INTEGRITY POLICY AND PREVENTION OF EARNINGS MANIPULATION AND OTHER FRAUDS

ADMINISTRATIVE PROVISIONS

OBJECTIVE AND SCOPE

1. This Integrity and Prevention of Results Manipulation and Other Fraud Policy aims to establish the guidelines and steps taken by Futuras Apostas to guarantee the integrity of bets and prevent fraud and results manipulation, ensuring a safe and transparent Betting environment for Bettors and Platform Users, in accordance with the guidelines of Law 14.790/23 and Law 14.597/23.
2. This policy applies to all employees, Bettors, Platform Users, and third parties involved in Futuras Apostas's fixed odds Betting and online gaming operations.

GLOSSARY 

1. For the purposes of this Policy, the following are considered:
   
   Bettor: a natural person who places a bet.

   Betting Platform: a digital channel integrated into the betting system, used to offer sports betting and online games to Bettors.

   Platform User: a natural person registered on the Betting platform, regardless of whether they have placed a bet.

   Betting: an act whereby a certain amount of money is put at risk in the expectation of obtaining a prize.

   Manipulation of Results and Other Frauds: intentional collusion, act or omission aimed at unduly altering the result or course of a sports competition, undermining the unpredictability of the competition, test or sports match with a view to obtaining an undue benefit for oneself or others.

   Inside Information: any data or knowledge that is not publicly available, which could influence the outcome of sporting events or Betting behavior.

GUIDING PRINCIPLES

1. Transparency and Compliance: Futuras Apostas prioritizes transparency in its processes, policies and terms and conditions and complies with the laws and regulations applicable to its activities, also seeking to comply with the best national and international practices in the sector.

2. Protection of User Data: Futuras Apostas implements security measures compatible with its activities to protect the privacy and personal data of Bettors and users of the platform, in compliance with the General Personal Data Protection Law (Law No. 13,709 of August 14, 2018).

3. Protection of Minors: Our Terms and Conditions (T&C), as well as all our internal guidelines and policies, establish guidelines aimed at protecting minors. From our advertising and marketing activities to the moment you register on our platform, all actions by Futuras Apostas must be cautious and not appeal to minors.

4. Responsible Gambling: We encourage responsible and rational gambling by providing truthful information about the practice of Betting and online games, with the aim of raising awareness about the risks and possibilities offered by gambling.

5. Education and Information: We promote accessible education on odds, risks and Betting strategies, providing clear and unbiased information to our Bettors and Platform Users.

6. Fraud prevention: We have implemented anti-fraud technologies and tools to combat fraud, match-fixing and illegal Betting. We also collaborate with the authorities in the fight against corruption in the sports Betting industry.

7. Anti-Corruption: We have implemented effective policies and procedures to prevent scams and corruption-related actions, including rigorous verification of clients' identities through technological tools such as the use of facial recognition and continuous monitoring of suspicious activities.

8. Collaboration with Authorities: We cooperate fully with the authorities responsible for regulating the sector, sharing relevant data and assisting in investigations when necessary, with the aim of promoting integrity and trust in the industry.

PEOPLE BARRED FROM BETTING

1. Futuras Apostas establishes clear guidelines on who is barred from participating as a Bettor on its platforms, in accordance with applicable legislation and regulations, and uses technological identification tools to help ensure the guidelines are effective. The participation of the following persons is prohibited on the Betting Platform:
   i. under 18 (eighteen) years of age;
   ii. owner, administrator, director, person with significant influence, manager or employee of the operating agent, as well as their spouses, partners and relatives in a direct or collateral line, up to and including the second degree,
   iii. public agent with duties directly related to the regulation, control and supervision of the activity within the scope of the federative entity in whose staff he exercises his powers;
   iv. persons who have or may have access to computerized fixed-odds lottery systems, spouses, partners and relatives in a direct or collateral line, up to and including the second degree,
   v. a person who has or may have any influence on the outcome of a real sporting event that is the subject of a fixed-odds lottery, including spouses, partners and relatives in the direct or collateral line up to and including the second degree:
   a) a person who holds the position of sports manager, sports coach, coach and member of the coaching staff or who holds a position that could influence the outcome of the real event or has access to privileged information about the real sports event;
   b) sports referee, assistant sports referee or equivalent, sports entrepreneur, agent or attorney for athletes and coaches, coach or member of a coaching staff;
   c) member of the management or supervisory body of a competition organizer or sporting event;
   d) athletes participating in competitions organized by the entities that are part of the National Sports System; and
   vi. a person diagnosed with ludopathy, according to a report from a qualified mental health professional or Bettors who opt for the measures described in art. 4, inc. IV, of SPA/MF Ordinance No. 1,231/24.

2. Futuras Apostas informs such impediments prominently on its marketing channels, ensuring that all users of the platform are aware of the rules and regulations governing participation in Betting.

BET MONITORING

1. Futuras Apostas establishes a partnership with Integrity Compliance 360 (IC 360) with the purpose of implementing and consolidating integrity and security practices aimed at effectively combating match-fixing and fraud in the sports Betting market. Through its expertise and advanced monitoring technology, IC 360 commits to providing technical and methodological support, access to data analysis tools, and strategic consulting to assist Futuras Apostas in identifying and preventing illegal activities that could compromise the integrity of the Betting environment.

2. This partnership provides Futuras Apostas with access to advanced anti-fraud monitoring technologies and ongoing technical support to mitigate risks related to match-fixing. Additionally, the association with IC 360 strengthens Futuras Apostas's reputation as a platform committed to the highest standards of integrity, security, and regulatory compliance, offering a robust response to the requirements imposed by national and international legislation and, thereby, mitigating operational and reputational risks.

3. We also use fraud detection algorithms that analyze Betting behavior and identify potentially fraudulent activities.

4. Futuras Apostas reserves the right to suspend the activities of Bettors' graphical accounts and the payment of prizes arising from bets investigated in which there is reasonable doubt as to the manipulation of results or corruption in sporting events, for the duration of the investigation process, under the terms of the applicable legislation.

5. With the support of IC 360, Futuras Apostas commits to promptly report to the relevant authorities any signs of match-fixing or other illegal activities that may be identified, in strict compliance with applicable legislation. When required, these reports will be made through the Betting Management System – SIGAP, ensuring full transparency and cooperation with regulatory authorities in the Betting sector.

GUIDING PRINCIPLES

1. We adopt strict "Know Your Client" (KYC) procedures to verify the identity of Bettors, including the collection of identification documents and proof of address when registering on the platform, as well as facial recognition systems.

2. We carry out periodic checks to ensure that user information is continually updated and correct, in compliance with anti-money laundering (AML) guidelines.

PREVENTING THE MISUSE OF INSIDER INFORMATION

1. It is expressly forbidden for employees, service providers, affiliates, business partners or anyone with access to privileged information to use such data to place or facilitate bets, either for their own benefit or for that of third parties.

2. Futuras Apostas adopts security measures commensurate with the risks of its activity to protect sensitive data and ensure that privileged information is stored and processed securely in compliance with applicable data protection laws . This includes encryption, multi-factor authentication and strict access control policies.

3. Only authorized employees will have access to confidential data, in accordance with their professional responsibilities. Our internal information is classified into levels of sensitivity, and access to each level is granted only to individuals who need that information to carry out their duties.

4. Access to systems and information is continuously monitored to detect and prevent unauthorized access. Any suspicious behavior will be investigated, and immediate corrective measures will be applied.

5. Any persons involved in the misuse of Inside Information will be subject to the sanctions provided for in this Policy and/or in the applicable legislation.
    

TRAINING AND AWARENESS

1. We provide regular and mandatory training for all employees, focusing on responsible gaming practices, identifying signs of match-fixing and other fraud, as well as training on the ethical use of information and the legal and disciplinary consequences of misusing Inside Information. These trainings are updated periodically to reflect changes in regulations and industry best practices. 

2. We implement periodic evaluations to ensure that employees fully understand the procedures and know how to identify suspicious activity. Performance reviews also consider adherence to integrity and anti-fraud practices.

3. In addition to internal training, we provide educational materials and awareness campaigns aimed at Bettors and users of the platform. These materials highlight the risks of match-fixing, the legal consequences and the best practices for safe and responsible gambling.

4. Our affiliates and commercial partners also undergo training programs, ensuring that they understand and follow the established integrity rules. This includes joint 

RESPONSIBLE AREA

1. The Integrity and Compliance Department is Futuras Apostas's focal point for issues related to Betting integrity and the prevention of match-fixing and other fraud. Futuras Apostas's Integrity and Compliance Department is responsible for:
   i. Develop Futuras Apostas's integrity plan and supervise its execution.
   ii. act as the central recipient of all integrity-related information, including whistleblowing and irregularity reports.
   iii. develop and maintain effective reporting mechanisms to detect potential manipulation of results and fraud.
   iv. create and implement awareness campaigns and educational programs aimed at preventing fraud, manipulation of results and other illicit behavior, involving all stakeholders.
   v. carry out training and educational sessions on integrity with employees, affiliates, agents and other relevant stakeholders.
   vi. conducting initial investigations into possible cases of match-fixing, including interviews with witnesses and suspects, and gathering information, starting with the creation of a procedure for handling complaints and investigations related to possible fraud.
   vii. prepare and send detailed reports on the cases investigated to the competent judicial bodies and independent entities.
   viii. participate in initiatives to exchange information and good practices in the sector, collaborating with other organizations and authorities.
    

NATIONAL AND INTERNATIONAL COOPERATION

1. We partner with regulatory bodies, sports leagues, federations and other national and international entities and stakeholders to promote integrity in sport and curb attempts to manipulate results. We believe that dialog and collaboration are essential to address the challenges of manipulating sports competitions.

2. Futuras Apostas is associated with Integrity Compliance 360 (IC360), a global organization that works to promote integrity in sport by combating fraud, match-fixing and other illicit practices in sports Betting. The partnership with IC360 reinforces Futuras Apostas's commitment to the best practices in the sector, ensuring compliance with international and national regulations. More information about IC360 can be found on its official website: IC360.
    

 REPORTING CHANNELS

1. We encourage the reporting of suspicious activity by offering secure and anonymous communication channels for employees, Bettors and partners to report any behavior that suggests manipulation of results or other fraud, available 24 hours a day, 7 days a week. We guarantee protection against retaliation for whistleblowers and treat all reports rigorously and confidentially.

2. Any complaints received will be forwarded to the Integrity and Compliance Department, which will proceed with the actions described in its own investigation plan. All recipients of information must guarantee the confidentiality of the complaint and the identity of the people involved.

3. Any suspicious activity can be reported through the following channels: [email protected].

CONSEQUENCES OF VIOLATION

1. Any violation of the provisions of this Integrity and Prevention of Earnings Manipulation and Other Fraud Policy, whether by employees, service providers, affiliates, business partners or users, will be subject to disciplinary measures to be applied in proportion to the seriousness of the violation and as provided for in internal rules and current legislation. Sanctions may include, as applicable:

2. For employees, service providers, affiliates, business partners or affiliates (based on the criteria established in the Internal procedure for handling complaints and investigations):
   a) Warning;
   b) Temporary suspension of activities or functions;
   c) Termination of employment contracts or business partnerships;
   d) Prohibition of new partnerships or future contracts.

3. For users
   Suspension or Banning from the Platform: for users who engage in fraudulent practices, manipulation of results or any other illicit activities that violate this Policy:

   • Temporary Account Suspension: the user's account may be temporarily suspended while the suspicious activity is under investigation. During this period, access to the platform and placing new bets will be blocked.
   • Permanent Ban: in cases of proven fraud, manipulation of results or other serious violations, the user's account will be permanently banned, making any future access to the platform impossible. In addition, winnings or bonuses obtained through illicit activities will be retained by Futuras Apostas in accordance with applicable regulations.

4. Those involved in acts of results manipulation or fraud may be held civilly and criminally liable, in accordance with current legislation. Futuras Apostas reserves the right to seek compensation for damages caused by such acts, including financial losses and damage to its reputation.

5. In cases where evidence of fraud is confirmed, the manipulated or defrauded bets will be annulled; the bets of the Bettors not involved in the fraud and who have been harmed will be refunded; and the accounts of the Bettors involved will be suspended for a fixed period or closed.

6. In the event of the closure of the account of a Bettor who has committed fraud proven through an investigation process, Brazino 777 reserves the right to withhold the amount deposited by the Bettor up to the limit of the damage caused.

INFRINGEMENT REGISTRATION SYSTEM

1. Futuras Apostas will implement an automated system for recording all infractions committed by users, employees, affiliates and partners. This system will allow the analysis of behavior patterns, helping to identify repeat users and enabling the adoption of more severe measures, as necessary.

REPORTING TO COMPETENT AUTHORITIES

1. In accordance with current legislation and regulations, any evidence of fraud, match-fixing or other illegal activities will be reported to the relevant authorities, including Betting regulators and anti-fraud bodies.

2. Indications of manipulation of the results of sporting events will be communicated by Futuras Apostas within five working days from the date on which they are identified, via the Betting Management System - SIGAP.

COLLABORATION WITH INVESTIGATIONS

1. Futuras Apostas undertakes to cooperate fully with official investigations, providing all necessary information in accordance with the law and taking proactive measures to facilitate the actions of the authorities in combating fraud and manipulation of results.

PUBLICITY OF SANCTIONS

1. In cases of serious violation of this policy, especially related to the manipulation of results, Futuras Apostas may choose to publicly disclose the sanctions applied in order to reinforce the commitment to integrity and deter similar practices in the future. Such disclosure will be made in compliance with applicable legal standards and the protection of personal data.

REVIEWING AND UPDATING THE POLICY

1. This policy will be reviewed annually or at shorter intervals, as necessary, to ensure alignment with market best practices and applicable legal and regulatory provisions.