TOTVS S A : Sustainability and ESG Policy

ORGANIZATIONAL POLICY

labor relations, environment, and anticorruption. This initiative relies on UN agencies, companies, unions, NGOs, and other partners to build a more inclusive and egalitarian global market. TOTVS has been a signatory to the UN Global Compact since 2014.

• Ethos Institute's Business Pact for Integrity and Against Corruption: Aims to bring together companies committed to promoting a more honest and ethical marketplace and eradicating bribery and corruption. TOTVS has been a signatory to the pact since 2014.
• Universal Declaration of Human Rights: Adopted and proclaimed by the General Assembly of the United Nations, it outlines the fundamental human rights inherent in all human beings and universally recognized by nations.
• Principles for Responsible Investment (PRI): Principles developed by investors in partnership with the UN Environment Program Finance Initiative (UNEP FI) and the UN Global Compact. It aims to understand the implications of investment on environmental, social and governance issues, in addition to supporting signatories in integrating these matters into their investment and asset ownership decisions.
• Global Reporting Initiative (GRI): A multi-stakeholder organization that helps companies and governments around the world assess and communicate their impact on key sustainability issues. GRI defines Sustainability Reporting Standards developed with contributions from different stakeholders and focused on the public interest. TOTVS adopts the GRI model in the management and creation of the Sustainability Report.
• The International Integrated Report Council (IIRC): a global coalition of investors, companies, accountants, regulators, academics, and NGOs developing a model for corporate reporting. The standard is developed on the analysis of value creation from the integration of sustainability to the business model. TOTVS develops its Sustainability Report based on the IIRC model.
• GHG Brazil Protocol: Establishes a comprehensive, globally standardized framework for measuring and managing greenhouse gas (GHG) emissions from public and private sector operations, value chains, and mitigation activities. TOTVS reports the GHG emissions of its operations based on the GHG Brazil Protocol.
• Healthy work environment: According to the World Health Organization (WHO), a healthy work environment is one in which workers and managers work together to implement a process of continuous improvement to promote the health, safety, and well-being of all workers and contribute to the sustainability of the workplace.
  3.2 Internal References
• Code of Ethics and Conduct applicable to companies in the TOTVS S.A. economic group ("CODEC").
• TOTVS S.A. Bylaws.
• TOTVS S.A. Contributions, Donations, and Sponsorship Policy.
• Policy on the Disclosure of Material Information and Trading of Securities of TOTVS S.A.
• TOTVS S.A. Risk Management, Internal Controls and Compliance Policy.
• TOTVS S.A. Human Relations and Compensation Policy.
• Policy on the Nomination of Members to the Board of Directors, its Advisory Committees and the Statutory Management of TOTVS S.A.
• TOTVS S.A. Policy on Business and Institutional Relations with Public Entities.
• TOTVS S.A. Information Security Policy.
• TOTVS S.A. Data Privacy Policy.
• TOTVS S.A. Diversity and Inclusion Policy.

4. Definitions

The terms and expressions listed below, when used in this ESG and Sustainability Policy, will have the following meaning:

Value chain: complete sequence of activities or parties that provide or receive value in the form of products or services. (1) Parties that provide value include suppliers, outsourced workers, contractors, and others. (2) Parties that receive value include customers, consumers, and other users.

ORGANIZATIONAL POLICY

Code of Ethics and Conduct - CODEC: is the Code of Ethics and Conduct of the TOTVS Group, which establishes a set of rules and ethical principles that guide the TOTVS Group's commitment to business integrity and internal and external relationships. The CODEC applies to all directors, officers, controlling shareholders, TOTVERS, service providers, suppliers, and partners.

Sustainable Development: Development that meets the current needs without compromising the capacity of future generations to meet their own needs.

TOTVS ESG and Sustainability Working Group: Group formed by a multidisciplinary team, with representatives from various areas and hierarchical levels, including leaders of the TOTVS Group. It aims to support the construction, development and strengthening of the integration of the ESG and sustainability agenda into the business. Acts in the implementation, communication, rendering of accounts, promotion of projects, initiatives and actions aimed at enhancing the topic within the TOTVS Group ecosystem.

TOTVS Group: TOTVS S.A. and its direct and indirect subsidiaries, domestic or foreign.

Impact: positive or negative change, totally or partially resulting from the organization's past and present decisions and activities related to society, economy or the environment.

ESG: Refers to an organization's environmental, social, and governance practices.

UN: United Nations Organization.

Stakeholders: individuals or groups that have an interest in any decision made by the TOTVS Group. They include employees, directors, shareholders, customers, suppliers, business partners, the internal community, and society in general.

Transparency: frankness about decisions and activities that affect society, the economy and the environment, and the willingness to communicate them in a clear, precise, timely and comprehensive manner.

5. Guidelines

We are committed to developing a sustainable agenda that reflects TOTVS Group's purpose and vision on how its businesses can positively drive and impact society, both as an employer and social agent. We believe in the transformative power of technology, in its ability to contribute to the construction of an increasingly digital, prosperous, productive, inclusive and sustainable ecosystem.

TOTVS' ESG and sustainability performance is supported by a solid governance structure, the pillars of which are set out in the CODEC, the Organizational Policies, and the most advanced corporate governance practices, by the transparency, ethics, and integrity that guide the relationships established with its audiences, and manifested through the commitment to continuously develop and improve the practices set out in the general and specific guidelines described below.

5.1 General Guidelines

This ESG and Sustainability Policy should be disclosed, made available and disseminated throughout the TOTVS Group ecosystem, in order to actively promote engagement with the principles, values and guidelines it recommends. The objectives, themes, and guidelines of this Policy must be included and taken into account in the strategic planning, product development, decision making, and investment processes of the TOTVS Group Management.

The content of this Policy should be gradually incorporated, where applicable, in the development of the products and services offered by the TOTVS Group, in internal processes and in research, development, and innovation activities.

Monitoring, management and communication should be made in a clear and transparent way relating to ESG performance, based on structured management and reporting processes, and ensuring undertaking of practical commitments towards the evolution of the integrated sustainability agenda to the business.

ORGANIZATIONAL POLICY

Good environmental practices aimed at eco-efficiency should be promoted in all TOTVS Group facilities.

Dialogue and building of partnerships with external audiences (e.g., customers, suppliers, innovation community, representative entities, among others), should be sought in the development of projects, initiatives and joint solutions related to the ESG sustainability topic.

6. Assignments:

Board of Directors

• Evaluate and approve the Sustainability and ESG Policy;
• Discuss the public commitments made by the TOTVS Group regarding ESG initiatives and the Sustainable Development Goals (SDGs);
• Discuss the Plan of Goals for the agenda on sustainability and integration of ESG aspects to the business strategy;
• Approve the sustainability indicators to be adopted by the company;
• Discuss the Business Materiality Matrix;
• Define and update TOTVS Group's strategic objectives that will guide the management of the theme, in accordance with the guidelines of this Policy, in an integrated way with the business;
• Evaluate and approve integrated ESG performance reports;
• Ensure the structure and resources (human and financial) necessary for the implementation of this Policy and the strategy of the topic in the organization.

Governance and Nomitation Committee

• Evaluate this Policy and recommend it for approval by the Board of Directors;
• Evaluate the Plan of Goals on sustainability and integration of the ESG aspects of the business;
• Monitor and express an opinion on the process of setting the TOTVS Group's sustainability goals;
• Monitor the process of engagement and consultation of stakeholders in the periodic review of the company's materiality, and evaluate and measure its results;
• Monitor and validate the development of the action plan on ESG sustainability, proposing updates and improvements when necessary;
• Evaluate integrated annual ESG performance reports.

Personnel and Compensation Committee

• Oversee the annual evaluation process of the company's senior executives, based on the definition and review of the achievement of financial and non-financial performance targets (including ESG) in line with the Group's values and ethical principles, and recommend their approval by the Board;
• Propose the form of disclosure of the directors' compensation in the management proposal to the general meeting and in the reference form;
• Recommend and monitor the company's social practices, including ESG aspects related to work models, diversity and inclusion, workforce skills, and education for work.

Strategy Committee:

• Analyze and discuss topics that develop the company's vision for the future and its strategic planning, including strategic guidelines related to ESG topics, and assess the company's actual ability to implement them.