Code of Ethics and Conduct
Our ethical principles guide all our decisions and relationships, ensuring transparency and integrity in everything we do.
v1.1 — revised September 2026
Code of Ethics
Index
01 | Message from the Impact team
02 | Mission, Vision and Values
03 | Target Audience
04 | Ethical Principles
05 | Regenerative Development Principles
06 | Respect for the Individual
07 | Good Relationship Practices
08 | Conflict of Interest
09 | Ethical Decision
10 | Responsible Use of Digital Media
11 | Impact Assets and Resources
12 | Complaints
13 | Complementary Provisions
01 | Message from the Impact team
Created from the fusion of external references and internal perspectives of our team, Impact's Code of Ethics is an organic document that must be updated periodically through collaborative and inclusive processes, so that together we can advance in this learning journey.
Its greatest mission is to be a conscious guide that guides our daily conduct, based on honesty, ethics, transparency, respect for others, for the planet, for life, for legislation and internal standards.
An important document, aligned and that strengthens our purpose of together collaborating to redefine profit by adding social and environmental value to money circulation to accelerate the transformations necessary for a more just and regenerative future.
Impact is committed to regenerative principles and practices, a development model that evolves beyond sustainability - it seeks to reverse environmental and social degradation.
Thus, a responsible stance for our choices and conduct, aware of the impact of our actions on the planet, on the organization and its community, will be determining factors for the success of the applicability of this Code of Ethics.
It is important to emphasize that each persons effort must go beyond self-responsibility and extend their actions to a non-omissive stance in the face of other conduct that does not meet the ethical principles of this code.
We invite you to dedicate a few minutes to reading this document, so that it brings you inputs for reflection and conduct guidance. Being recognized as an institution of integrity, reliability, honesty and transparency depends on strict compliance with this Code of Ethics.
This document also reflects our belief that it is necessary to take advantage of Brazils current moment so that our society can reinvent itself and be more ethical, fair and regenerative.
Gabriel Ribenboim and Impact team
02 | Mission, Vision and Values
Mission
Together, we collaborate to redefine profit by adding social and environmental value to money circulation to accelerate transformations necessary for a more just and regenerative future.
Vision
To be a financial platform that leaves no one behind and that promotes innovation in financial services and ethical and fair business models that collaborate for social and environmental regeneration.
Values
Ethics and Justice; Honesty and Transparency; Respect and Reciprocity; Collaboration and Inclusion; Harmony and Balance, Based on Nature and Human Beings; Regenerative Impact first.
Code of Ethics Principles
Respect
Integrity
Honesty
Transparency
Responsibility
Harmony and Reciprocity
03 | Target Audience
The Impact community
TRANSFORMATION AGENTS
Impact clients, partner third sector organizations and their direct beneficiaries
COLLABORATORS
Interns, apprentices, managers and employees of contracted companies. EMPLOYEES People with employment relationships with Impact.
SENIOR MANAGEMENT
Directors of the Company.
04 | Ethical Principles
Impact is committed to disseminating the Code of Ethics among all its collaborators, to ensure that its actions are governed by the principles and commitments present in this Code of Ethics. Ethical principles are an essential part of our responsibilities and dictate the direction we must take, especially when we experience ethical dilemmas and need to make decisions.
RESPECT
The relationship with the Impact community must always be based on respect, dignity and non-discrimination of people. We respect and value the ancestral knowledge of past generations and respect the limits of present generations without compromising the ability of future generations to meet their own needs. Impact refuses and repudiates any degrading attitude against the planet and its biodiversity and any hostile or humiliating attitude against people, does not tolerate disrespect for dignity, equality, diversity, privacy of people and life. The work environment and relationships must be guided by professionalism, respecting different cultures, beliefs and positions.
HONESTY
We expect the conduct of Impact community members to have honesty as their standard. We must do and communicate only what is correct, we must act in good faith, with integrity and sincerity in matters affecting community duties and interests.
TRANSPARENCY
Impact strives for transparency in its relationships, actions and business. The secrecy and confidentiality of information are required in our routine. The trust of our partners is linked to the access that Impact gives to information, accountability and decision-making. However, actions deliberately executed in secret are not ethical and acceptable.
RESPONSIBILITY
Each member of the Impact community is responsible for their actions and decisions. We must be responsible for creating a transparent, respectful and safe environment, so that relationships and business are ethical and regenerative. It is also our responsibility to know, care for and comply with established internal policies and procedures.
HARMONY AND RECIPROCITY
Harmony is understood as the combination of elements linked by a relationship of relevance, which produces a pleasant and pleasurable sensation. The concept reflects a culture of peace between the Impact community, our products and services, and the balance between business, people and planet. If a relationship, of any nature, or the perception of any product or service does not sound harmonious, it is a signal to stop, communicate, reflect and co-create solutions, from listening and collective and inclusive construction. Remember that each of us, members of the Impact community, contribute to the harmony of the community and the movement in which we choose to be inserted, just as the community and the movement as a whole contribute directly to our harmony and prosperity as individuals.
05 | Regenerative Development Principles
1. Right relationship
Understands that the ecosphere is composed of nested systems, living and non-living. Recognizes that the human economy is embedded in culture and the ecosphere and must operate in dynamic and cooperative relationship with them, respecting cultural needs and planetary boundaries. Allows critical exchanges of added value to occur at all scales in reciprocal relationship, in contrast to commoditized transactions.
How we position ourselves
There is a growing movement of companies that see their role as more than simply maximizing shareholder value. One example is B Corporations, which prioritize environmental and social goals as much as fiscal ones, and understand that they can make the world a better place than it was when they started - and they do so profitably. Impact has already begun the process of B Corporation certification, following in the footsteps of Welight Social Technology, where we originated. We operate with our social and environmental duty as the focus in defining policies, standards and procedures for preventing and combating corruption, as well as money laundering and terrorism financing. We repudiate any form of degrading work. It is part of our institutional culture to develop and support regenerative development initiatives and we value bonds established with the communities in which we operate and respect their cultural values and knowledge and return to the community a portion of the value added to business.
What we can do as individuals
Observe instances of cooperation around you all the time - in nature, in the business world and in human culture more broadly. Incorporate this principle by reflecting on opportunities for cooperation and healthy interactions and take advantage of them when possible. For example, companies can expand their relationship with local companies and suppliers. As an individual, seek collaboration and advice from neighbors on your projects, such as gardening, creative work or commercial ventures. Support organizations, movements and leadership that focus on having a right relationship with nature and society.
2. Seeing wealth holistically
True wealth is not just money in the bank. It starts from the assumption that wealth is the well-being of the whole, which must be achieved through harmonizing multiple types of wealth or capital, including social, cultural, living and experiential. It recognizes that countless dimensions of human and natural capital cannot be measured in monetary terms, but must be nurtured as intrinsic components of holistic wealth. Thus, wealth must be defined by broadly shared prosperity across all varied forms of capital.
How we position ourselves
Companies that incorporate regenerative principles know that wealth is more than just financial. Impact SA values its human capital, in the form of happy and well-cared-for employees; values and encourages its cultural capital by providing a space for positive, diverse and strengthening interactions to occur; and values natural capital, creating value chains that improve the health of the planet we share.
What we can do as individuals
Take stock of the various forms of wealth you possess, beyond financial. Perhaps it is a satisfying social network, access to parks and natural spaces, the ability to pursue curiosity and develop intellectually, or spiritual fulfillment. Support community organizations that emphasize multiple forms of capital and seek to build the various types of wealth that can provide deeper fulfillment than money.
3. Innovative, adaptable, responsive
In a world where change is always present, the qualities of innovation and adaptability are essential for the health of the whole. In a comparison to Charles Darwin theory, the fittest is the one that fits best, the one that is most adaptable to a changing environment.
How we position ourselves
The application here is clear: humans have a special talent for solving problems in creative ways. Companies that do well are the ones that survive. Creative business models are usually the best at solving difficult problems, in a way that also benefits local communities and the planet.
What we can do as individuals
Everyone has creative skills, even if they haven not been intentionally exercised recently. Challenge your habitual ways of thinking about social problems - be willing to let go of ideas about what should work and what has already been done. Consider solutions or ideas that seem irrational or impossible, because once more options are on the table, innovative solutions can emerge.
4. Empowered participation
All healthy living systems are self-organized and operate through continuous negotiation among themselves and in constant interaction. Similarly, a healthy human economy requires the empowered participation of individuals and groups, negotiating in their own enlightened interest, as they naturally promote the health of the whole.
How we position ourselves
We adopt a decentralized leadership model as a way to ensure that everyone has a voice, ensure adherence to Impact SA community goals, strengthen professional relationships, and create a healthy and empowering collective.
What we can do as individuals
Recognizing that the best scenarios are those where everyone benefits, seek ways to strengthen these interactions in the world. Support solutions and policies that are good for people and the planet. Many policies that are good for the planet are also beneficial to people and the economy, and our elected officials need to know we support them. In business, seek to bring as many stakeholders into the conversation as possible, rather than restricting decision-making to smaller, closed groups.
5. Honor communities and places
Each human community consists of a mosaic of peoples, traditions, beliefs and institutions uniquely shaped by long-term pressures of geography, human history, culture, local environment and changes in human needs. Honoring this fact, a regenerative economy nurtures healthy and resilient communities and regions, each uniquely informed by the essence of their individual history and place.
How we position ourselves
In a world seemingly dominated by large companies, small companies can have important collaborative advantages that should be strengthened. Traditional and indigenous communities in Brazil and local populations possess a vast collection of specific knowledge about their territory, culture, economy, wildlife, biodiversity, climate and soil conditions specific to their area. Knowledge holders can often be more successful than larger companies trying to apply off-the-shelf solutions. Similarly, in partnership with organizations and groups working in different territories, we seek to catalyze local energy and knowledge to adapt solutions that would not be possible without special place-based knowledge.
What we can do as individuals
Think about how your locality is unique and worthy of celebration. Take pride in your place by being a patron and promote, encourage and participate in activities that regenerate your region and its people.
6. Abundance of edge effect
Creativity and abundance flourish synergistically at the "edges" of systems, where the bonds that hold the dominant pattern in place are weakest. For example, there is an abundance of interdependent life in salt marshes where a river meets the ocean. At these edges, opportunities for innovation and cross-pollination are greatest. Working collaboratively across boundaries - with continuous learning and development from the diversity that exists there - is transformative both for the communities where exchanges are taking place and for the individuals involved.
How we position ourselves
Companies with greater diversity are more innovative, generate more profits and have more satisfied employees. Diverse perspectives help groups make more informed decisions, lead to greater creativity and promote respectful environments. This business "edge effect" is a feature of more regenerative economic systems.
What we can do as individuals
Notice the ways in which diversity in its many forms - in your social network, the cultures you have experienced, the ideas you consider, the foods you try - can enrich your life. In your workplace, see if there are ways to introduce unconventional perspectives or bring in people who have them. While experts have some strengths, generalists who are well versed in a variety of topics can often have creative insights or valuable ideas. Look for connections between disparate areas of your knowledge.
7. Robust circular flow
A regenerative economy mimics the metabolic process found in resilient living systems, harnessing what we now discard as "waste" in a continuous, productive, circulatory and value-added flow. Similarly, the regenerative model promotes the circular flow of value creation of money, information, efficient use and reuse of materials and are particularly important for individuals, companies and economies to achieve expected regenerative potential.
How we position ourselves
Being a movement primarily guided by digital, our parallel is made with money circulation. We conceive solutions from guiding questions of "How to mobilize capital to finance transformations for a more just and regenerative future?", "How can we maximize the positive impact of money circulation?" and "What are the most efficient strategies and vehicles to finance social and environmental impact initiatives?". Nevertheless, we seek to incorporate the circular economy of energy and materials as much as possible, reducing, reusing, recovering and recycling. One example is the next version of our Impact SA Card, which we are working with suppliers to offer a recycled plastic card taken from the oceans.
What we can do as individuals
Find ways to reduce or reuse "waste" in your own life. Reflect, everyone profits from the absence of waste - and so does the planet! Get to know the content platform YAM - the voice of the heart, as another way to approach a sustainable lifestyle. Food: reduce animal protein consumption, plan your purchases and seek to buy from small local producers, plant at home, eliminate the concept of waste by reusing leftovers, and have composting at home for what cannot be used as food. There are several tutorials on the internet for you to create your own composter at home and contribute to this cycle. To know much more, see here a YAM guide with 10 steps to avoid food waste. Plastics: eliminate those that are not necessary, reuse and recycle, keeping them in the economy and out of the environment. Learn more in the Recycling for Real guide, from the YAM platform. Fashion: seek to ensure that clothes and accessories are worn more often, can be transformed into new pieces and look for those made from safe and renewable materials. Finance: seek to support companies in their transition to circular business models and support movements, NGOs and leadership that develop circular economy solutions.
8. Search for balance
Being in balance is more than just a pleasant way to be. It is actually essential for systemic health. Like a canoeist rowing her thin canoe in turbulent waters, regenerative systems are always engaged in this delicate dance in search of balance. Achieving this requires them to harmonize multiple variables rather than optimize single ones. A regenerative economy seeks to balance efficiency and resilience, collaboration and competition, diversity and coherence, and the needs of small, medium and large organizations.
How we position ourselves
Often, businesses have been a force that pushes natural and social systems out of balance - but many are now changing their priorities to help restore balance. B System companies and regenerative business models balance profit motivation with equal emphasis on people and planet. Impact SA was conceived as a movement that puts first its contribution to social, ecological and economic systems operating in healthy balance.
What we can do as individuals
Balance is a theme that permeates each of the Regenerative Principles. Things simply work better when they are in balance. Consider things in your own life that seem unbalanced and look for ways to restore balance. Support movements, NGOs, companies, policies and politicians that aim to restore balance and help create systems that provide shared prosperity on a thriving planet.
06 | Respect for the Individual
Relationships in the work environment and in all interactions of the Impact SA community must be guided by mutual respect and courtesy, valuing ethics, integrity and transparency. No type of discrimination or intimidation attitudes regarding differences in race, origin, color, physical conditions, gender, sexual orientation, religious beliefs or political convictions will be tolerated.
• We respect the diversity of people who make up the work environment and who maintain relationships with Impact SA.
• We encourage a culture of respect and repudiate violence.
• We strive to establish a dignified and healthy work environment, guiding relationships with respect and cordiality, regardless of the position held in the organization or role within the Impact SA community.
• We must prevent embarrassment and damage to the image of Impact SA and the employee.
• Moral harassment is understood as all abusive conduct, such as gestures, words and attitudes that are repeated systematically, affecting the dignity or psychological or physical integrity of the worker.
• We repudiate conduct that may characterize harassment of any nature, discrimination or its induction; coercion, persecution or embarrassment; disrespect for functional attributions; public disqualification, offense or threat.
The definition of harassment is described in art. 216-A of the Penal Code: "To constrain someone with the intention of obtaining sexual advantage or favoring, taking advantage of their condition of hierarchical superiority or ascendancy inherent to the exercise of employment, position or function".
07 | Good Relationship Practices
The Impact SA Code of Ethics defines guidelines that must be observed by its community:
MANAGERS
• We expect our managers to be developer leaders, inspiring teams and stimulating engagement, with a view to forming successors for current and future challenges.
• We determine that managers do what is right, be a reference for appropriate posture and encourage teamwork as a practice of collaboration and sharing knowledge and experiences.
• We believe that corporate ethics is mainly related to the behaviors, practices, beliefs and values of all. Therefore, it seeks to promote a corporate culture, based on solid pillars where people come first, whether they are employees, suppliers, customers or society in general.
• Managers must act with transparency, be open to dialogue and interact with their employees in order to share actions and objectives that lead to the common good, always ethically.
• Cultivate environments that provide the realization of high quality work, relevant for those who perform it, for the institution and society.
• We guide that the manager, in addition to having ethical conduct, disseminate the organization values and precepts of the Code of Ethics, contributing to the application of this document.
SUPPLIERS
We guide suppliers to follow the guidelines of this Code of Ethics. We must require from suppliers:
• Compliance with social security and tax; labor legislation;
• Compliance with legislation and regulations relating to the prevention and fight against corruption;
• Non-use of child or slave labor; adoption of good environmental preservation practices;
• Non-adoption of acts of corruption against governments and Brazilian or foreign public administration.
COMPETITORS
• We define that ethics, integrity and civility should be guiding principles of our relations with competition. Information exchanges can only occur in a lawful and transparent manner, preserving our principles and Impact SA interests.
• We prohibit inadequate practices in offering products and services, including imposition in business execution.
• We are transparent and agile in providing information, observing secrecy and confidentiality rules.
GOVERNMENTS
• We must act in relations with public authorities in accordance with international guidelines regarding the prevention and fight against tax evasion, corruption, money laundering and terrorism financing.
• We must establish, regardless of individual ideological convictions, courteous relationship with the Brazilian public authority and that of the countries where we operate.
• We repudiate acts of corruption practiced against governments and Brazilian or foreign public administration.
• We prohibit giving, offering, promising or authorizing giving anything of value to Brazilian or foreign government employees, directly or through intermediaries, in order to influence action to obtain undue advantage.
BENEFICIARIES
The beneficiaries of the Impact SA Transformation Fund, whether legal entities or individuals, are its main reason for existence. For this reason, all principles provided for in this Code of Ethics apply to Impact SA relationship with its beneficiaries. Impact SA understands that it must always make the greatest efforts so that actions carried out on behalf of its beneficiaries prove to be increasingly effective and efficient, paying attention to:
• Treatment and offering solutions with quality, respect and honesty of its actions, aiming at beneficiary satisfaction;
• Transparency in planning and executing actions, with beneficiary participation in all stages of the process;
• Deadlines and values established in planning;
• Compliance with all principles of this Code of Ethics.
08 | Conflict of Interest
We warn that the actions exemplified below constitute conflict of interest:
• Conducting affairs or business with public agent with decision-making power within government agencies and entities with whom they have kinship relationship, in direct or collateral line, by blood or affinity, up to 3rd degree.
• Using privileged information about relevant act or fact not yet disclosed in the market to which they had access due to position or function.
• Using internal information to conduct personal business with third parties, such as customers, suppliers, service providers, and partners.
• Performing external activities that may constitute damage or competition to Impact SA.
• Cases of conflict of interest involving Directors are decided by the other Director, with written record, with the conflicted Director abstaining. If the conflict reaches both Directors, the matter is submitted to the General Assembly. The Company has committed to establishing an Ethics and Compliance Committee, with at least one member external to the Board, in the first quarter of 2027.
09 | Ethical Decision
1. Is your decision in accordance with Impact SA code of ethics with current legislation and internal regulations?
2. Does your decision serve the interests of the Impact SA community?
3. Can this decision be justified to your colleagues and superiors?
4. Except for situations where there is a need for secrecy and confidentiality, can your decision be public?
5. If you answer NO to some of these questions, then seek help!
10 | Responsible Use of Digital Media
• We strive for inclusive communication that creates favorable conditions for business action and work performance, focusing on transparency, clarity and objectivity.
• We must responsibly use digital media and apply good communication practices aligned with principles of integrity, transparency and respect.
• We understand that internal communication should contribute to strengthening the relationship between the Company and employees.
• We value manifestations in the digital environment that respect diversity of ideas and Company positioning.
• We prohibit linking Impact to comments and posts of offensive information or images and/or that violate the privacy of employees and third parties on digital media and social networks.
• We prohibit issuing or disseminating offensive criticism or slander that exposes the image or honor of Impact, its areas or its employees.
• Before writing on social networks, remember that all added content is public. Think about the impact on your professional life, your privacy and that of others.
11 | Impact Assets and Resources
• We prohibit the use for private purposes of goods or services exclusive to the performance of our duties.
• We must care for Impact's heritage and image and disseminate this care.
• We prohibit the use of facilities, equipment, work materials and electronic communications network for political-partisan, religious or commercial interest matters of our own or third parties.
• We must preserve institutional identity, avoiding using the Company name, marks and private symbols without authorization.
• We must be aware of responsibility in handling corporate information.
• We prohibit employees from dealing with confidential and internal use matters of Impact in conversation rooms, social networks and applications with internet access.
• We must safeguard information secrecy, related to relevant act or fact to which they have privileged access due to the position or function they occupy.
• We must observe intellectual property standards for books, texts, images and other products protected by copyright.
• We treat internal and external data collected responsibly and ethically, according to legislation, throughout the information life cycle.
• We must carry out our activities respecting customer privacy and legislation related to the subject, including in the use and treatment of analytical databases.
12 | Complaints
We value your voice. If you notice something that violates this Code of Ethics, it is your duty to report it.
Complaints should be forwarded to: [email protected]. Anonymous reports are accepted. Retaliation against anyone who reports in good faith is itself a violation of this Code and is investigated with the same seriousness as the reported conduct. A good-faith report that proves unfounded does not subject the reporter to any sanction.
Cases of this nature will be evaluated from an ethical aspect and may be forwarded for disciplinary treatment.
13 | Complementary Provisions
We understand that non-compliance with the guidelines of this Code of Ethics represents a serious manifestation against ethics and against Impact's administrative principles. Anyone who fails to comply with the Code of Ethics is subject to penalties under normative instructions and may be held responsible in the judicial sphere.
Be Part of the Ethical Transformation
Be Part of the Ethical Transformation
Join Impact's community and be part of a genuine ethical transformation. Together we build a more just, transparent and regenerative future.
