Code of Conduct

1. Core principles

TaxUp's work is guided by five non-negotiable principles:

1. Technical integrity — every tax recommendation is grounded in verifiable legal basis, consolidated case law and precedent from CARF, the STJ and the STF.
2. Absolute confidentiality — professional secrecy over client information (Art. 7, II and XIX of Law 8.906/1994 — the OAB Statute).
3. Independence — the technical autonomy of the responsible attorney, free from undue interference by third-party interests.
4. Transparency — clear communication on scope, timelines, costs and risks of the engagement.
5. Commitment to legality — work confined to lawful tax planning (tax avoidance). We decline tax evasion, sham transactions or aggressive savings schemes lacking genuine business purpose.

2. Adherence to the OAB Code of Ethics and Discipline

TaxUp fully adheres to the Code of Ethics and Discipline of the Brazilian Bar Association (OAB) (Resolution 02/2015) and to Provision 205/2021 on legal advertising.

As a result, TaxUp's communications:

• Do not promise outcomes in specific cases;
• Do not solicit clients in a vulgar, commercialized or intrusive manner;
• Do not use unverifiable superlatives ("the best", "leader", "exclusive");
• Do not draw nominal comparisons with competing firms;
• Do not convey misleading information about services or outcomes.

3. Conflicts of interest

TaxUp follows a formal process to identify and manage conflicts of interest before accepting a new engagement:

• Prior screening for potential conflicts with existing or former clients;
• Refusal to act in cases of an unresolvable conflict;
• Express consent of the parties involved where the conflict can be resolved;
• Operational segregation (Chinese wall) where applicable.

4. Anti-corruption and anti-bribery

TaxUp and its staff do not offer, promise, authorize or accept undue advantages to or from public or private agents, in compliance with:

• Law 12.846/2013 (Brazilian Anti-Corruption Act);
• Law 8.429/1992 (Administrative Improbity Act);
• The U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, where applicable to international clients.

We work with partner foreign firms in observance of local regulation.

5. Anti-money-laundering

TaxUp observes the obligations arising from Law 9.613/1998 (the Brazilian Anti-Money-Laundering Act) and the regulation applicable to the legal profession, including:

• Know Your Client (KYC) due diligence;
• Due diligence on the source of funds where applicable;
• Refusal of transactions showing signs of illegality.

6. Diversity, equity and inclusion

TaxUp:

• Does not tolerate any form of discrimination based on gender, race, sexual orientation, religion, age, disability or social background;
• Promotes an inclusive and safe professional environment;
• Actively combats moral and sexual harassment;
• Encourages diversity in hiring and career development.

7. Environmental and social commitment

TaxUp:

• Adopts digitalization practices and reduces paper use;
• Supports pro bono initiatives in causes aligned with its technical work;
• Encourages collaboration with professional associations (OAB, IBPT, IBDT, ABRADT).

8. Whistleblowing channel

Suspected violations of this Code of Conduct can be reported confidentially:

Email: contato@taxup.com.br (subject: "Compliance — confidential report")

We guarantee:

• Confidential handling of the report and the reporter;
• Impartial and timely investigation;
• Protection against retaliation;
• Communication of the outcome to the reporter where possible.

9. Applicability and updates

This Code of Conduct applies to TaxUp's consultants, attorneys, staff, interns, partners and suppliers. Non-compliance may result in internal disciplinary measures and, depending on severity, in reporting to the OAB and the competent authorities.

The Code may be updated periodically. The version in force is always the one published on this page.