CODE OF

CONDUCT

Uninter

NO SHORTCUTS.

ALWAYS FORWAD!

SUMMARY

PAG. 04 MESSAGE FROM THE CHAIR

PAG. 06 CORPORATE IDENTITY

PAG. 09 PRINCIPLES OF THE UNINTER GROUP

PAG. 10 WE BELIEVE

PAG. 11 SCOPE AND APPLICATION

PAG. 14 AIMS OF THE CODE OF CONDUCT

PAG. 15 ASSET, LABOR AND LABOR HEALTH SECURITY

PAG. 18 INFORMATION SECURITY AND CONFIDENTIALITY

PAG. 22 ADEQUATE CONDUCTS

PAG. 31 CONFLICT OF INTERESTS

PAG. 34 COMPLAINT CHANNEL

PAG. 35 ETHICS, RISKS AND COMPLIANCE COMMITTEE

PAG. 36 REMEMBER! IT IS PROHIBITED...

PAG. 37 ACKNOWLEDGEMENT OF RECEIPT AND AGREEMENT

PAG. 39 GENERAL PROVISIONS

MESSAGE

FROM THE CHAIR

Prof. Wilson Picler

President and founder of Uninter Educacional

Some say, on the grapevine, that the world é belongs to the "smart", to those who "get along"

and take advantage of everything. In fact, this is a big

lie. The world does not, and never has, belonged to

the "smart". The world belongs to honest, simple and

true people. The "cleverness" based on ripping

people off only corrupts and destroys, while acting

with honesty ennobles the soul and elevates true

values.

Honesty is guided by ethics and straight conduct.

It forges and builds future generations, edifies and

dignifies the history of our civilization.

The Uninter Group has been the result of the daily

work of thousands of employees for almost 25 years.

People from all backgrounds, social classes and

places in Brazil. There are more than 800 centers in

700 cities, including the United States. We serve 250

thousand active students and we have already trained

more than 500 thousand people. We have

approximately 400 undergraduate, graduate,

master's, doctorate and extension courses in the face-

to-face, semi-face-to-face and distance courses.

4

If today we have the respect of the whole

country and we are a reference in distance

learning (EAD) - we have the best virtual

platform and several of our courses have the

highest score in MEC -, it is because we

cultivate real values within our company, as

ethics, love of neighbor and honesty.

All of this was achieved without “cleverness”,

only with work, togetherness, creativity and

motivation to do even better. We always seek to

innovate and give our students the best support

materials, as well as the best teachers and

courses, so that they leave here prepared for

life and success.

Our commitment to humanity is our mission.

And you, our employees, suppliers and

partners, are great agents of this transformation.

Our Code of Conduct is like a compass: it

serves to guide and preserve us. Our north is

work and respect.

Come together. We are all Uninter.

5

COPORATE IDENTITY

The corporate identity of the Uninter Group is made up of four

categories: business (with which we operate); mission (the reason

for our existence in the market and in society); vision (purposes and

objectives to be achieved); and values (ethical conduct and

consistent with the ideals of our brand). Through them, we seek to

guide the work and the definition of the company's strategies. The

corporate identity must guide the actions of everyone who is part of

the Uninter Group on a daily basis.

Business

Education.

Mission

Develop and transform people through education.

Vision

Be recognized as an organization of excellence for

study, work and investment.

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7

8

VALUES

Respect for people

People are the raison d'être of our business.

We act with a view to inclusion, well-being,

development and personal and professional transformation and

with authority and responsibility.

Integrity Act with honesty and equity.

Responsability Commitment to ethical, moral and legal conduct.

Excellence Unremitting search for quality and innovation in everything we do.

PRINCIPLES OF THE

UNINTER GROUP

Dignity, zeal, effectiveness and awareness of

moral principles must guide the Uninter

Group's employees in the exercise of their

duties, in order to guarantee behaviors aimed

at preserving the company's image.

The Uninter Group's products and services

are expected to be offered with quality, within

ethical and integrity principles, with the aim of

achieving the company's vision: to be

recognized as an organization of excellence

for studying, working and investing.

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WE BELIEVE

We believe that education improves people's lives. Thus, we

assume the responsibility of offering an inclusive and high quality

education at affordable prices - both in Brazil and internationally.

Our brand seeks to obtain recognition and excellence in study,

scientific development, work and investment at international

levels.

We invest in the personal and professional development of our

employees. We encourage self-development, recognizing merits

and valuing the results produced, with fair and adequate

remuneration, in favorable environments. All of this sharing mainly

experiences and knowledge, as well as giving the employee

freedom to make suggestions and complaints.

We also value our suppliers and business partners. Commitments

to ethical, moral and legal conduct are the basis of our relations

with people and institutions.

In addition, we recognize our environmental responsibility and

support inclusive and voluntary actions, encouraging civism and

solidarity in all the communities in which we are present.

We use the most current technologies, promoting research and

academic extension - something that is in our DNA. We optimize

all management and educational processes to ensure the

sustainability of our business and the quality of the services we

offer. All of this to ensure a fair reward for our students,

employees, partners and shareholders and for society as a whole.

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SCOPE AND

APPLICATION

The Code of Conduct applies to everyone who works for the

companies of the Uninter Group, including their directors,

employees, interns and young apprentices, regardless of the

type of employment.

All those linked to the Uninter Group must guide their

conduct and behavior in this Code, both in their work

relationships and in the conduct of the company's business,

in order to promote and disseminate the culture of integrity in

all environments of the organization.

The Code of Conduct also extends to suppliers, service

providers, business partners and third parties who have a

relationship with the Uninter Group, regardless of their

relationship.

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ARAUCÁRIAS Unit

CORPORATE Unit CAMPO LARGO Unit

13 DE MAIO Unit MOSSUNGUÊ Unit

DIVINA Campus

GARCEZ Campus

CIC Campus

TIRADENTES Campus CARLOS GOMES Campus

AIMS OF THE

CODE OF CONDUCT

Make it clear that the exercise of professional activity

in the Uninter Group has the mission of developing

and transforming people through education,

assuming, therefore, adherence to the ethical and

conduct rules provided for in this Code.

Establish rules inherent to directors, employees,

interns and young apprentices, regardless of the type

of employment.

Preserve the image and reputation of all those

professionally linked to the Uninter Group, whose

conduct must be in accordance with the rules

established in this Code.

Avoid the occurrence of situations that may give rise

to conflicts between the individual interest and the

interests and objectives of the Uninter Group.

Create a consultation mechanism designed to enable

the prior clarification of doubts regarding ethical

behaviors and standards of conduct expected by the

Uninter Group.

Give greater transparency to the activities of each

employee, especially those related to public agents,

considering that they can put the Uninter Group's

business at risk.

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ASSET, WORK AND LABOR HEALTH SECURITY

The Uninter Group maintains security procedures for

recognizing the importance of protecting property assets against

intentional losses, theft and robbery, guaranteeing actions that

ensure the continuous improvement of processes and services,

preserving the safety of employees, students and third parties.

Preventive tactics range from physical and electronic barriers

to access control for people and vehicles, in addition to safety

standards for employees, teachers, students, visitors and

service providers.

The use of the badge is indispensable in any dependency of

the institution, in situations where the employee is representing

the institution and in external visits, such as meetings with

suppliers or technical visits.

The disappearance of assets, private or owned by the Uninter

Group, must be immediately reported to the manager of the

employee who noticed the occurrence of the fact, as well as to

Property Security. Likewise, employees who find objects that

have been forgotten by colleagues, students or visitors on the

institution's premises must hand them over to Property Security.

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BASIC RULES FOR PROTECTION OF ASSETS AND PERSONS WHO CIRCULATE IN THE DEPENDENCIES OF THE UNINTER GROUP

• It is up to the employee to keep their belongings in a

safe place, keeping their drawers and/or lockers

locked.

• The Uninter Group is not responsible for valuables or

personal equipment brought to the corporate

environment.

• Employees are prohibited from bringing electrical or

electronic equipment to the corporate environment,

such as a refrigerator, heater, microwave, fan and

coffee maker.

• In places where there is indoor parking, spaces are

available in accordance with internal policies, with

spaces for people with special needs and the elderly

being preserved, as determined by law.

• The maximum speed limit on company premises and

parking lots is 10 km/h.

• The employee must respect the traffic signs, as well

as the guidelines of the Property Security area.

• Employees or visitors who make use of the internal

parking must park their vehicle backwards (car,

motorcycle, bicycle) only in the permitted places,

using the space of only one parking space.

• It is not allowed to obstruct side passages and central

rows in parking lots. 16

The Uninter Group is committed to providing a

safe and healthy work environment in its units

and to its visitors, by valuing health, safety and

quality of life. The Uninter Group ensures

compliance with the processes and procedures

in the Health and Safety areas.

It is the employee's duty to communicate any

threat to the physical integrity of people on the

institution's premises. The communication must be

forwarded to the Specialized Services in Safety

Engineering and Occupational Medicine (SESMT)

area or to a representative of the Internal Accident

Prevention Commission (CIPA) of your unit.

For areas and activities where uniforms and

protective equipment are mandatory, the

instructions for use and conservation must be

respected, without exceptions.

Employees using a fleet vehicle must observe

the safety rules established in the Fleet Use

Policy, available on the intranet.

The Uninter Group values and encourages its

employees to maintain healthy habits and a

well-being environment. Therefore, the use and

entry of legal or illegal narcotic substances into

the company's facilities is expressly prohibited.

Smoking is prohibited in its premises, in

compliance with the legislation in force.

The Uninter Group repudiates any form of

physical or moral violence. The carrying of

weapons on its premises is prohibited, with the

exception of qualified and designated

professionals for this purpose.

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INFORMATION

SECURITY AND CONFIDENTIALITY

INFORMATION SECURITY

Information is any flow of communication or representation of

knowledge, such as data, facts and opinions, conveyed in any

medium or format (for example, textual, numerical, graphic, narrative

and audiovisual information).

Information Security aims to preserve the properties of confidentiality,

integrity and availability of information, not limited to computer

systems, electronic information and/or storage systems, including

physical documents and/or paper records.

Confidentiality ensures that information is not made available or

disclosed to unauthorized persons, entities or processes. Integrity, in

turn, prevents unauthorized modifications to software, hardware or

data, so that they remain internally and externally consistent.

Availability ensures that authorized users gain access to information

and corresponding assets whenever necessary.

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CORPORATE RESOURCES

The various resources that are made available to employees for the

exercise of their functions, such as computer/notebook, printer,

telephone (landline and mobile), internet and vehicle/chartered

transport, must be used with caution exclusively for professional

purposes, that is related to the institution's activities. It is everyone's

duty to ensure the conservation of these resources, protecting them

against losses, damages and deviations.

All files, documents, communications and information (digital or

electronic) originating and/or transmitted by systems and technological

means made available by the company are property of the Uninter

Group, such as corporate e-mail, landline and corporate cell phone.

Thus, the Uninter Group monitors and inspects the use of all equipment,

electronic or digital, at any time, without the need for prior notice.

E-MAIL

Corporate e-mail should only be used to deal with professional

matters related to the job's activities. It is a work tool and a means

of professional communication, therefore, it is under continuous

monitoring.

TELEPHONE

When using the corporate telephone, employees must be objective in order

to avoid long calls. For private calls, the rule of thumb is common sense: use

only when necessary and be brief.

PASSWORDS

The passwords for accessing the systems are individual and non-

transferable. The loan, sharing or disclosure of user and password is

prohibited.

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CONFIDENTIALITY

É The external disclosure or the use of sensitive, confidential, strategic

and privileged information about the Uninter Group with a deviation in

purpose or for the benefit of itself or third parties is prohibited.

All directors, employees and third parties who have a relationship with

the Uninter Group have a duty to protect the information related to the

Group, even after the end of their professional relationship.

Confidentiality also applies to the disclosure of the Group's strategic

and confidential information in academic works, theses and

dissertations (authored by the employee or third parties), which may

only contain information that has been officially disclosed by the

company to the external environment. However, works of interest to

the Group may contain certain information, as long as they have been

previously approved, in writing, by the management of the involved

areas and by the press office.

To deliver a lecture or similar on behalf of the Uninter Group and

to present internal information about the Group, the employee

must have the approval of his/hers immediate superior (manager

and/or director).

PERSONAL DATA PROTECTION

É All employees are responsible for the use, custody, security and storage

of personal data, in order to guarantee both their own protection and the

protection of students, customers, suppliers, shareholders, service

providers and business partners.

The Uninter Group is committed to good information security governance

practices and the privacy of personal and sensitive data, in compliance

with the General Data Protection Law (LGPD).

The legislation is based on several values, such as respect for

human rights, privacy, freedom of information and the inviolability

of intimacy, honor and image.

20 INTELLECTUAL PROPERTY

The ideas for improvement and innovation of employees in relation to the

Uninter Group are the sole and exclusive property of the Institution,

regardless of the channel used until its effective implementation.

SOCIAL MEDIA BEHAVIOR

The Uninter Group respects the individuality and freedom of expression

of its employees. However, the publication on social media, even if

personal, of any statements on behalf of the Group that violate its image

or that contain confidential and privileged information is prohibited.

This prohibition extends to the use of technological resources made

available by the Uninter Group (cell phone, notebook, among others) to

share, use, obtain, store or elaborate content that contains pornography,

apology for crime, racism, prejudice of any character, or that causes

damage to third parties, even if exclusively moral.

Employees are advised to exercise prudence and caution when speaking

on the internet, as employees who may be involved in negative

publications to the image or reputation of the Uninter Group may be held

responsible under the terms of the law, even though the publications

have taken place in personal profiles.

For more information, access the Policy on the Use of Resources and

Technological Information, available on the intranet.

PHOTOS AND FILMING

Any type of broadcasting or capture of audio or images (photos, footage

or recording) of employees or students, with the exception of promotional

or institutional materials, promoted by the Marketing Department is

strictly prohibited.

BRAND USE

The use of brands, logos, insignias and other signs of the Uninter Group

can only occur with the prior authorization of the Marketing Department,

always respecting the Brand Manual, available on the intranet.21

ADEQUATE

CONDUCTS

COMPLIANCE WITH LEGAL PRINCIPLES

All employees, regardless of the position

they occupy, must comply with the

principles of this Code, the laws and

regulations applicable to the Uninter

Group, as well as its internal policies.

KNOWLEDGE AND COMPLIANCE

WITH INTERNAL RULES

The Uninter Group's Code of Conduct,

policies and standard procedures, as well

as information and internal changes, are

posted on the intranet.

The Uninter Group's Code of Conduct

can also be consulted on the website

itself, available for access by both internal

and external audiences.

It is essential that all employees carefully

read the information and documents

made available on the company's

communication channels, periodically

accessing the page to keep up to date.

EQUAL OPPORTUNITIES

The Uninter Group respects diversity and

is committed to ensuring equal

employment opportunities for all people,

regardless of gender, race, religion,

political or sexual orientation, disability,

age or any other condition. 22

ACCESSIBILITY

Whenever possible, the Uninter Group will work to offer all the tools and

conditions necessary for employees to exercise their activities.

It is responsibility of the People Management department to assist

employees who need any support in terms of accessibility.

AUTHORITIES

It is the limit of competence and authority assigned to the employees and

administrators of the Uninter Group, in line with the position exercised

and with their duties and responsibilities. Its objective is not only to

prioritize organizational decisions, but also to determine the approval of

investments, payments, generation of costs and expenses and other

decisions involving budgetary and financial resources.

It is the responsibility of all employees to conduct their actions in

accordance with the limits established and indicated in the specific

policies of each process.

It is strictly forbidden to split or subdivide amounts in order to adjust

levels of approval to levels other than those applicable to the total

amount.

SUSTAINABILITY

Sustainable attitudes, such as the correct disposal of garbage and the

conscious use of resources (water, energy, paper, printer ink, among

others), are part of the philosophy of the Uninter Group, and the top

management should reinforce the culture of preserving the environment

with the employees, students, business partners and suppliers.

CORPORATE LABEL AND CLOTHING

The Uninter Group emphasizes the importance of clothing being consistent with the corporate and academic environments.

Dressing properly does not mean giving up comfort, nor individual style, but it is essential to always be in appropriate clothes to represent the Uninter Group in front of customers, students, suppliers and business partners. It is recommended to avoid exaggeration so that the clothes do not

overlap with your competence. Employees should seek out the People

Management department if they have any questions about the

appropriate clothing for the Uninter Group environments.

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ATTENDING MEETINGS

Meetings must be productive and conclusive - and respecting

them is essential. We share the following guidelines on how they

should be conducted in the Uninter Group:

• The employee must be punctual at meetings.

• The use of mobile phones, notebooks and or other electronic devices should be avoided in activities that are not linked to the functions performed at the Uninter Group.

• The distribution of business cards must be done with common

sense.

• When you are invited, only invite other people if you agree with the meeting organizer.

• Understand the scope/objectives of the meeting and get ready.

• Organize meetings in advance so that the public can

contribute effectively.

• Be punctual as a participant. As an organizer, be punctual about the start and end of the meeting.

• Before scheduling a meeting, check if there are no other ways

to address the topic.

• Do not invite people just for the sake of inviting.

• Meetings must be objective.

• Every meeting must have a record, by means of minutes, describing what has been defined, such as deadlines and responsible for each task.

• Discuss ideas, but keep your mind free of any filter or

censorship.

FINANCIAL AND ACCOUNTING RECORDS

The financial and accounting records must fully and accurately

reflect the operations of the Uninter Group: their bookkeeping

must be carried out in accordance with current legislation and

accounting principles, and must be supported by appropriate

documentation.

Inappropriate, ambiguous or fraudulent accounting entries, as

well as any other accounting procedure, technique or artifice that

may conceal or cover up illegal payments, or that aim at fraud or

manipulation of any degree, are prohibited.

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TRAVEL AND REPAYMENT OF EXPENSES

Travel and commuting to work must be justified and previously

approved by the respective board. All employees who need

reimbursement must observe the respective policies, both available on

the Intranet.

HARASSMENT AND DISCRIMINATION

The Uninter Group repudiates any form of harassment and discrimination.

Unequal and prejudiced treatment in relation to employees and other

people who relate to the Uninter Group is prohibited.

Everyone must maintain a harmonious and pleasant work

environment, treating their colleagues with courtesy and respect,

always maintaining an ethical posture and respect for social diversity.

Any conduct of hostility, psychological violence, humiliation,

embarrassment, social, cultural and ethnic discrimination or related to

gender, age, religion, political positioning, sexual orientation, physical,

psychological and mental condition, among others, will not be

tolerated, due to any reasons, with the intention of obtaining an

advantage or favor, nor that the condition of hierarchical superior or

the ancestry inherent in the exercise of a certain job, position or

function is used to commit this type of aggression.

The practice of these conducts is subject to disciplinary action in

accordance with the internal policies and applicable laws, and may

even result in the termination of the offender's employment contract for

fair dismissal.

INTERPERSONAL RELATIONSHIP

The Uninter Group values an environment of respect, safety and

health. Therefore, all interpersonal relationships must be based on

mutual respect, courtesy, positive and kind attitudes and care for the

cleanliness, organization and safety of the work environment.

It is important that everyone collaborates with the cleanliness of the

place, exercise constructive feedback at all levels and respect the

space of colleagues, avoiding vocabulary and inappropriate subjects.

It is important that everyone has their positions respected, especially

regarding political parties and sports preferences, sexual orientation,

religion and any other issue that may affect the work environment.

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ACADEMIC RELATIONSHIP

In the academic environment, we count on

the collaboration of the Dean's Office, the

faculty, coordinators and other collaborators

involved in the process of direct and indirect

assistance to students in order to comply with

the rules and guidelines of the Ministry of

Education (MEC).

The students and clients of the Uninter Group

must always be treated with courtesy,

efficiency and transparency, and the work

must be guided by the quality delivery of all

the services offered, with the objective of

satisfying and retaining these students.

É Any preferential treatment to anyone, out

of personal interest or, still, with the intention

of circumventing academic rules and

procedures is prohibited.

RELATIONSHIP WITH STAFF SUPPORT POLICY

AGENTS AND MANAGERS

The process of choosing and contracting

business partners to manage the On-site

Support Center must be judicious and carried

out based on technical, commercial, ethical

and professional fundamentals, always

meeting the needs and interests of the

Uninter Group.

Any business decision that results in the

management of the face-to-face support pole

by employees, former employees, family

members or friends, must be previously

deliberated by the Ethics, Risks and

Compliance Committee.

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RELATIONSHIP WITH SUPPLIERS AND SERVICE

PROVIDERS

The process of choosing and contracting suppliers of goods and

services for the Uninter Group must be judicious and carried out

based on technical, commercial, ethical and professional

fundamentals, always seeking to meet the needs and interests of

the institution, according to predetermined processes. It is strictly

forbidden to hire suppliers of doubtful reputation.

Visits by suppliers on the premises of the Uninter Group are

allowed only during regular business hours and visitors must be

welcomed and accompanied during the entire visit by an

authorized employee.

The Uninter Group does not, under any circumstances, allow

suppliers, service providers, third parties and business partners to

engage in any type of illegal and unlawful conduct on behalf of the

company, which is why all contracts signed must contain

mandatory anti-corruption clauses (Law 12.846/2013) to ensure

compliance with this Code of Conduct.

Friendship or any form of relationship with a supplier or business

partner can be interpreted as a conflict of interest. In such cases,

the employee is not allowed to participate in the hiring process or

influence the process of selecting a supplier or partner.

When faced with a conflict case, the employee must report it

à to the immediate leadership, so that another professional can

proceed with the hiring process with absolute exemption.

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RELATIONSHIP WITH PUBLIC SERVANTS

Uninter Group’s relationship with public agents is based on

compliance with laws and ethical procedures.

It is prohibited to accept, offer or commit to any advantage that may

constitute an illegal or active or passive corruption, public or private

practice, under national or country laws with which the institution is

dealing. It is also not allowed to incite, demand, accept, obtain or

receive promises of benefits, even if not in cash.

The prohibitions also apply to the business partners of the Uninter

Group, both in relation to public and private agents.

The Uninter Group conducts its activities in a lawful and ethical

manner, regardless of local customs and practices. For this reason,

no employee will be penalized for delay or loss of business resulting

from his refusal to commit an act of corruption.

RELATIONSHIP WITH THE PRESS AND THE MEDIA

The Uninter Group carries out institutional communications through

its Press Office and/or through another professional authorized by

the Board of Directors. Therefore, it is forbidden for other

employees and managers to grant interviews and press releases on

behalf of the company without prior authorization from the Press

Office and the Executive Board.

RELATIONSHIP WITH COMPETITION

The Uninter Group seeks to maintain a healthy and respectful

relationship with its competitors, and employees and managers are

prohibited from offending and defaming products and services

offered by them.

RELATIONSHIP WITH UNIONS AND OTHER

REPRESENTATIVE BODIES

For the representation of the Uninter Group in unions or other

representative bodies, formal or informal, employees must have the

approval of a director in advance. If the focal point occupies a board

position, it must have the approval of its immediate superior.

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29

GIVEAWAYS AND GIFTS

Offering or receiving gifts, presents, hospitality and favors for the

purpose of obtaining personal or third party benefits or advantages

is prohibited.

This prohibition does not apply to occasional gifts of symbolic

value, which do not have a personal character to certain

employees, which have no commercial value or which are

distributed as a courtesy, advertisement or usual dissemination,

such as pens, diaries and calendars up to BRL 200.00, per

occasion and per supplier (limited to BRL 600.00 per year).

Giveaways and gifts offered and received in excess of the limit or

which may present or indicate any conflict of interest, within the

limits shown, must go through a formal donation process in favor of

the Uninter Group and be forwarded to the People Management

department for realization draw among employees.

For the offering of gifts at a higher price, the department's

immediate management must previously communicate to the

Compliance department and obtain approval from the Ethics, Risks

and Compliance Committee and/or the Board of Directors of the

Uninter Group.

A giveaway/gift is considered a conflict of interest if it was given

according to the position held by the recipient, whenever the giver:

• has a personal or professional interest in a decision that may

be taken by the employee due to his/her position;

• is participating or about to participate in the hiring process or

has a business relationship with the Uninter Group;

• represent the interest of a third party that is included in the

previous hypotheses.

No department of the company is authorized to request gifts from

suppliers, service providers and the like, current or under

negotiation, for projects and events promoted and/or organized by

the companies of the Uninter Group.

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CONFLICT OF

INTERESTS

GENERAL RULES

The Uninter Group expects its directors, employees and business

partners to conduct themselves with integrity and honesty, always aiming

at the interests of the institution to the detriment of any personal interest.

Any situation that creates a conflict between the interests of the Uninter

Group and the private interests of employees and third parties acting on

behalf of the company is considered to be a conflict of interest.

Any and all situations of conflict of interest, or even the appearance of

conflict, should be promptly reported to the Compliance department,

which, upon identifying its occurrence, will report the case to the Ethics,

Risks and Compliance Committee, which will support the decision-making

process of the Board of Directors.

For this reason, we do not allow our employees to associate and/or form a

partnership with our competitors, suppliers and service providers.

HIRING OF RELATIVES, FAMILIES AND INDICATION OF

PROFESSIONALS

Family, kinship or friendship bonds in the workplace are allowed as long

as they do not generate favors of any kind and the employees involved do

not have a direct or indirect subordination relationship.

For the purposes of this Code, the degree of kinship or family relationship

is understood as: father, mother, son, daughter, brother, sister,

grandfather, grandmother, uncle, aunt, spouse (formally married or in a

stable relationship), boyfriend, nephew, cousin, father-in-law, daughter-in-

law, son-in-law, brother-in-law, sister-in-law, stepfather, stepmother and

stepchild.

At the beginning of the selection process, the candidate must fill the Term

of Kinship or Relationship with another employee, and the prior approval

of the Ethics, Risks and Compliance Committee will be required

if any family relationship is noted. The area manager who

identifies the possible conflict is also obliged to report it to the

People Management department.

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Likewise, employees who in the future may form a family bond with operations

in the same department or who may have a direct subordination relationship

must communicate the People Management department, which will report the

fact to the Ethics, Risks and Compliance Committee, which will analyze the

possibility of relocating one of the employees in conflict.

Referrals from professionals are welcome. The recommended

professionals will normally participate in the Recruitment and Selection

Process, and the employee who indicated / recommended may not be the

final decision maker regarding the hiring or not of the participant.

É It is forbidden to hire relatives of employees in the departments with

transversal activities (Legal, Compliance, Internal Audit, Personnel

Administration and People Management) in any department of the organization.

COMBATING CORRUPTION, BRIBERY AND MONEY LAUNDERING

The Anticorruption Law (Law No. 12.846 / 2013) holds the legal entity

responsible for "acts against public administration, national or foreign, even

if the non-direct involvement of the company is proven". This means that

the International Uninter Group can be held responsible even if the

employee acts independently, that is, without the company's consent. In

other words, both the legal entity and the employee who committed the

crime will be penalized.

• Corruption is the act of soliciting or receiving, for yourself or for

another person, directly or indirectly, an undue advantage, or

accepting the promise of such an advantage. The most common forms

of corruption are bribery and extortion [...].

• Bribery is the offer, promise, supply, acceptance or solicitation of an

improper advantage, as a form of persuasion or incentive to unethical

action.

• Money laundering is the practice of hiding or concealing the nature,

origin, location, movement or ownership of goods, rights or values

arising, directly or indirectly, from a criminal offense.

32

The Uninter Group conducts business only with

reputable partners, whose commercial activities

are legal and whose funds come from legitimate

sources. In support of this commitment, we should

watch for signs of money laundering and terrorist

financing, monitoring our business partners for any

indication of illegal activity, as well as keeping an

eye out for possible “red flags” that may appear in

the course of business, signaling a problem. We

must maintain complete and accurate records of all

business transactions and follow the requirements

for reporting cash transactions.

POLITICAL PARTY

CAMPAIGN AND ACTIVITIES The Uninter Group is prohibited from participating

in campaigns and political party activities, through

its directors, employees or business partners, in

the internal work environment, in the exercise of

their functions or on behalf of the company.

SPONSORSHIP AND DONATIONS All and any kind of sponsorship or donation made

by the Uninter Group or by the companies that

compose it must take place in accordance with this

Code, with the prior opinion of the Compliance

department. The initiatives to be sponsored must be organized

and carried out by entities proven to be suitable,

regularly incorporated, and have no direct or

indirect political party ties

33

COMPLAINT

CHANNEL

0800 800 1800 WWW.CONTATOSEGURO.COM.BR/UNINTER

The Uninter Group's Compliance Program provides employees and other business partners with a channel for complaints, called the Complaint Channel, which allows anonymous manifestations related to misconduct, or suspicions of their occurrence.

This tool is linked to an independent and specialized company, with absolute secrecy and confidentiality of the reports being ensured, so that reports in good faith are not subject to any type of retaliation.

Violations of this Code or any other policies, procedures, guidelines or resolutions of the Uninter Group may result in disciplinary and legal actions, in accordance with the provisions of the CLT (Labor Laws Consolidation).

Complaints involving misconduct and non-conformities will be received and analyzed by the Ethics, Risks and Compliance Committee, which will investigate the veracity of the case, prepare a treatment suggestion and forward it to the Board of Directors of the Uninter Group for deliberation, in accordance with the attributions and powers provided for in the Internal Regulations.

The guarantee of anonymity and protection of the whistleblower's identity is ensured.

The Uninter Group undertakes not to carry out any discriminatory and retaliatory actions in the face of employees or third parties, for the reports of suspected non-conformities and reports made in good faith, maintaining the confidentiality of the authorship of the complaints, the persons denounced and the employees who may need to participate in an internal investigative procedure.

Retaliatory acts - promoted by the directors of the Uninter Group and employees - against whistleblowers or employees who work in an investigative procedure will result in liability, according to the Uninter Group's policy of consequences.

Any violation or suspected violation of this Code must be promptly

communicated through the Complaint Channel, by calling 0800 800

1800 or via website www.contatoseguro.com.br/uninter, and it can

be acessed via smartphones or tablets. 34

ETHICS, RISKS AND COMPLIANCE COMMITTEE

The Ethics, Risks and Compliance

Committee is in charge of guiding and

advising on the professional ethics of the

employee, in dealing with the people and

the assets of the Uninter Group, having the

specific responsibility to know the

imputation or procedure susceptible to

censorship.

The cases that are not foreseen in this

Code must be communicated to the

Compliance department and will be subject

to deliberation by the Ethics, Risks and

Compliance Committee.

The Ethics, Risks and Compliance

Committee's duties and way of acting are

established in its own Internal Regulations.

35

REMEMBER! IT IS PROHIBITED...

• Share, borrow or communicate your access

passwords.

• The use of your position or function in the

Uninter Group to obtain any favoritism, for

yourself or for others.

• Deliberately harming the reputation of other

employees or customers who depend on

them.

• Allow personal annoyances to interfere in

dealing with subordinate or hierarchically

superior customers and employees.

• Request, promise, offer, give, suggest or

receive any type of financial aid, gratuity,

prize, commission, donation or improper

advantage of any kind with the aim of

obtaining benefits or facilitations for you,

family members or anyone.

• Change or misrepresent the content of

documents to be sent for action.

• Request other assistance from other

employees than expected in order to meet

particular interests.

• Remove from the sector or institution,

without being legally authorized, any

document, book or asset belonging to the

Uninter Group's assets.

• Make use of privileged information,

obtained as a result of the functions

exercised in the Uninter Group, for its own

benefit or for the benefit of third parties.

36

• Offer, trade or use narcotic substances

(legal or illegal) within the facilities of the

Uninter Group.

• Support acts, behaviors and institutions that

encourage prejudices of any kind.

• Treating customers and other employees

poorly, as the Uninter Group expects them

to be treated in a kind, thoughtful, respectful

and absolutely unrelated to any kind of

prejudice.

• Cause damage to any property belonging to

the Uninter Group, deteriorating it due to

carelessness or ill will.

• Autonomously investigate alleged violations

by colleagues, suppliers or partners.

• Make false reports or commit acts of bad

faith to a colleague, supplier or business

partner.

• Refuse without justification the attendance

to mandatory training of the Uninter Group.

CU

T H

ER

E

ACKNOWLEDGEMENT OF RECEIPT AND AGREEMENT

I declare, for all purposes, that I have received a full copy of the UNINTER

Group Code of Conduct, that I have read the entire document, that I have

been informed of the obligation to comply with it in the exercise of my

activities and in the conduct of business, that I have become aware of its

provisions and that I undertake to comply with them in full.

I also declare that in the event of situations in which there is no express

provision in this Code regarding the required or expected conduct, I will

immediately inform the Group's Compliance structure.

Finally, I declare that I am aware that the tools provided by the UNINTER Group

to carry out my work, such as computer, telephones, extensions, e-mail boxes,

Skype for business and other forms of communication, as well as access the

systems and databases are owned by the UNINTER Group and can be

monitored and audited at any time by a team designated by the Shareholders,

by the Ethics Committee or by the Compliance and Sox Manager.

I hereby authorize any verification routine in these tools to be authorized and

declare that they will be used only to fulfill the purpose of the UNINTER Group in

the execution of my work activity.

Name: Group company you work for: Registration: Board/Department where you work:_____________________________ Place and date:

Signature 37

If you have doubts on how to act in a given

situation, seek guidance from your

manager, in the People Management

department or in the Compliance

department of the Uninter Group.

GENERAL PROVISIONS

The employees or any business partner of the

Uninter Group may not, under any circumstances

or under any argument, claim ignorance of the

provisions contained in this Code.

É It is everyone's obligation to observe the

provisions of this document, under penalty of

applying the sanctions and penalties provided for

in the Consequence Policy of the Uninter Group,

in accordance with the provisions of the CLT.

The Uninter Group is committed to promoting

periodic training for all its employees and

managers on topics related to the Code of

Conduct, Risk Management and the Integrity

Program.

This Code is effective from the date of its

publication, for an indefinite period of time, and is

available on the Uninter Group website and on

the intranet.

39

INSTITUTION

MAXIMUM SCORE

IN MEC *

/grupoeducacionalUninter

@grupoUninter

@Uninter

/webUninter

Uninter International University Center

uninter.com

* Institution reaccredited for distance education with maximum score (MEC ORDINANCE No. 1378 OF 19/012/2018, PUBLISHED IN THE

FEDERAL REGISTER ON 12/20/2018 AMENDED BY PUBLICATION ON 12/26/2018. REPORT CNE/CES No. 474) by the evaluation of the

Ministry of Education (MEC). | ** Note published by Inep/MEC in the FEDERAL REGISTER on 12/12/19.