MercadoLibre : Code of Ethics for Suppliers and Business Partners (EN)

Mercado Libre Code of Ethics for suppliers and business partners.

This is who we are, what we believe in, and how we connect.

MELI CODE +

Mercado Libre code of ethics for suppliers and business partners

This code of ethics (MELI CODE +) applies to all suppliers of goods and services and business partners of MercadoLibre Inc. and all its subsidiaries and companies (hereinafter "Mercado Libre" or "MELI"), including contractors, subcontractors, agents, and representatives (hereinafter "Suppliers" or "Third Parties").

The signing of the contract, and/or the acceptance of a purchase order, and/or the supply of goods/services to Mercado Libre constitute the acceptance of the

MELI CODE+

If any part of this code conflicts with local laws or regulations, only the sections of this code permitted by those laws shall apply.

Because this is who we are And this is what we

believe in

this is how

we connect

MELI CODE +

We are a committed team, united by a great purpose.

We innovate, make an impact, and pursue major transformations, guided by ethical values that define who we are and how we operate.

We always choose the correct way, without shortcuts, to

achieve our purpose: "Democratize commerce and financial services to transform the lives of millions of people in Latin America."

We operate with suppliers and business partners, key links in our value chain, to foster a virtuous network.

Together we create new solutions that multiply the opportunities for growth and development for all parties.

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MELI CODE +

Creating value together

MELI CODE + encompasses the ethical, operational and environmental standards we expect our Suppliers and Business Partners to comply with.

Our goal is to establish transparent and meaningful relationships in every interaction with Mercado Libre.

By connecting under these standards, we build a network of ethical conduct.

Consequently, compliance with this code absolutely conditions the selection of our Suppliers, the possibility of initiating any type of business or operation together, and its sustainability over time.

If you are reading this, you are part of the Mercado Libre´s value chain

Your behavior defines us.

Your actions impact.

Your ethical commitment counts.

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MELI CODE +

Minimum standards of business conduct we expect from all our Third Parties.

MELI CODE + regulates the relationships we establish with people and companies operating in the value chain of our ecosystem.

01

I N T E G R I T Y I N H O.W

W E D O B U S I N E S S

Anti-corruption.

Financial integrity

Protection of information

Intellectual property

Responsible use of artificial intelligence

Conflict of interest

Free competition and commerce

Prevention of money laundering, combating terrorism financing, and compliance with sanctions programs.

02

M U T U A L R E S P E C T A N D D I G N I T Y

Mistreatment and/or discrimination

Child labor, forced labor and modern slavery

03

S A F E A N D H E A L T H Y

W O R K E N V I R O N M E N T S

04

E N V I R O N M E N T A L I M P A C T

05

T O G E T H E R, W E P E R F O R M W I T H E X C E L L E N C E

06

S Y N E R G I E S A N D C O O P E R A T I O N

Cooperation

Non-compliance

Reporting and communication.

MELI CODE +

01

Integrity in our way of doing business

We act with integrity across the different markets and countries we operate in, with committed teams that grow and diversify to generate a positive impact, overcoming geographical, cultural, and financial barriers in the region.

This dynamic approach demands an ethical framework that is always updated, with clear, specific, and transparent guidelines that align with our purpose and encompass our entire value chain.

We invite you to continue growing alongside us with integrity, and to expand

our impact, values, and commitments to transform the lives of millions of people in Latin America.

Discover MELI CODE + and integrate its standards into your business practices.

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MELI CODE +

01	I N T E G R I T Y I N H O W
	W E D O B U S I N E S S

Anti-corruption

We do not tolerate corruption in any of its forms.

We have a risk-basedAnti-corruption Program designed to prevent, detect and remedy actions contrary to existing regulations. We also require our employees and Suppliers to comply with the applicable regulations in every country we operate in.

We strictly prohibit requesting, giving or receiving, directly or through third parties, money or anything of value intended to influence the decisions of other people to obtain undue advantages or benefits.

This restriction applies to the relationship between Mercado Libre´s Suppliers and employees, as well as to any relationship between Suppliers and other third before whom we are represented, particularly if it involves public officials.

#ExtiendeMELICODE+

Members of the value chain may only give or receive gifts and courtesies as part of the occasional exchange that builds trusting and reliable business relationships.

If you are going to give a gift or courtesy to a third party on behalf of Mercado Libre, always consult our Ethics and Complianceteam to confirm its feasibility and ensure that it is acceptable according to the requirements:

• They must be modest, traditional, and associated with industry practices and customs.
• They must not violate any law or regulation.
• They must not be perceived as a way to obtain an advantage.
• They must not be given in cash

Your responsibility is to act with absolute transparency and commitment to the standards presented here:

Supervise employee practices to ensure they are ethical and comply with these standards and applicable laws.

If you interact with government bodies and/or public officials on behalf of Mercado Libre,

it is essential to:

• Comply with the financial controls required by Mercado Libre.
• Fully and transparently safeguard and store the documents that support transactions.
• Comply with the anti-corruption commitments undertaken.
• Request authorization from Mercado Libre if you need to subcontract third parties in connection with the services to be provided.

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01	I N T E G R I T Y I N H O W
	W E D O B U S I N E S S

Financial integrity

The integrity of financial information is an essential condition for the development of our ecosystem.

We rely on our books and records to make business decisions and inform financial results, among other uses.

We disclose information to the U.S. Securities and Exchange Commission (hereinafter "SEC") in a complete, fair, accurate, updated, and understandable way, in accordance with the regulations established by SEC and by the corresponding regulatory authorities.

#ExtiendeMELICODE+

As part of our value chain, you must:

• Maintain transparent books and records, documenting fully and accurately all transactions and operations. This includes records of financial and commercial operations, and interactions with public entities related to transactions made within the Mercado Libre ecosystem.
• Cooperate with any request of information that Mercado Libre may require as part of our commercial relationship in order to fulfill the responsibilities and obligations of disclosing or reporting to third parties or other government authorities.

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01	I N T E G R I T Y I N H O W
	W E D O B U S I N E S S

Protection

of information

At Mercado Libre, the protection of the information we handle and that is stored in our systems is of utmost importance. We understand the serious damage that could be caused if it was disclosed or shared with unauthorized third parties.

The proper treatment of the information we handle is a duty as well as an opportunity to generate trust in our value chain.

*Confidential information: any data, document, record, memo, or content protected by industrial or intellectual property rights, as well as any information, in any format (oral or written, whether physical or digital) to which you have access and that is not publicly available.

**Personal data: any type of information that may directly or indirectly identify a person.

#ExtiendeMELICODE+

Take these precautions to protect confidential information and personal data**:

• Protect the personal data you receive from or collect on behalf of Mercado Libre, implementing the necessary security measures.
• Comply with applicable data protection legislation and internal Mercado Libre policies, ensuring responsible data processing.
• If you deliver packages sold through Mercado Libre, remember to safeguard the personal data of sellers and buyers you have access to.
• Adopt appropriate security measures and controls according to the sensitivity of the information you handle.
• Guarantee appropriate measures in order to promptly correct and report any information security violation and incident you detect.

The Suppliers who access to confidential information of Mercado Libre during the commercial relationship are obligated to preserve it before, during, and after the relationship ends. It must not be used or disclosed to third parties without the prior authorization of Mercado Libre, except when authorized by law. (!)

Insider trading. If you gain access to material non-public information related to Mercado Libre:

• You must not use it for your own direct or indirect benefit. Consequently, you must not trade securities or shares based on this kind of information, nor should you disclose or share it.

The information is considered material if it can be expected to affect the price of a company's shares, whether positively or negatively, and regardless of whether the change is large or small.

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01	I N T E G R I T Y I N H O W
	W E D O B U S I N E S S

Intellectual property

At Mercado Libre we respect and protect our own and third parties´ intellectual property rights, including trademarks, designs, domain names, software, knowhow, among others.

We ensure the authenticity, integrity and quality of the products offered on our platform.

#ExtiendeMELICODE+

• If you are authorized by contract, you may use our intellectual property responsibly and in accordance with the provisions of ourLegal Brandbook
• While providing goods and services for Mercado Libre and/or its users, you must guarantee you have all the necessary intellectual property rights and that you do not infringe upon third party rights.

The procurement of services or purchase of products by Mercado Libre does not imply an authorization of use or the assignment of its intellectual property rights, which are protected by local and international laws.

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