Whistleblowing Channel

Every report received by Novadata undergoes a confidential, rigorous, and impartial process aimed at ensuring thorough investigation of reported facts and implementation of appropriate measures, always in compliance with current legislation and company values.

The report processing flow occurs in well-defined stages:

• Receipt and Registration
  Once submitted, the report is logged in our proprietary system with timestamp and provided data (anonymous or identified) and immediately routed to the screening team.
• Triage and Classification
  Reports are preliminarily assessed for relevance, severity, and sufficiency of information to proceed with an investigation. If needed, identified reporters may be contacted for further clarification.
• Internal Investigation
  If validated during screening, the report is forwarded for detailed review by a dedicated committee, potentially involving Compliance, Legal, and HR departments, depending on the subject. Investigations may include interviews, document verification, system analysis, and other appropriate measures.
• Conclusion and Actions
  Following the investigation, appropriate actions are taken, which may include warnings, termination for cause, internal process restructuring, or referral to competent authorities, as necessary.
• Feedback to the Reporter (if Identified)
  If the report is not anonymous and contact information is provided, the reporter will receive feedback on the investigation outcome, respecting legal limits and the confidentiality of any involved third parties.

Novadata upholds process integrity and information confidentiality, ensuring no report is ignored or archived without review. Anonymity is guaranteed for those who choose not to identify, and all reports are handled with impartiality and professionalism.

Novadata commits to protecting personal data provided through this Whistleblowing Channel, ensuring its use is strictly limited to investigating reported facts and implementing appropriate administrative, disciplinary, or legal measures.

This channel complies with Law No. 13.709/2018 – General Personal Data Protection Law (LGPD) – and adheres to the principles of purpose, necessity, transparency, and information security.

By completing the reporting form and choosing to identify yourself, you agree to the processing of your personal data exclusively for the following purposes:

• Recording and storing the report;
• Contact for requesting additional clarifications, if necessary;
• Internal investigation of reported facts;
• Communicating the outcome of the report, where applicable;
• Compliance with legal and regulatory obligations.

If you choose not to identify yourself, no personal data will be collected, and anonymity will be guaranteed throughout the process.

All provided data are handled with the highest level of confidentiality and protected by technical and administrative information security measures. Access is restricted to personnel involved in the investigation; sharing with unauthorized third parties is prohibited.

Identified reporters may, at any time, request information regarding the processing of their personal data and exercise their rights under Articles 17 to 22 of the LGPD via Novadata's official support channel.

By submitting an identified report, you declare awareness and agreement with the terms of this document and authorize the processing of your personal data within the limits described herein.