2.1. Controlling Shareholders: shareholder or group of shareholders bound by a shareholders’ agreement or under common control, holding the controlling power of the Company, pursuant to the provisions of the Law no. 6,404/76 and its further amendments.

2.2 Material Act or Fact: any decision of a Controlling Shareholder, resolution of a general meeting or of the Company’s administrative organs, or any other political-administrative, technical, business or economic-financial act or fact related to the Company’s business, which may affect in a considerable way:

(i) the quotation of the Securities;
(ii) the investors’ decision to buy, sell or keep Securities; and
(iii) the investors’ decision to exercise any rights inherent to their position as Securities’ holders.

2.3. Stock Exchanges: stock exchanges and/or organized over-the-counter market entities, national or foreign, where securities are accepted for trading.

2.4. Company: Santos Brasil Participações S.A.

2.5. Accredited Brokers: Securities brokers accredited by the Company for the trading of the Securities by persons subject to the present policy.

2.6. CVM: the Brazilian Securities and Exchange Commission.

2.7. Investor Relations Officer: the officer nominated by the Company’s Board of Directors, responsible for providing information to investors, to the CVM and to the Stock Exchanges, as well as for updating the registration of publicly-traded company, and who shall also be responsible for the execution and follow-up of the disclosure and trading policies set forth herein.

2.8. Inside Information: any information related to a Material Act or Fact not yet disclosed to the market, as provided for by laws or by the present instrument, to which the Related Persons have inside access by virtue of the office or position they hold.

2.9. CVM Instruction 358: CVM Instruction no. 358, of January 3, 2002, and further amendments, which provides for the disclosure and use of information about Material Acts or Facts related to publicly-traded companies, as well as about the trading of securities issued by publicly-traded companies pending a Material Fact not disclosed to the market, among other matters.

2.10. CVM Instruction 400: CVM Instruction no. 400, of December 29, 2003, and further amendments, which provides for the public offers of securities, in primary or secondary markets.

2.11. Relevant Shareholding: shareholding corresponding, direct or indirectly, to five per cent (5%) or more of type or class of shares representative of the Company’s capital stock.

2.12. Related Persons: in relation to the Company, jointly or individually, (a) Controlling Shareholders, officers, members of the board of directors, of fiscal council, and of any 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 a Material Act or Fact.

2.13. Trading Policy: policy for the trading of Securities, approved by the Company’s board of directors as provided for in the article 15 of the CVM Instruction no. 358, described herein.

2.14. Individual Investment Programs: individual plans for the acquisition of Securities filed at the Company’s headquarters, through which Related Persons have announced their intention of investing in Securities with own funds, on a long-term basis.

2.15. Affiliated Companies: companies in which the Company has an interest of ten percent (10%) or more, without controlling them.

2.16. Subsidiaries: companies in which the Company, directly or through other subsidiaries, is the holder of partner rights that entitle it, on a permanent basis, to prevail in corporate decisions and grant it the power to elect the majority of the administrators.

2.17. Compliance Statement: statement of compliance with the present policy, document to be executed as provided for by the articles 15, paragraph 1, section I, and 16, paragraph 1, of the CVM Instruction no. 358

2.18. Securities: in its wider meaning, any shares, debentures, subscription warrants, subscription receipts and rights, promissory notes, call and put options, indices and derivatives of any type, as well as any other securities or collective investment agreements issued by the Company, or related thereto, which, by legal decision, are deemed to be securities.