Compliance

To ensure the proper autonomy of Compliance Program actions, Wiz has a dedicated team to ensure fulfillment of the responsibilities that guarantee compliance, transparency, and the ethical conduct of Wiz’s business. The Program is supervised by the Internal Audit Committee.

Below is the Wiz Governance structure regarding the Compliance Program:

Internal Audit plays a crucial role as an independent technical body linked directly to the Internal Audit Committee (COAUD) and the Board of Directors (CA). The team performs annual tasks approved by these bodies, closely monitoring the company’s primary and most critical processes, including accounting processes for the recognition of revenue, expenses, assets, and liabilities.

By ensuring compliance with laws and regulations, protecting organizational assets, and guaranteeing the reliability of financial and operational information, Internal Audit plays an essential role in the effective implementation of the Integrity Program. By validating processes and guidelines, and ensuring the consistent and transparent application of anti-corruption measures, it promotes an organizational culture of compliance and accountability—fundamental to the organization’s sustainability and credibility with stakeholders. Therefore, Internal Audit is responsible for evaluating the application of the Integrity Program at Wiz Co.

Audit Values

• Protecting the business: Through assurance engagements, the internal control environment is evaluated independently and objectively.
• Problem-solving: Through in-depth investigation, the audit is able to identify the root causes of issues found during ordinary and extraordinary assignments.
• Generating ideas: Improvement suggestions provided by the audit are aligned with the latest market best practices; this proactive role can serve as a source of innovation for departments that choose to adopt these recommendations.
• Trusted advisory: Acting in strategic consulting or audits requested by governance bodies, delivering an in-depth and independent study of the analyzed facts.

The Compliance department is responsible for promoting a culture of integrity and ensuring that ethical values and best practices become an intrinsic part of the organization’s daily routine. This culture helps prevent misconduct, such as fraud and corruption, and strengthens trust among employees, partners, and clients.

The Compliance department’s responsibilities include:

• Applying the Integrity Program, as well as managing and ensuring its fulfillment;

• Ensuring adherence to applicable laws and regulations, internal policies, and the Wiz Co Code of Ethical Conduct;

• Advising Senior Management and the Audit Committee on monitoring the adequacy and effectiveness of the Company’s compliance risk management structure;

• Maintaining communication channels and reporting lines for submitting information regarding compliance deficiencies, risks, or incidents, as well as ethical and conduct deviations (whistleblowing channel management).

Wiz Co’s Internal Controls and Risk area seeks to assist the Company in managing its risks, increasing the likelihood of achieving objectives, optimizing the operational effectiveness and efficiency of internal processes, ensuring a reliable data base for decision-making and planning, and promoting and disseminating a risk management culture among employees.

Despite being part of Wiz Co’s Corporate Governance, the area’s autonomy ensures that the team can identify and evaluate risks objectively, without pressure to underestimate or ignore issues, while maintaining effective internal controls that mitigate risks appropriately and timely. Therefore, the Internal Controls and Risk area plays a supporting role in the application of the Integrity Program at Wiz Co.

Risk Management Policy

Wiz Co has a Risk Management Policy that is duly updated and disclosed to stakeholders. The Internal Controls and Risk area reports to the Internal Audit Committee and adopts the 4 Lines of Defense model recommended by the Institute of Internal Auditors (IIA), where:

• Managers are part of the 1st line, always seeking to improve the environment and its internal controls;

• The Internal Controls and Risk area and the Compliance area fulfill their supporting role in the 2nd line of defense;

• The Internal Audit area acts as the 3rd line of defense by evaluating the Company’s internal controls and verifying their effectiveness;

• Independent External Audit acts in the 4th line of defense, assisting the Company in providing reliable financial statements.

• Wiz’s Risk Policy

The Legal Department plays a fundamental role in Wiz Co’s Integrity Program by ensuring that the Company operates within the legal and regulatory boundaries of the insurance brokerage sector. The inclusion of an independent legal team in our operations is a measure aimed at promoting long-term sustainable growth, protecting the Company from litigation and risks inherent to the Market.

Preventive, administrative, and judicial actions provide effective solutions to the challenges that arise in the daily operations of Wiz Co and its affiliates. As a publicly traded company, we understand the importance of ensuring a secure environment, strengthening investor confidence.

The Corporate Governance practices carried out at Wiz Co seek to ensure that Group companies are directed and managed efficiently and effectively, through decisions that maximize the use of available resources to achieve the best possible results. To this end, independence is essential to guarantee that decisions are made transparently and responsibly, aligned with the best interests of the company and its stakeholders.

Wiz’s Code of Ethical Conduct was entirely revised and validated by the Board of Directors in 2023, serving as one of the main pillars of our Compliance Program. It outlines the core guidelines regarding the behavior we expect from our employees, as well as what we do not tolerate. In this same document, we reaffirm our commitment to fighting corruption, whether public or private.

To facilitate the understanding of the Company’s internal rules and ensure their effective comprehension, we have prepared the Compliance Handbook, a document that presents the main rules of the Code of Ethical Conduct in a more didactic and objective manner. We emphasize that the rules provided in these documents apply to all employees and senior management, regardless of their position.

Additionally, we have internal policies related to specific topics, such as (i) Hiring of Third Parties and Suppliers; (ii) Donations and Sponsorships; (iii) Anti-Discrimination Policy; (iv) Fraud and Corruption Prevention and Combat; (v) Fighting and Preventing Fraud and Corruption; (vi) Third-Party Relationship Code, among others.

The policies mentioned above are available for public knowledge below:

• To access the Wiz Co Code of Ethical Conduct, click here.
• To access the Wiz Co Compliance Handbook, click here.
• To access the Wiz Co Policy on Fighting and Preventing Fraud and Corruption, click here.
• To access the Wiz Co Donations and Sponsorships Policy, click here.
• To access the Wiz Co Hiring of Third Parties and Suppliers Policy, click here.
• To access the Wiz Co Anti-Money Laundering and Counter-Terrorist Financing Policy, click here.
• To access the Wiz Co Anti-Discrimination Policy, click here.
• To access the Wiz Co Third-Party Relationship Code, click here.

Wiz is committed to the ethical and socially responsible conduct of all its business activities.

To this end, we adopt a transparent stance with the public sector, respecting and following internal procedures to comply with the provisions of Law 12,846/2013 (Anti-Corruption Law), which provides for the administrative and civil liability of companies for acts against public administration, whether domestic or foreign, as well as the rules established in Law 14,133/21 regarding the rules for participation in public tenders.

It is worth noting that currently, some Wiz companies maintain active contracts with the public administration; click here to check the contracts currently in force.

We provide our employees, shareholders, suppliers, and the general public with an exclusive Channel for secure and, if desired, anonymous communication.

Through this Channel, we encourage the reporting of conduct considered unethical, that violates the principles of the Code of Ethical Conduct, the corporate governance best practices adopted by Wiz companies, and current legislation, as well as the reporting of irregular practices under the Anti-Corruption Law (Law No. 12,846/2013).

Our Whistleblowing Channel is managed by an independent company specialized in this type of service. The Channel is available to receive reports 24 hours a day, 7 days a week.

Reports can be made by telephone or via the web:

• Telephone: 0800 810 8461

• Website: https://www.contatoseguro.com.br/wizco

For further clarification regarding the Channel, access our FAQ here.