1.1. In compliance with CVM Instruction 358, the present policy – the terms of which are defined in section II below – aim at establishing (i) the policy of disclosure of material act or fact, and (ii) the policy for the trading of the Company’s securities, to be observed by (a) its controlling shareholders, officers, members of the Board of Directors, of the fiscal council, and of any other technical or advisory bodies, established by the Company’s Bylaws, (b) employers and officers having access to Inside Information; and; (c) whomever, by virtue of their title, office or position in the Controlling Shareholders, Subsidiaries or Affiliated Companies, is aware of information related to Relevant Act or Fact.

1.1.1. The Related Persons shall sign the respective Compliance Statement, as per the model attached to this policy as Exhibit I.

1.1.2. The Company shall maintain at its headquarters a list of persons signing the Compliance Statement, with their respective qualifications, positions or duties, addresses, and corporate or individual taxpayer’s identification number. The list shall always be maintained at the CVM’s disposal (CVM Instruction no. 358, article 16, paragraph 2).