Terms and Conditions of the Commercial Partnership Program

Clause 1 — Definitions

1.1.Case: proceeding — administrative or judicial — brought by IKLAIM on behalf of a passenger to claim compensation arising from a delay, cancellation, overbooking or other flight irregularity, before airlines, regulatory bodies (such as ANAC, the European authority under Regulation EU261 or the British authority under UK261) or the courts.

1.2.Agent or Agency: individual or legal entity registered in the Program who refers passengers to IKLAIM for a Case to be opened.

1.3.Sales Partner: individual or legal entity appointed exclusively by IKLAIM, by invitation and under a separate internal agreement, to recruit and accredit new Agents or Agencies, and who may also act directly as an Agent for Cases they refer personally. Sales Partner status cannot be requested or obtained by registering in the Program: those who register join as an Agent or Agency.

1.4.Partner: generic term covering both the Agent/Agency and the Sales Partner.

1.5.Successful Case: Case for which IKLAIM has actually received the administrative compensation or the amount of the judgment, settlement or success fees in court proceedings, making the corresponding commission liquid, certain and payable.

1.6.Agent Commission: fixed amount owed to the Agent for each Successful Case they referred, according to the amounts in force in Annex I. The amount varies depending on whether the Agent is an individual ("Individual Agent") or a legal entity/Agency ("Business Agent"): the Business Agent, operating with its own structure and a higher recurring volume of referrals, receives higher amounts than the Individual Agent, as set out in Annex I.

1.7.Sales Partner Override: fixed, recurring amount owed to the Sales Partner for each Successful Case referred by an Agent they recruited who remains registered in the Program.

1.8.Opening Bonus: fixed amount owed only once to the Sales Partner, paid when the first Case referred by an Agent they recruited becomes a Successful Case.

Clause 2 — Purpose

2.1.The purpose of the Program is to remunerate Partners who (i) refer passengers to IKLAIM for Cases to be opened and/or (ii) in the case of Sales Partners appointed by IKLAIM, recruit new Agents or Agencies for IKLAIM's referral network, through payment of the commissions described in Clause 5 and detailed in Annex I.

2.2.Joining the Program is free of charge and does not require any investment, membership fee or purchase of products or services by the Partner.

Clause 3 — Legal Nature of the Relationship

3.1.Joining the Program and receiving commissions from it do not, under any circumstances, create an employment relationship, a partnership, an exclusive commercial agency or any form of subordination between the Partner and IKLAIM.

3.2.The Partner carries out referral and/or recruitment activities with full autonomy as to hours, means and methods of work, without hierarchical subordination, without control of working hours and without exclusivity, subject to Clause 9.

3.3.The Partner is solely responsible for paying the taxes levied on the amounts received under this Program — including, depending on their situation, social security contributions as a self-employed contributor, income tax and, where applicable, service tax (ISS) — and for issuing an invoice, self-employed payment receipt (RPA) or equivalent document required by law, IKLAIM being responsible for no withholding other than those required by law.

3.4.Should the collaboration between the parties in practice take on elements of personal service, regularity, subordination and remuneration typical of an employment relationship — for example fixed working hours, mandatory exclusivity, subordination to direct orders and use of IKLAIM's structure — the parties shall formalise the relationship through a specific instrument (employment or commercial agency contract, as the case may be), and these Terms shall not apply to that new relationship from the date of its formalisation.

3.5.This document does not constitute and shall not be construed as a commercial agency contract under Brazilian Law No. 4,886/1965, unless the parties expressly agree otherwise through a specific instrument.

Clause 4 — Registration and Joining the Program

4.1.To join the Program, the applicant must provide IKLAIM with at least: full name or company name; tax ID (CPF or CNPJ, or the equivalent in their country); address; payment details (bank account or Pix key); and, in the case of an Agent recruited by a Sales Partner, the name of the Sales Partner responsible for the referral.

4.2.IKLAIM may refuse the registration of any applicant, and suspend or cancel the registration of an accredited Partner, at any time and at its sole discretion, by written notice, especially in the cases provided for in Clause 10.

4.3.The Partner undertakes to keep their registration details up to date and is solely responsible for any delay or impossibility of payment resulting from outdated or incorrect details.

Clause 5 — Commission Structure and Payment Conditions

5.1.The amounts of commissions, overrides and bonuses in force on the date of joining are set out in Annex I, which forms an integral part of these Terms.

5.2.Payment of any commission is subject to the condition precedent that the corresponding Case becomes a Successful Case, as defined in item 1.5. No amount is owed for a mere referral, the opening of a Case or the registration of a new Agent that has not yet generated a Successful Case.

5.3.Commissions on administrative Cases shall be paid in euros (EUR); commissions on judicial Cases shall be paid in Brazilian reais (BRL). IKLAIM may, at its discretion and with the Partner's prior agreement, make payment in another currency, applying the commercial exchange rate in force on the payment date.

5.4.IKLAIM shall pay the commissions owed within 10 (ten) business days of confirmation of the Successful Case and of IKLAIM's actual receipt of the corresponding amounts.

5.5.Sales Partner Override: applies on a recurring basis to every Successful Case referred by an Agent recruited by the Sales Partner, as long as (i) the Agent's registration remains active in the Program and (ii) the Sales Partner's registration remains active in the Program on the date the Case becomes a Successful Case.

5.6.Opening Bonus: owed only once per recruited Agent, when the first Case referred by that Agent becomes a Successful Case. Subsequent Cases of the same Agent do not generate a new Opening Bonus, even if they generate the recurring Override.

5.7.When the Sales Partner personally refers a passenger, without the intermediation of an Agent they recruited, they are entitled to the Agent Commission set out in Annex I for that Case, which cannot be combined with any Override on themselves.

5.8.IKLAIM may change the amounts in Annex I at any time, at its sole discretion and regardless of the Partner's agreement or consent, with at least 15 (fifteen) days' notice. The new amounts apply only to Cases referred from the effective date of the change; Cases referred before it keep the amounts in force on the date of referral.

5.9.Referral attribution: for commission purposes, only claims from passengers who (i) accessed the IKLAIM platform through the Partner's unique link or QR Code, or (ii) entered the Partner's affiliate code when opening the claim will be considered the Partner's referrals. The referral is recorded when the passenger completes the claim; link visits, started forms or contacts that do not result in a completed claim do not constitute a referral.

5.10.Passengers who reached IKLAIM through other channels — including direct contact, internet search, advertising or third-party referral — will not be attributed to the Partner and will not generate a commission, even if the Partner claims to have advised them. The affiliate code may not be attributed retroactively to claims opened without it.

5.11.If the same passenger has accessed the links of more than one Partner, the referral will be attributed to the Partner whose link or code was used last before the claim was completed.

Clause 6 — Partner Obligations

6.1.Provide truthful, complete and up-to-date information about themselves and the passengers they refer.

6.2.Obtain from the referred passenger the authorisation needed to share their personal data with IKLAIM, under Brazilian Law No. 13,709/2018 (General Data Protection Law — LGPD), before making any referral.

6.3.Not make, on behalf of IKLAIM, any promise of amount, timeframe or result to passengers, nor charge the passenger, directly or indirectly, any amount, fee or commission not expressly authorised in writing by IKLAIM.

6.4.Act in good faith and not defraud the Program through disguised self-referral, fictitious Cases, duplicate referrals or any other device aimed at obtaining commissions improperly.

6.5.Keep confidential IKLAIM's commercial information to which they have access because of the Program, including the commission table, passenger lists and other Case data, for the term of the Program and for 2 (two) years after it ends.

6.6.In the case of the Sales Partner, guide and support in good faith the Agents they recruited on how the Program works, without taking IKLAIM's place in setting amounts, timeframes or conditions.

Clause 7 — IKLAIM Obligations

7.1.Pay the Partner the commissions owed, in the amounts, currencies and timeframes provided for in these Terms.

7.2.Provide the Partner, upon reasonable request, with information on the progress of the Cases they referred, subject to information protected by professional or legal confidentiality.

7.3.Process the personal data shared by the Partner in accordance with the LGPD.

Clause 8 — Personal Data Protection

8.1.For the purposes of the LGPD, IKLAIM acts as controller of the personal data of passengers related to the Cases. The Partner who collects and shares passenger data with IKLAIM acts as an occasional processing agent and must ensure they have a legal basis and the data subject's authorisation for such sharing.

8.2.The Partner undertakes not to use the passengers' personal data to which they have access for any purpose other than referral to the Program, nor to share it with unauthorised third parties.

Clause 9 — Confidentiality and Non-Solicitation

9.1.The duty of confidentiality set out in item 6.5 applies to Partners.

9.2.While registered in the Program and for 12 (twelve) months after it ends, the Partner undertakes not to induce passengers already referred to IKLAIM, nor other Agents of the network, to move their Cases or activity to IKLAIM's direct competitors, without prejudice to each passenger's right to freely choose their service provider.

Clause 10 — Fraud, Withholding and Reversal of Commissions

10.1.IKLAIM may withhold, suspend or reverse any commission, Override or Opening Bonus, even if already calculated or partially paid, in the following cases: (i) proven fraud or well-founded suspicion of fraud in the referral; (ii) fictitious or duplicate Case, or one based on false information; (iii) refund, reversal or chargeback, by the airline or by court decision, of the amounts that gave rise to the commission; (iv) breach by the Partner of any obligation under these Terms.

10.2.Where fraud is established, IKLAIM may additionally remove the Partner from the Program and take the appropriate legal action.

Clause 11 — Term, Termination and Account Removal

11.1.These Terms remain in force for an indefinite period from the Partner's joining the Program.

11.2.Either party may terminate the relationship at any time with at least 15 (fifteen) days' notice, without the need for justification and at no cost to either party.

11.3.Termination does not affect the Partner's right to commissions, Overrides or Opening Bonuses relating to Cases referred before the termination date, even if the Case becomes a Successful Case afterwards.

11.4.Once the Sales Partner's registration is terminated, the right to the Override on Cases referred by Agents they recruited ceases from the termination date, the Override remaining due on Cases referred before that date, even if success occurs afterwards.

11.5.Removal for inactivity: IKLAIM may deactivate the registration of a Business Agent (Agency) that goes 24 (twenty-four) consecutive months without accessing the affiliate portal and without registering any new referral, with 30 (thirty) days' prior notice sent to the registered email address. The Business Agent keeps the registration active by accessing the portal or making a referral within that period. This rule does not apply to Individual Agents, whose affiliate registration follows their IKLAIM customer account.

11.6.Removal for misuse: IKLAIM may immediately suspend and then remove the Partner's registration in the event of fraud; misuse of the link, QR Code, affiliate code or IKLAIM brand; unsolicited messages (spam); misleading advertising; breach of the LGPD; or breach of any obligation under these Terms, without prejudice to Clause 10.

11.7.Removal at the Partner's request: the Partner may request the removal of their account at any time by writing to affiliates@iklaim.com. Removal will be completed within 15 (fifteen) days of the request, subject to item 11.2.

11.8.Effects of removal: upon removal, the Partner's link, QR Code and affiliate code no longer generate new referrals. Commissions on Cases referred before the removal that become Successful Cases remain due, as set out in item 11.3, except where removal results from fraud or misuse, in which case Clause 10 applies.

11.9.After removal, the Partner's personal data will be deleted or anonymised, except for data IKLAIM must retain to comply with a legal or regulatory obligation, pay pending commissions or exercise its rights, in accordance with the LGPD.

Clause 12 — Limitation of Liability

12.1.IKLAIM does not guarantee the success of any referred Case, nor any specific timeframe for its conclusion, as these factors depend on third parties (airlines, regulatory bodies and the courts).

12.2.The Partner acknowledges that the commission is only due upon actual success, as set out in Clause 5, and that no remuneration, reimbursement of expenses or compensation is due for Cases that do not become Successful Cases.

Clause 13 — General Provisions

13.1.These Terms, including Annex I, constitute the entire understanding between the parties regarding the Program and supersede any prior oral or written understanding on the same subject.

13.2.Either party's tolerance of a breach of any provision of these Terms shall not imply novation or waiver of the right to demand future compliance.

13.3.If any provision of these Terms is held void or unenforceable, the remaining provisions shall remain in full force.

13.4.The Partner may not assign or transfer to third parties the rights and obligations arising from these Terms without IKLAIM's prior written authorisation.

Clause 14 — Jurisdiction

14.1.The courts of the District of Recife, State of Pernambuco, Brazil, are chosen to settle any disputes arising from these Terms, to the exclusion of any other, however privileged.