Kobana
Legal Document

Code of Ethics

A map of who we want to be, and what we choose not to be.

Last updated: May 7, 2026

CEO's Message

Codes of ethics tend to be long, defensive, and written to protect companies from the people who work in them. Ours is not.

Kobana exists because we believe a company can be built differently — without reproducing the logic of concentrating power and wealth that dominates the world, without trapping people in routines without purpose, without trading integrity for short-term results. This code is the written form of the commitment we make among ourselves and with anyone who relates to Kobana in any way — customers, partners, suppliers, society.

It is not a list of prohibitions. It is a map of who we want to be, and what we choose not to be.

Rafael Lima's signature

Rafael Lima — CEO

Who we are

Kobana Tecnologia Ltda. (CNPJ 05.813.794/0001-26) is a financial technology company, headquartered in Barueri/SP, Brazil, with a fully remote team. We chose this format because we believe in working relationships built on autonomy, responsibility, and mutual respect.

Kobana

Our values and principles

Who we are, what guides us, and how we choose to act.

Our

VALUES

They are who we are. When everything else is gone, they are what remain.

  • Love

    We do it because it matters, not just because it pays.

  • Fellowship

    We carry it together. No one delivers alone, and no one is left behind.

  • Respect

    Every person, no exceptions, deserves the treatment we ourselves would want to receive.

  • Simplicity

    Complicating is easy. Simplifying takes work — and that is what we pursue.

  • Safety

    We look after the safety of Kobana's people, our customers, and everyone who is part of our ecosystem.

  • Transparency

    We say what needs to be said, even when it is uncomfortable. We are transparent because that is how trust is built.

Our

PRINCIPLES

They are how we work.

  • High performance

    Quality and depth are non-negotiable. Performance must be high to meet our expectations. The satisfaction of delivering more than expected and being driven by results.

  • Loving relationships

    Professionalism is not coldness. We value warm, balanced human relationships grounded in empathy, understanding, respect, kindness and compassion.

  • Attention to detail

    Detail is a form of care. Differentiation lives in the details — we believe the details matter and make all the difference.

  • Creativity and innovation

    All our work is born from the creativity of doing things differently and focuses on innovation as a result — newness with usefulness.

  • Sustainable pace

    We do not value hard-work that creates excess or accelerated paces that cannot be sustained in the long run.

  • Long-term vision

    What we decide today must shape the future. What we do today thinks of the years ahead — we are not seduced by short-term gains and do not chase them at any cost.

We take care of your processes, while you focus on your purpose.

How we treat each other

We spend many hours working. A good part of life happens in here. That is why how we treat each other matters as much as any deliverable.

We listen before responding.

When someone says something hard, the first reaction is to understand, not defend. This applies to technical feedback, to disagreement, and also when someone comes with something personal.

There is no place for violence — in any form.

Not physical, not verbal, not written, not in the silence that excludes. Moral and sexual harassment, and discrimination based on race, gender, sexual orientation, religion, age, disability, origin, social condition or any other characteristic, is incompatible with Kobana and has immediate consequences.

We disagree with care.

Conflict is part of it. We treat disagreement as an opportunity to get closer to the truth, not as a contest of who shouts louder. We attack ideas, never people.

We tell the truth, with respect.

Sugar-coating feedback helps no one. Neither does offending. There is a middle path: saying clearly what needs to be said, in the way we would want to hear it, when it needs to be said.

Diversity is practical wealth, not rhetoric.

Different points of view make work better. That is why we seek a diverse team and protect the space for each person to show up whole — with their story, their way of thinking, their language.

Colleagues' privacy is protected.

What is known about someone — diagnosis, family situation, compensation, history — stays with those who need to know. People's privacy will always be respected, regardless of context.

We make mistakes. And acknowledge them.

Whoever makes a good-faith mistake finds welcome, conversation, adjustment. Mistakes are not punished. Whoever covers up their own mistake or someone else's loses the trust that holds everything together and has no place here.

How we relate to our customers

Kobana's customer entrusts their operation to us. That is serious.

We don't sell what the customer doesn't need.

Never. If the right product is a simpler one, or none, that is what we recommend.

We don't use information asymmetry to win.

The customer may not know everything we know about the product, the market, the financial system. That is not an advantage to extract value — it is a responsibility to inform.

When we make mistakes, we say so.

We don't hide. We don't outsource the blame. We fix what can be fixed and correct the process so the mistake doesn't return. We assume our humanity and fragility and work to keep improving.

Complaints are valuable information.

Whoever complains is going to the trouble of helping us improve. We treat it with the seriousness it deserves and act, however hard it may be, to resolve the issue.

How we relate to partners, suppliers and competitors

Fair negotiation.

Kobana has bargaining power in many relationships. We use that power with weight and responsibility — not to extract conditions the other party cannot meet.

We pay on time.

Late payment corrodes the lives of those smaller than us. It is not a cash-flow lever. We do not negotiate longer terms with smaller suppliers.

Choosing a partner is a technical and ethical decision.

We don't favor friends, relatives, or acquaintances in hiring processes. We choose by the whole: technical qualification, security, and trust.

What we demand of ourselves, we demand of suppliers.

Whoever works with us — develops software, runs infrastructure, supports customers — needs to be aligned with this code where applicable.

Competition is fair.

We talk about our product, we don't speak ill of others'. We don't fix prices, we don't divide markets, we don't trade sensitive information with competitors. If a competitor tries that kind of conversation, we end the conversation.

How we relate to money

Money is a means, not an end. For Kobana, and for every person on the team.

Accounting is honest, always.

We don't dress up numbers, we don't create fictitious expenses, we don't hide liabilities. There is no result good enough to justify bad accounting.

We don't pay or receive bribes.

Not direct, not indirect, not disguised as commission, travel, gift, or favor. It applies to any agent — public, private, regulator, partner. No exceptions, no gray areas.

Gifts and courtesies have a limit.

If the gift is large enough to influence a decision, it is too large to accept. When in doubt, ask before accepting — in relevant cases, register it.

Company resources are for the company.

Corporate card, tools, platform credits, team time — none of that is personal property. Occasional and reasonable use is part of life; systematic and opportunistic use is not.

Conflict of interest is not shame — hiding it is.

If you are involved in something that may affect your judgment at Kobana (external partnership, side activity, family relationship with a supplier, investment in a competitor), declare it. We talk and decide together how to handle it.

How we relate to work

Sustainable pace is the rule.

There are peak moments, and we deliver hard in them. Continuous overload work is a planning failure, not heroism.

Rest is non-negotiable.

Weekends, vacations, end of the workday. We don't expect responses during those times, and we don't interrupt those who are away. Real urgency is rare; manufactured urgency does not justify intrusion.

Quality comes from care, not from rushing.

Attention to detail — in code, in text, in spreadsheets, in customer service — is a form of respect for whoever will read, use, and depend on it.

We decide for the long term.

A shortcut that weakens the company three years from now is not a shortcut — it is postponed loss.

Learning is part of the work.

Studying, erring, reflecting, returning with what was learned. That is delivery, not pause.

We don't take outside what belongs to the company.

Code, processes, customer base, methodology, material developed in here belongs to Kobana. It applies during and after the contract.

How we relate to the world

Kobana doesn't exist in a vacuum. What we do has effects on community, market, and the environment.

We don't help concentrate power and wealth.

When a decision has the effect of increasing asymmetry — between large and small customers, between us and partners, between Kobana and the team — we weigh it again.

Following the law is the floor, not the ceiling.

There is no discussion about strictly following what is defined in the laws.

We fight money laundering, terrorism financing and fraud.

There are processes, controls, training, and alerts. Whoever operates on these subjects has direct responsibility to follow the specific policies and raise suspicion as soon as it appears.

We care for the environment.

In choosing suppliers, infrastructure, and travel — when there is an alternative with lower impact and reasonable cost, that is the preferred alternative. We make sustainable choices.

Political participation is personal.

Each person has an opinion and the right to live it. Kobana, as a company, takes no partisan position and does not donate to campaigns or candidates. When you speak publicly about politics, you speak as you, not as Kobana.

Privacy, data and information

We work with people's financial data. It is the most sensitive thing there is.

Customer data is only for what the customer authorizes.

We don't use it for anything else, we don't share it with third parties, we don't take it out.

Confidential information is truly confidential.

It includes what we see in meetings, in customer service, in code, in systems. It includes after the person no longer works here.

Privileged information is not a personal advantage.

If you have access to something that is not yet public — about Kobana, about a customer, about an operation — don't use it for your own benefit or for third parties. Don't trade assets based on it. Don't tell someone so they can trade.

Equipment and access are for work.

Occasional personal use is part of life. Equipment provided by Kobana and access to company systems may be audited, with criteria and registry, in situations involving information security or incident investigations.

Security is everyone's responsibility.

It is not just the security team's. Locking the screen, not falling for phishing, not sharing passwords, reporting incidents early — that is everyone's job.

External communication

Who speaks for Kobana is defined.

Press, corporate social media, public events: there are people who formally represent the company. If you are approached by a journalist or influencer about something at Kobana, forward it to the responsible area before answering.

Your personal voice is yours.

You can have your own profile, your own opinion, your own public presence. When you talk about topics that touch Kobana or our market, make it clear you speak as you — and avoid exposing confidential information or compromising the company's image.

Kobana's public tone is simple and honest.

No promises we don't keep, no inflated data, no offensive comparisons.

When things go wrong

Mistakes happen. What matters is what we do next.

It is safe to speak up.

If you saw, heard, or suspect something that violates this code, or simply are not okay with something — speak up. There are paths:

Direct conversation

With the person involved, when it makes sense and is safe.

Reference person or leadership

Reach out to whoever supports your area to help you handle the situation.

Private message to the CEO

Receives reports confidentially and acts immediately.

There is no retaliation.

Whoever reports in good faith is protected, period. Retaliating against someone who brought a problem is a serious violation of this code, with immediate consequences.

We investigate with care.

Every report is taken seriously, investigated confidentially, and the person named has the right to position themselves before any decision.

Consequences are proportional and, whenever possible, educational.

Good-faith mistakes tend to become conversation, adjustment, training. Deliberate conduct against the values has firmer consequences — it may include termination of the contractual relationship and, in cases provided by law, communication to the authorities. What does not exist is theatrical punishment to "set an example".

This code is alive

This document is not law. It is a compass.

Real life brings situations it did not foresee. When that happens, return to the values and principles, talk to someone who can help you think, and make the decision you could explain face to face — to a colleague, to a customer, to someone you love, to yourself ten years from now.

If you think something here is wrong, dated, or could be better, speak up. This code belongs to all of Kobana. We review it when it makes sense, and anyone can propose changes.

Contact

For questions, suggestions, or to report a violation of this Code of Ethics, please get in touch:

contato@kobana.com.br

Kobana Tecnologia Ltda.

Calçada das Margaridas, 163, Sala 02 Centro Comercial Alphaville - Barueri, SP - CEP 06453-038

CNPJ: 05.813.794/0001-26