RELAND Code of Conduct

Letter from the Directors

At RELAND, "good business" is synonymous with correct business: legally sound, environmentally responsible, and socially legitimate. We exist to organize the rural real estate market with transparency, technical expertise, and respect for producers and communities, connecting responsible capital to quality assets and projects that generate income, conserve landscapes, and expand opportunities in the countryside.

This Code of Conduct translates this commitment into clear rules. It consolidates national standards — especially those of the COFECI/CRECI system, the Professional Ethics Code for Real Estate Brokers, the Civil Code (arts. 722–729), the LGPD, and anti-corruption and competition legislation — and incorporates international best practices for integrity and governance: independence, impartiality, honesty, professionalism, accountability, and risk management.

As a platform and operator specialized in rural real estate, we assume three central commitments: technical rigor (due diligence on ownership, environmental, and land use, always documented), informational precision (complete, verifiable data aligned with the asset's reality), and data protection (privacy by design, security by default). We expect the same from all who work with us — employees, partners, brokers, and suppliers — with probity in relationships, transparency in commercial conditions, and respect for people and the territory.

This Code is mandatory and guides daily decisions. When in doubt, prioritize integrity, consult Legal or our integrity channel, and say "no" to anything that doesn't meet our principles. Leadership is exercised by example; trust is preserved through coherence.

Júlio Mühlbauer & Valter Ziantoni
Directors — RELAND

1) Scope, Principles, and References

• Who is subject to it: employees, directors, brokers (individuals/legal entities), commercial partners, consultants, representatives, service providers, and suppliers who act on behalf of RELAND or on its platforms.
• Non-negotiable principles: legality, integrity, loyalty, diligence, transparency, confidentiality, respect for people/communities, sustainability, non-retaliation.
• Normative references: COFECI/CRECI (incl. Res. 326/1992 and amendments), Civil Code (brokerage), LGPD (Law 13.709/2018), Law 12.846/2013 (anti-corruption), Law 12.529/2011 (competition), Law 9.613/1998 (AML/FT), Forest Code (Law 12.651/2012), and state/municipal land use/licensing regulations.
• International standards: values and guidelines from the UNDP Code of Ethics (independence and impartiality; avoiding conflicts of interest; protection of resources, data, and reputation; respectful behavior; risk management; reporting and protection against retaliation).

2) Sectoral Compliance — COFECI/CRECI

• Professional duties: probity, technical care, suitable advertising, written contracting, accountability, refusal of illicit business, respect for prerogatives and the class's reputation.
• Prohibitions: unfair solicitation, deceptive advertising, “over-price”, undue retention of values/documents, collusion, unfair competition, unjustified abandonment, illicit favoritism, illegal practice.
• Identification: correct use of name/corporate name and CRECI (primary/secondary/temporary) when required; operation within regional qualification.

CODE OF CONDUCT

1. Independence and impartiality: every decision must reflect the best interest of the client, partners, and RELAND, free from internal or external pressures, favoritism, and conflicts of loyalty.

2. Probity and truthfulness: commercial, technical, and legal information must be complete, accurate, and clear; any relevant omission, data manipulation, or unverifiable promise is prohibited.

3. Technical diligence in rural real estate: asset qualification requires registry and ownership checks, georeferencing when applicable, environmental status, access logistics, productive vocation, and associated risks, with registration of these acts in the CRM.

4. Responsible advertising: commercial communication must be identifiable as such, avoid deceptive artifices, and never imply guarantees of results; images and simulations must be labeled as illustrative.

5. Personal data protection: data collection and processing follow legitimate purpose, minimization, security, and restricted access; incidents are communicated immediately and handled with priority.

6. Platform integrity: it is prohibited to circumvent controls, scrape databases, manipulate metrics, bypass authentications, or exploit vulnerabilities; credentials are non-transferable and subject to control.

7. Money laundering prevention: know your counterparty, identify warning signs, validate the lawful origin of resources when necessary, and refuse suspicious operations, recording and escalating the case.

8. Conflicts of interest: personal, family, corporate, or financial situations that may affect objectivity must be declared and managed with removal from decisions and formal mitigation paths.

9. Gifts and hospitality: only institutional items of symbolic value, without expectation of quid pro quo, are allowed; non-refusable offers per protocol are registered and allocated institutionally.

10. External activities: positions, lectures, publications, boards, and parallel businesses require prior approval and must not conflict with RELAND's activities, nor exploit privileged information.

11. Brand and intellectual property: distinctive signs, contents, methods, and software developed in professional practice belong to RELAND; copying, personal use, or unauthorized sharing is prohibited.

12. Records and documentation: reports, proposals, appraisals, and communications must accurately reflect facts and dates; forgery, undue backdating, material omissions, and destruction of evidence are very serious faults.

13. Communication and social media: only authorized spokespersons speak on behalf of RELAND; personal profiles must preserve confidentiality, independence, and good corporate image.

14. Relationship with clients and partners: respectful, transparent, and diligent service; commissions, refunds, and commercial conditions are informed objectively, without parallel agreements or “over-price”.

15. Third parties and suppliers: selection based on merit, value, and integrity; due diligence proportional to risk (reputation, regularity, sanctions, socio-environmental, and data protection) and contracts with compliance clauses and termination for violation.

16. Respect, diversity, and safe environment: harassment, discrimination, or abuse of authority is not tolerated; leaders ensure an inclusive environment, welcome reports, and act with speed and discretion.

17. Rural communities and rights of local populations: action sensitive to cultural context, clear communication, and informed consent; coercive or exploitative practices are prohibited.

18. Sustainability and environmental responsibility: intermediation considers current legislation, risks, and opportunities for regularization and restoration; facilitation of assets linked to environmental illicit acts or land grabbing is prohibited.

19. Risk management and controls: identify, assess, and mitigate legal, operational, data, ESG, and reputational risks; comply with internal controls and continuity plans, reporting incidents promptly.

20. Anti-fraud and anti-corruption: bribery, kickbacks, illicit “success fees”, documentary fraud, collusion, and misappropriations are prohibited; any request or offer must be refused and reported, with pursuit of reimbursement.

21. Transparency in commissions and sharing: observance of the agreed commission and applicable minimum practice; sharing between real estate agencies is formalized in writing, defining calculation base, deadlines, and proof of transfer.

22. Use of resources and security: assets, systems, vehicles, and corporate time are for professional purposes; non-compliance with security rules or unauthorized personal use is inadmissible.

23. Conduct outside work: private life cannot compromise RELAND's reputation; comply with local laws and avoid conduct that affects market or community trust.

24. Psychoactive substances: it is prohibited to act under the influence of alcohol or drugs; use of medications is only admissible if it does not compromise safety and performance.

25. Confidentiality and professional secrecy: strategic, commercial, personal, and technical information is protected and shared only on a “need to know” basis; the duty of confidentiality survives the end of the relationship.

26. Fair competition: anti-competitive practices, undue exchange of sensitive information, and market manipulation are prohibited; competing ethically strengthens the real estate chain.

27. Training and continuous improvement: adhere to training programs, refresher courses, and integrity tests; learn from incidents, adjust processes, and raise performance standards.

28. Reports and protection against retaliation: RELAND maintains a confidential channel for good-faith doubts and reports; any form of retaliation against those who report or cooperate is strictly prohibited.

29. Accountability and sanctions: violations of the Code may result in warning, dismissal, contract termination with partners, communication to competent bodies, and pursuit of full damage repair.

30. Leadership by example: those who lead set the ethical tone, prevent risks, support reports, resolve dilemmas with transparency, and promote an integrity culture that transcends people and business cycles.