohibited. To be clear – Wise must never use Third Parties to do something that would be prohibited by applicable law, by this Code, or that is against the principles or any guidance materials of the company.
As the actions of Third Parties can affect the reputation of Wise, the quality of our products, and our legal liability, Wise takes seriously the retention and oversight of Third Parties. All Third Parties are subject to due diligence review, and there must be written agreements requiring the Third Party to act in accordance with our standards of ethics and integrity and comply with all applicable laws. Third Parties must be chosen based on their qualifications to provide necessary goods or services. No Third Party should ever be hired to induce or in reward for any improper advantage for Wise.

All Employees who hire or supervise Third Parties are responsible for ensuring that these individuals or entities understand the norms and expectations of Wise and the applicable laws. Employees must never ignore information that suggests possible corruption on the part of Third Parties.

4.2 Relations with Public Officials

Consistent with the values of ethics, integrity, and transparency of Wise, Employees must interact with Public Officials in an ethical and transparent manner and in accordance with laws, regulations, and best practices applicable.
In many jurisdictions, these interactions are restricted and/or highly regulated. Employees must act according to the same principles listed in the code of conduct and always interacting in at least two people. Considering the high reputational risk, if the relationship with a public official is significant, one should seek guidance material with HR.

4.3 Competition / Antitrust

Wise is committed to complying with all applicable antitrust and competition laws. Antitrust and competition laws regulate, among other things, relationships between competitors, pricing policies, restrictions on licensees, rebates and discounts for customers.
No Employee should enter into any agreement, plan, or scheme, express or implied, formal or informal, with any competitor concerning prices, bids, production, distribution, terms or conditions of sale, territories or customers. Employees are prohibited from exchanging ideas or discussing with a competitor about prices, terms or conditions of sale or service, bidding or bidding conditions, credit conditions and billing practices, terms and conditions offered by suppliers, profit or profit margin, costs, business plans and investments, capacity levels and expansion plans, warranty terms or any other competitive information from Wise.

All Employees, especially those involved in purchasing and commercial areas, have the responsibility to ensure that they know the competition and antitrust laws applicable. In case of doubts, direct Managers should be consulted to advise and offer training on the subject.

5. Conflicts of Interest

A conflict of interest occurs when the personal interests of an employee, a third party, or a close relative have the potential to interfere with their ability to judge impartially, expected in their responsibility, or in the interests of Wise.
If a Conflict of Interest situation occurs or if an employee faces a situation that may involve, appear or lead to a Conflict of Interest, the employee should report it to their direct manager or HR to resolve the situation in a fair and transparent manner.

6. Accounting Records

Employees of Wise should not engage in actions that may characterize fraudulent conduct in the preparation of financial reports / statements of Wise. Actions of this kind can lead to disciplinary sanctions and may, eventually, result in legal sanctions provided for in applicable legislation.
Similarly, Wise is committed to maintaining its accounting records accurately in order to meet the principles and rules of good governance and legal practices as well as regulatory requirements.

7. Bribery and Corruption

Wise condemns any form of bribery and corruption.
Wise does not give or receive, directly or indirectly, bribery or other improper advantages to gain commercial or financial gains, whether in the public or private sector.

Employees may never, directly or through intermediaries, offer, give, or receive any gift or payment that is or may be considered bribery. Any request or offer of bribery must be rejected and immediately and reported to leadership and HR.

Employees also should not perform any action or behavior that may give the impression or generate suspicion that inappropriate conduct is being carried out or attempted.

It should be clear to Employees that if a bribery action is characterized to influence the decision of a third party, in the public or private sector, it may lead to disciplinary sanctions and even criminal implications.

8. Political Activities

Political Contributions include, but are not limited to, financial contributions, or provisions of goods or services (e.g., transportation, meeting space/facilities, printing or office services), to political parties, candidates, or their teams. Wise must not make Political Contributions even if allowed by local legislation. Thus Employees are prohibited from promising, offering, authorizing, or giving, directly or indirectly, Political Contributions to political parties or to candidates for public office with resources or in the name of Wise.
Wise does not adopt a partisan position, and Employees are prohibited from linking Wise to partisan activities. Similarly, Employees may not engage in partisan activities or solicit votes, directly or indirectly, on behalf of or using the resources or facilities of Wise.

Employees who choose to run for political or public office, or who wish to express themselves politically and publicly outside of Wise, must not use the advantages of their position or any resources or means of the company. These individual activities must be dissociated from Wise.

9. Money Laundering

Wise does not tolerate acts of Money Laundering. Employees must comply with all laws, regulations, and regulations addressing Money Laundering and the financing of illegal activities.
Wise should only do business with reputable Third Parties involved in legitimate activities and whose resources come from a legitimate source.

Gifts, Presents, Entertainment, and Hospitality
Wise Employees must ensure that any gifts or hospitalities offered or received meet the following criteria:

• There must be a justified and proportional business relationship;
• The values of gifts, entertainments, and hospitalities must not exceed the limit of R$300 in a 1-year period;
• The values of business lunches must follow the values established in Wise’s reimbursement policy.
• The gifts and hospitalities received above this value must be refused or have the due approval from HR
• The gifts and hospitalities received with the intention of influencing business decisions must be refused and reported to HR or handed over to HR.
• Offering and receiving gifts, entertainment, and hospitality from/to Public Officials is not allowed.

If a gift exceeding the financial limit set by Wise is offered, Employees should politely refuse it and present Wise’s rules. In exceptional situations, when such gifts have to be accepted to avoid causing uncomfortable situations or in cases where return is unfeasible, Employees should forward the gift to HR who will take measures to have the gift donated to a charity or used for a raffle among Employees.
Furthermore, Wise Employees should not offer gifts, hospitality, or other favors that could influence their business decisions or create an obligation to do something in return.

In specific campaigns promoted by the company, Wise may occasionally ask Commercial teams to inform suppliers about the opportunity to contribute, without implying any obligation.

11. Penalties

Any Professional who violates the ethical principles of the Company, or its Code of Ethics, will be subject to disciplinary measures, which may result in dismissal and legal proceedings in case of violation of the law.
The corrective actions will depend on the severity of the violation and the relevant circumstances of the fact, including, but not limited to: (i) verbal or written warning; (ii) suspension; and (iii) dismissal with or without just cause.

12. Reporting of illegal or non-compliant conduct in relation to this Code

Employees must report any practices or actions that may be considered inappropriate in relation to this Code or illegal to their direct managers, if the employee deems it necessary the report can be made confidentially and anonymously through the whistleblowing channel. Employees can report such practices through the “Speak Up” channel, available on the Wise website. All good faith reports and complaints will be properly investigated and the whistleblower of good faith is guaranteed no retaliation.
Additionally, all direct managers who are aware of practices or actions above, must make the appropriate record in the channel.
Each Employee may be required to cooperate in internal investigations of misconduct and unethical behavior.

GLOSSARY

“Public Agent(s)”: any individual acting in an official function or exercising a public function for or on behalf of: (i) a national, regional or local government (whether in a legislative, administrative, or judicial capacity); (ii) an agency, department or instrumentality of a national, regional or local government; (iii) a government-owned or government-controlled company or enterprise, or (iv) a public international organization, such as the United Nations, the World Bank, or the World Trade Organization. In addition, any political party, party official, candidate for political office or any individual acting in an official function on behalf of any of the above
“Conflict of Interest” or “Conflicts of Interests”: occurs when the interest of an individual, or the interest of a Relative of that individual, is in conflict with the interest of Wise, interfere with (or appear to interfere with) their ability to judge objectively the execution of their Company responsibilities, or when a Member or their Relative receives undue personal benefits due to their position in Wise.

“Political Contributions”: include, but are not limited to, monetary contributions, or the provisions of goods or services (e.g.: transportation, meeting space/facilities, printing or office services), to political parties, candidates or their officials.

“Personal Data”: any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Employee(s)”: employees who work at Wise, at all levels, including executives, counselors, directors, interns and trainees (as applicable in geographic locations).

“Money Laundering”: a process that seeks to mask the nature and source of money associated with an illegal activity, introducing these funds into the economy, in a way that appears legitimate and/or whose origin or owner cannot be identified

“Company Guidance Materials”: the Guiding Documentations, support documentations, trainings, and other guidances adopted by Wise.

“Third Party(ies)”: any individual or legal entity acting on behalf of, in the interest of, or for the benefit of Wise, provide services or supply other goods, as well as business partners who provide services to Wise, directly related to obtaining, retaining, or facilitating business, or for the conduct of Wise’s affairs, including, without limitation, any distributors, agents, brokers, customs brokers, intermediaries, supply chain partners, consultants, resellers, contractors, and other professional service providers.