StoneCo : Insider Trading Policy

STONECO LTD.

POLICY ON TRADING OF SECURITIES

ISSUED BY STONECO LTD. (INSIDER TRADING POLICY)

INFORMATION

CATEGORY

Public

AREA RESPONSIBLE

Investor Relations

APPLICABLE SUBSIDIARIES

StoneCo Group

APPROVAL

DATE OF APPROVAL

APPROVERS

March 7, 2024

Board of Directors of StoneCo Ltd.

REVISION HISTORY

REVISION NO.

DESCRIPTION

DATE

RESPONSIBLE / AREA

01

POLICY REVIEW

FEBRUARY 22, 2024

CORPORATE GOVERNANCE

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INDEX
1.	TERMS AND DEFINITIONS	3
2.	PURPOSE	5
3.	SCOPE AND APPLICABILITY	5
4.	APPROVAL	5
5.	EFFECTIVENESS	Erro! Indicador não definido.
6.	PRINCIPLES AND GUIDELINES	6
7.	GUIDELINES FOR SECURITIES TRADING	7
8.	EXCEPTIONS	10
9.	ADDITIONAL GUIDELINES	11
10.	APPLICABLE LIABILITIES AND PENALTIES	14
11.	REPORTING AND CONTACT CHANNELS	14
12.	LEGISLATION AND RELATED DOCUMENTATION	14

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1. TERMS AND DEFINITIONS

MANAGEMENT: means the members of the Board of Directors, the advisory committees to the Board of Directors and the Company's statutory Executive Officers.

EMPLOYEE: means any employee of the Company, in accordance with CLT (Brazilian Consolidation of Labor Laws) or internship regime, including the Company's statutory and non-statutory officers, regardless of where they are based.

COMPANY: means StoneCo, and the companies directly or indirectly controlled by it, as applicable.

BOARD OF DIRECTORS: means the Board of Directors of the Company.

EXECUTIVE OFFICERS: means the Officers of StoneCo, elected by the Board of Directors, and the statutory Officers of the companies controlled by it, as applicable.

MATERIAL NON-PUBLIC INFORMATION: has the meaning assigned to it in item 7.1. hereof.

NASDAQ: means NASDAQ Stock Market, located in New York City, USA.

SUBJECT PERSON(S): means, for the purposes of this Policy, (i) the Employees, including their Related Persons; (ii) members of the Company's Board of Directors and of the advisory committees to the Board of Directors, as well as their Related Persons; (iii) Executive Officers, as well as their Related Persons; (iv) any person who, by virtue of a position, function or position in the Company, is aware of Material Non- Public Information, including their Related Persons; (v) other persons that the Company, at its discretion, considers relevant for the purposes of this Policy and that have undertaken the duty to comply with it; and/or (vi) other third parties who may be identified as potential subject persons by the Company, from time to time.

RELATED PERSON(S): means, for the purposes of this Policy, a family member of a person or entity that may influence or be influenced by such person in their negotiations with the Company, including, but not limited to (i) the spouse or partner; (ii) child(ren) and stepchild(ren); (iii) any person who is economically

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dependent on such person and/or their spouse or partner, including dependents listed in their annual income tax adjustment return; and (iv) companies directly or indirectly controlled by the specific person or persons mentioned in the items above.

POLICY: means this Policy on Trading of Securities Issued By SroneCo Ltd. (Insider Trading Policy).

SEC: means the United States Securities and Exchange Commission.

STONECO: company incorporated and validly existing under the laws of the Cayman Islands, with its registered office at Harneys Fiduciary (Cayman) Limited, 4th Floor, Harbour Place, 103 Church St., PO Box 10240 KY1-1002, Georgetown, Cayman Islands, registered with CNPJ/MF (Brazilian Taxpayers' Registry) under No. 31.752.270/0001-82.

SECURITY(IES): means the common shares, common stock options, debt securities and any other securities that the Company may issue from time to time, such as preferred shares, warrants, bonds and convertible debentures, as well as derivatives related to the Company's securities, including securities exchangeable for securities of the Company, depository receipts representing securities of the Company, whether or not issued by the Company, such as exchange traded options, and also shares of investment funds that invest predominantly in securities of the Company.

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2. PURPOSE

1. This Policy aims to determine the principles and guidelines to ensure that trading of the Company's Securities is carried out in accordance with the legislation in force and applicable to the Company, with the purpose of preventing the improper use of any Material Non-Public Information by Subject Persons, preventing the practice of insider trading.
2. This Policy does not, in any way, exempt the Subject Persons from complying with the regulations that are in force on the subject, including, but not limited to, federal and state laws of the United States, the Cayman Islands, rules issued by the SEC, as well as Brazilian legislation and legislation from other foreign jurisdictions on the subject, with said persons being subject to the applicable penalties in case of non-compliance with such rules.

3. SCOPE AND APPLICABILITY

1. This Policy applies to negotiations carried out with the Company's Securities, and shall be complied with by the Subject Persons.
2. This Policy applies to any person indicated above, including his/hers Related Persons, that terminates his/hers relationship with the Company and who is aware of Material Non-Public Information, until said information is disclosed, in accordance with this Policy, or for the period of 120 (one hundred and twenty) days from the end of the relationship, whichever occurs first.
3. Subject Persons are fully responsible for communicating the terms of this Policy to their Related Persons and for ensuring compliance by such persons in the best possible way, with such Related Persons also being subject to applicable penalties.

4. APPROVAL

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This Policy and any amendments thereto shall be evaluated and recommended by the Executive Officers of StoneCo and approved by the Board of Directors of StoneCo.

5. EFFECTIVENESS

This Policy takes effect on the date of its approval and shall be updated to the extent that the actions or topics described herein are changed, or in the event of an amendment or applicable regulatory requirement.

6. PRINCIPLES AND GUIDELINES

1. The actions of each Subject Person must be guided by the duty of loyalty, veracity and good faith, as well as by the principles determined by the Company's Code of Ethics.
2. The disclosure of Material Non-Public Information to anyone is prohibited, except for those people in the Company who, due to their positions, must have access to such information. All Subject Persons have the duty to ensure the confidentiality of Material Non-Public Information and to adopt security measures with respect to the discussion and proper storage of such information.
3. Subject Persons are prohibited from providing, commenting, sharing, photographing or filming, through any means of communication, including the internet and social networks, any Material Non-Public Information.
4. The responsibility of the Subject Persons will extend to acts carried out by third parties, whenever such third parties act under the influence, guidance or delegation of the Subject Person. Nevertheless, this Policy does not exempt liability arising from legal and regulatory provisions attributed to third parties not directly linked to the Company and who are aware of Material Non-Public Information.
5. Subject Persons must adhere to the terms of this Policy by signing a Commitment Term at the time of their hiring, election of positions, promotion or transfer, in which they will declare that they know and agree with all the terms of this Policy, as well as they undertake the obligation to observe them.

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7. GUIDELINES FOR SECURITIES TRADING

7.1. MATERIAL NON-PUBLICINFORMATION

1. In general, there is no exhaustive definition of what is Material Information, and its relevance must be analyzed on a case-by-case basis. A piece of information can be considered relevant when there is a probability that it is considered relevant to the decision-making process of buying, holding or selling securities - that is, it may influence the share price of a company. Any information that could affect a company's share price, whether positively or negatively, regardless of whether the change is large or small, may be considered material. The information does not need to be consummated or definitive to be considered material.
2. Although it may be difficult to determine whether information is material, there is a range of

information that is extremely sensitive and should therefore always be considered "Material Information". Examples of such information include:

1. financial results or related information;
2. accounting or net equity changes;
3. projections of future revenues, gains, or losses;
4. any spin-off, consolidation, substantial disposal of assets, joint venture, merger or any corporate restructuring (even if not implemented);
5. creation of a relevant direct or contingent financial obligation and/or the possible failure to comply with such obligation;
6. entering into, changing or terminating relevant agreements and/or contracts;
7. impending bankruptcy or financial liquidity problems;
8. gain or loss of a relevant client, customer or supplier;
9. launch, resumption or interruption of the offer or sale of a product or service, representing present or future material revenues or expenses;
10. regulatory issues and strategies inherent to the Company's activity;
11. issuance of shares or structuring of operations in the capital market;
12. changes in pricing strategies;
13. changes/modifications in the Management;
14. material litigation, investigation or regulatory exposure;

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1. change of control of the Company;
2. security incidents; and
3. the Company's strategic plan.

7.1.3. Information is not considered public until it has been widely disclosed to the market (through an official statement from the Company or through filing of a document containing said information with the SEC) and the public has had a reasonable time to absorb said information.

7.2. PROHIBITION OF USE OF MATERIAL NON-PUBLICINFORMATION

7.2.1. The use of Material Non-Public Information for any purpose harmful to the Company is prohibited, including but not limited to:

1. buy, sell or, in any way, engage in any operations of this nature, or assist any person in this regard, directly or indirectly, related to the Company's Securities;
2. make recommendations, give guidance or express opinions on trading of the Company's Securities, based on such information (Tipping);
3. disclose such information to any third party; and/or
4. help anyone in the activities listed above.

7.2.2. The above restrictions also apply to the trading of securities of another company, by any person who has material and non-public information relating to that other company, when such information is obtained in the course of a relationship of any nature on behalf of the Company and/ or involving the Company.

7.3. BLACKOUT PERIOD

7.3.1. The Company has established quarterly blackout periods, therefore, Subject Persons will not be able to conduct any operation with Company's Securities during the period that begins 35 (thirty-five) calendar days before the date of the quarterly disclosure of the Company's results and lasts until the beginning of the first business day (in New York City, United States of America) following the first full day available for trading of the Company's Securities following the quarterly disclosure of the Company's

results ("Blackout Period").

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1. The Investor Relations area may establish an additional period of prohibition and will communicate the Subject Persons, as well as other persons they consider relevant. The imposition of an additional period of prohibition is, in itself, a confidential information, and the fact that it has been imposed may not be disclosed to any other persons.
2. The Company may not, during a Blackout Period, trade its own Securities and/or execute/implement repurchase programs for its own Securities.
3. Subject to the provisions above, trading of the Company's Securities is permitted during periods that are not considered Blackout Periods. The trading of Company's Securities by Subject Persons listed in Exhibit Ihereto must be previously approved by the Investor Relations Officer of StoneCo and the Legal Officer of StoneCo. The trading of Company's Securities by the Investor Relations Officer must be previously approved by the Chief Executive Officer of StoneCo.

7.4. RESTRICTION PERIODS AD HOC

7.4.1. The Investor Relations area may impose special restriction periods during which certain Subject Persons will be prohibited from buying, selling or carrying out transactions with any Company's Securities

or derivative securities ("Restriction Period ad hoc"). If a Restriction Period ad hoc is imposed, the Investor Relations team will notify certain Subject Persons, who thereafter shall not engage in any covered transaction involving the Company's Securities and shall not disclose the existence of the Restriction Period ad hoc to others.

7.5. OTHER APPLICABLE SPECIFIC RESTRICTIONS

7.5.1. The following transactions are considered high risk and are prohibitedas indicated below, even if the Subject Person is not in possession of Material Non-Public Information:

1. SHORT SALE. Short sale represents the trading of a security with the expectation that it will decline in value. Short selling may create a false perception regarding the Company's securities and harm the Company's reliability and image. In this sense, the carrying out of short sales by any Subject Persons is prohibited.

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1. RENTAL OF SECURITIES. The rental of any Security of the Company is prohibited.
2. OPTIONS. A put option gives the investor the right to sell the security at a certain future date at a fixed price, and a call option the right to buy the security at a specific fixed price until a pre- established date. Put options are usually bought when a person believes the price of a security will fall, and call options are bought when a person believes the price of a security will rise. Carrying out transaction with options may create a perception of trading with the Company's Material Non-Public Information. In this sense, carrying out any transactions with options (put or call) or other derivative operations related to the Company's Securities on a stock exchange or any other organized market, as well as on the over-the-counter market, is prohibited.
3. HEDGING TRANSACTIONS. A hedging transaction aims to protect a financial operation from possible price changes. Given its nature, it is prohibited to carry out hedging transactions, including swaps, collars, exchange funds and fixed-term sales contracts. Such transactions give a shareholder the chance to lock in a large portion of the value of their shares, often in exchange for all or part of the shares' expected potential appreciation. These transactions allow the shareholder to continue to hold the securities covered by these transaction, but without the risks and full rewards that accompany ownership. As participation in these transactions may cause a person of the Company to no longer have the same objectives as the other shareholders of the Company, no Subject Person of the Company may engage in such operations.
4. 1. SPECULATION. Short-range speculation based on market fluctuations puts the personal gain of Subject Persons in conflict with the best interests of the Company and its shareholders, thus, the acquisition or disposal of the Company's Securities is prohibited before 180 (one hundred and eighty) days have elapsed, respectively, from the last sale or acquisition of the Company's Securities on the stock exchange or over-the-counter market.

8. EXCEPTIONS

8.1. INCENTIVE PLANS. This Policy does not apply to the acquisition of shares by an applicable Subject Person or through the Company's stock-based incentive plans, including, but not limited to, the Restricted

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