Code of Ethics

All Administrators, employees and Staff of Vision Brazil Investments shall guide their professional activities based on a sense of awareness and diligence that any prudent and diligent person would employ in the management of his/her own personal business. Vision Brazil Investments’ Administrators, employees and Staff shall place the Clients’ interest as their priority, acting with loyalty and avoiding practices that may be detrimental to the existing fiduciary relationship with such Clients, aiming at achieving the highest possible ethical and professional standards in the services provided.

Thus, the Administrators, employees and Staff of Vision Brazil Investments shall:

Comply with the rules applicable to their activities. The activities of Vision Brazil Investments are regulated by several authorities. Administrators, employees and Staff shall be fully aware of and comply with the regulations applicable to their activities.

Understand the fiduciary relationship maintained with the clients. Hence, Administrators, employees and Staff shall act with integrity, diligence, respect and with ethical standards, placing the clients’ interest as a top priority and maintaining the confidentiality of clients’ information and portfolios.

Perform their duties in order to meet the objectives and investment policies of the clients. While conducting their activities, Administrators, employees and Staff shall always use their best judgment and act prudently, carefully and with integrity when making any such judgment.

Eliminate conduct deviations. The independence and objectivity of investment recommendations made by Vision Brazil Investments must not be affected by conflicts of interest and Administrators, employees and Staff shall not take or participate in any actions that may be detrimental to Vision Brazil Investment’s reputation.

Prioritize transparency. Administrators, employees and Staff shall provide information requested by clients on the assets composing their portfolio(s).

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