MITRE

COMPLIANCE

COMPLIANCE PROGRAM

At Mitre Realty, we conduct our business with ethics, integrity, transparency, and respect across all our relationships, actions, and decisions. Our Compliance Program focuses on continuously improving our management, control, and governance practices while strengthening our risk management culture.

Code of Ethics and Conduct

Our Code of Ethics and Conduct sets out the guidelines, standards of behavior, and principles expected of all employees, supporting the continuous and sustainable growth of our business while maintaining the quality of our products and ensuring customer satisfaction.

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Supplier Code of Ethics and Conduct

Our Supplier Code of Ethics and Conduct sets out the standards of behavior and guidelines that our suppliers are expected to follow, in line with Mitre's values and our commitment to ethical and transparent business practices.

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Privacy Policy

Mitre is committed to protecting the data and privacy of all parties with whom we interact. To support this commitment, we have established our Data Governance and Privacy Policy, which, in accordance with Brazil's General Data Protection Law (LGPD), provides guidelines and principles for the processing of personal data.

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Ethics Channel

The Ethics Channel is a dedicated channel for reporting ethical misconduct, violations of the Code of Ethics and Conduct, or breaches of any other Mitre policy. It is available 24 hours a day to all employees, suppliers, and members of the public. The channel is managed by an independent and impartial third-party company, with trained professionals qualified to receive and handle all types of reports. All cases are handled with strict confidentiality, whether reports are submitted anonymously or with identification, and no individual who makes a report in good faith will face retaliation.

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Privacy Channel

To ensure transparency for our customers, employees, and suppliers, we have created a dedicated Privacy Channel to address all matters related to Brazil's General Data Protection Law (LGPD – Law No. 13,709/2018).

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