Machine Translated by Google CODIM GUIDANCE COMMITTEE FOR RELEASE OF INFORMATION TO THE MARKET (ABRAPP – AMEC – ANBIMA – ANCORD – ANEFAC – APIMEC – B3 – CFC – IBGC – IBRACON – IBRI) GUIDANCE PRONOUNCEMENT No. 14, of September 4, 2012. REVISION - R1 of December 10, 2015 REVISION R2 - December 06, 2018 SUMMARY: BEST PRACTICES FOR DISCLOSING INFORMATION ON SUSTAINABILITY. NEED TO INFORM ABOUT THE MERGER PROCESS DO SUSTAINABILITY IN THE COMPANY'SDAILY LIFE AS A WAY TO CREATE VALUE FOR THE COMPANY, SOCIETY AND OTHER STRATEGIC AUDIENCES. The Guidance Committee for Disclosure of Information to the Market - CODIM, based on its competence, makes public that, after submitting the matter to a public hearing, it approved, by decision of its members at a meeting held on August 29, 2012, the this Guidance Pronouncement, which it does under the following terms: Conceptualization The concepts of Sustainability are focused on sustainable development and corporate social responsibility and are based on the premise that, in addition to the return to shareholders, the Company must disclose its commitment to defending human rights, social causes, responsible investments, efficient and conscious use of natural resources, its governance and transparency practices, diversity and the promotion of local development, generating a healthier economy, among other factors. These principles, in addition to being aligned with the Corporate Law and other important legal, market and voluntary regulations, are gradually consolidated in companies of all sizes, which include these themes in their strategy integrated with the economic and financial aspects of long-term, aiming at the preservation and creation of lasting value for civil society and its other strategic publics that influence or are influenced by it. The sustainable development of the Companies allows greater reliability and transparency to their investors about the future returns that may be obtained from their investments. Objective 1. The purpose of this Guidance Pronouncement is to induce the Company to disclose the strategies, actions and facts arising from the interaction and its socio-environmental and sustainable development commitments, involving its employees, investors, shareholders, customers, suppliers and other audiences 1 Machine Translated by Google in a broad and transparent manner, contributing to a better perception of the future of this Company. Disclosure of Information on Sustainability in General 2. The Company must render accounts to strategic audiences about socio-environmental information in a transparent, clear and integrated manner with economic and financial information, especially in the Annual Report (see PO No. 13 of CODIM) and preferably following the guidelines of the GRI - Global Reporting Initiative, the guidelines of the International Structure for Integrated Reporting of the IIRC – International Integrated Reporting Council – in addition to the Novo Valor Sustainability Guide, published by B3, an important tool in the presentation of options to the Company that wants to commit to the Sustainability theme. 3. The integrated information from all areas of a company, in addition to making the analysis and understanding of the business, risks and opportunities more complete and realistic, provides an alignment, being also an important test of consistency between the various sources of disclosure of your information. This integration means to coherently merge the socio-environmental aspect with the economic-financial aspect. What is important is the quality, consistency and relevance of the information disclosed in an Integrated Report, duly aligned with the Company's business model. 4. As the Company develops the process of inserting Sustainability principles into its business strategy, it must voluntarily add information on the subject in its regular reports. 5. The information must reflect the current stage and position of the Company in relation to the topic, whether positive or not. Following the guidelines of the “Report or Explain” initiative, it is recommended that those who do not disclose this information explain the reasons why they do not do so in the Reference Form and in the Annual Report. a) Company that does not adequately deal with socio-environmental issues increases exposure to risks and consequent loss of value. 6. The Company must give wide dissemination of information through its website Investor Relations, in the IPE (Periodic and Occasional Information), in addition to other means that it deems will contribute to the achievement of the objectives of this pronouncement. 7. It is recommended to use an Independent Auditor to ensure the integrity of the information disclosed by the Company in its reports, increasing credibility and transparency, conveying the message that this information is relevant, reliable and that its content and format are in line with organizational objectives and adequate in relation to standards defined by the Company. Benefits of the Practice and Disclosure of Information on Sustainability 8. The adoption of a Sustainability agenda mitigates risks and creates business opportunities, being a differential for the Company, as it produces competitive advantages perceived by the financial market and by society as a whole. Below we list some of the main benefits for the Company that adopts a sustainable agenda: a) Possibility of greater attractiveness and retention of talent; b) Possibility of reducing costs and/or increasing revenue with new products and services; 2 Machine Translated by Google c) Valuing products or services from the perspective of consumers, impacting the value of the brand, its strengthening and its visibility both nationally and internationally; d) Substantial improvement in the understanding of the Company's values and culture, providing new reflections and business opportunities; e) More complete and efficient assessment of the assets and liabilities involved, as well as the profitability and results of the Company by investment professionals, who now consider the socio-environmental information of the business; f) Possibility of participation of this Company's shares in Capital Market indices linked to Sustainability, adding more value to the Company and, consequently, to the shareholder; g) Financial Institutions favor financing aimed at this type of Company and, in some cases, restrict service to those that do not have sustainable practices; h) The Company also starts to demand sustainable practices from its chain of relationships, which can influence the choice of its suppliers and business partners, generating value for the chain as a whole. i) Reduction of risks, fines, interdictions and negative exposure in relation to the market; and j) Possible improvement in the pricing of its debt and equity instruments due to the transparency of its information and lower discount rate used in the evaluation made by investment professionals. Responsible Investment Principles 9. The Company must be aligned with the United Nations Global Compact and the Principles for Responsible Investment (PRI - Principles for Responsible Investment). The PRI, developed by representatives of an international network made up of institutional investors, supported by the United Nations, who believe that environmental, social and corporate governance (ESG ) issues are relevant and can impact the performance of their investment portfolios. a) The PRI encourages the adoption of ESG actions by the Companies, also encouraging transparency in relation to such practices, especially in relation to their progress, since this information is used in the analysis and investment decision-making processes. b) The same alignment guideline must be extended, in the specific case of Insurance Companies, in this case, to the Responsible Insurance Principles (PSI - Principles of Sustainable Insurance) launched at the United Nations Conference on Sustainable Development (Rio+20 Conference) in June 2012. High admnistration 10. The involvement of senior management in the definition and dissemination of the sustainability strategy linking socio-environmental and economic-financial aspects is essential to ensure the effective integration of the topic in decision-making processes and in the day- to-day of the business. It is the business leaders who insert the theme into the companies' business strategy and decisions, directly influencing the form, content and, above all, the strength and credibility of the disclosure of this information. The commitment of the executives and the Board of Directors is essential for the improvement of the Corporate Culture. 3 Machine Translated by Google 11. Senior Management must make the different levels of the Company aware of its social responsibility and engage strategic audiences in the exercise of practices that are environmentally correct, socially fair and economically viable (Triple Bottom Line). of the Shareholders 12. It is essential to involve the shareholders, since they are responsible, among other things, for the election of the Board of Directors and for the approval of the values and criteria for the compensation of the managers. To this end, we suggest the creation of communication channels (see item 17 of the “Structures for Sustainability”) between shareholders and the Company's bodies. Sustainability Diagnosis 13. The assessment of Sustainability practices is essential to identify risks and opportunities and to draw up an action plan. This diagnosis must be carried out periodically and disclosed together with the actions that will be taken to achieve the goals set. It is worth noting that the diagnosis must consider the business model and the characteristics of the Company, the sector and the country in which it operates, highlighting the Company's focus on Sustainability. 14. After carrying out the diagnosis, the Company must establish priorities according to the relevance identified for the activities and impacts on the Company. 15. The diagnosis must also take into account: a) eco-efficiency – efficient use of natural resources and reduction of environmental impacts through continuous improvement in production processes, generating economic and financial gains by reducing costs; b) relationships with its strategic audiences, including the value chain; c) sustainable business opportunities; d) the risks and impacts of Sustainability practices not only of an economic, but also of a social and environmental nature, qualifying and quantifying them whenever possible; and e) the link between accounting practices and records, evidencing their effective implementation in the Company. Public Commitments 16. The Company must be a signatory of general or sectoral commitments to be part of a learning and interaction network, including commitments to society and specific to its areas of activity (eg: Global Compact/UN and Sustainable Development Goals; Compact for the Eradication of Slave Labor; Carbon Disclosure Project; Water Disclosure Project; Forest Footprint Disclosure; Task Force on Climate-Related Financial Disclosures; Green Protocol, etc.). a) Participation in Capital Market indices based on Sustainability, such as the Dow Jones Sustainability World Index, Corporate Sustainability Index - ISE or Carbon Efficient Index - ICO2, among others, reflects the public commitment to the topic, strongly helping to disseminate these information. It is worth noting that simply filling in the questionnaires of these indexes properly contributes to a comparative analysis of the level at which the Company is in relation to its sector of activity, making it possible to generate a knowledge base for new sustainable initiatives. 4 Machine Translated by Google b) Participate directly or indirectly in the activities of the International Integrated Reporting Council - IIRC (International Council for Integrated Reporting), with the objective of monitoring the evolution of the integration of economic-financial data linked to data of a non-financial nature, anticipating the mandatory in the preparation and publication of the Financial Statements linked to the social and environmental dimensions and to good governance practices. Structures for Sustainability 17. It is important that the Company create an integrated management and governance structure for Sustainability, which reaches the different organizational levels, with a direct channel with the Company's communication areas, mainly with Accounting (aiming, when possible, to link disclosures with the records and disclosures made), Investor Relations, Institutional Relations and Press Relations. a) The number of instances must be adequate to the size of the Company and its structure (eg: Committee linked to the Board of Directors; Committees composed of employees, etc.) which will contribute to the credibility of the information presented. b) The availability of communication channels with strategic audiences is recommended to ensure the flow of information on the Company's strategies and practices, allowing the receipt of suggestions, comments, considerations or criticisms. Corporative identity 18. Disclosure of Sustainability commitments and practices will influence the Company's objectives and relationship with its strategic audiences. Thus, such practices must always be reviewed in relation to the Company's mission, vision and business model, as well as checking whether the Company's values reflect its commitment to Sustainability, providing an adequate understanding of all its employees and generating a coherent and consistent disclosure. 19. For the effective implementation of a sustainable agenda, it is essential that the entire Company works aligned around the same objective through continuous communication that encourages the involvement of all employees, who are the basis for the dissemination of a sustainable culture. Involvement of Strategic Publics 20. The first step must be to map the strategic audiences and involve, whenever possible, the entire chain of relationships of the Company, from suppliers to customers, ensuring efficient communication and engagement. 21. Next, a structured form of dialogue with stakeholders should be established in order to capture demands and receive feedback (eg meetings, surveys, negotiations, focus groups, stakeholder panels, etc.). 22. It is recommended that representations of strategic publics be used to make the communication channel viable, such as associations and unions that represent them. 5 Machine Translated by Google Sustainability Policy 23. The Company must prepare and disclose its Sustainability Policy, containing principles and guidelines that guide the areas in the planning and execution of their initiatives. It is important that this policy is developed, considering the expectations of strategic audiences in order to establish clear directions and actions aligned with them. 24. The Company must position itself on the so-called most sensitive issues relevant to the sector in which it operates, such as animal testing, climate change, biodiversity, local development, relationship with countries with an exception regime, corruption and other illegal practices, human rights, decent work, environmental protection, among others. This position must be compatible with the Company's activities, so that its statements can be credible. Definition, Monitoring and Disclosure of Indicators 25. The Company must create, monitor, follow up and update methods, tools, practices and indicators related to areas and operating units, verifying which and in what way they must be disclosed to the public, including its programmed investments and expected benefits related to the Sustainability of your business. Such instruments must be linked to the Company's business model and strategy, linking economic-financial objectives to socio- environmental objectives. 26. The Company must establish clear and objective socio-environmental goals, which are transparent and publicly known, in addition to being subject to external monitoring and review. This attitude, in addition to demonstrating effective commitment, generates credibility, strengthens reputation, minimizes risks and enhances opportunities for the Company. 27. The Company must present its performance in relation to the socio-environmental goals defined in previous periods, evidencing the level of achievement of these goals and the reasons why it was not able to achieve certain goals, if that is the case. case. Sao Paulo, September 04, 2012 Geraldo Soares Haroldo Reginaldo Levy Neto Speakers Geraldo Soares Haroldo Reginaldo Levy Neto coordinators Emílio Mayrink Sampaio – Reviewer R1 Fabiana Lopes da Silva and Fernando Fonseca - R2 Reviewers 6 Machine Translated by Google Recommended Reading: - Corporation Law - Law No. 6,404, of December 15, 1976. - CODIM Guidance Pronouncement Nº13 “Preparation and Dissemination of the Annual Report. - GRI – Global Reporting Initiative. - IR – Integrated Reporting do IIRC – International Integrated Reporting Council. - Novo Valor Sustainability Guide, published by B3. - CVM Instruction No. 480/09 amended by CVM Instruction No. 603/18. - CDP - Carbon Disclosure Project. - Task Force on Climate-Related Financial Disclosures. - PRI - Principles for Responsible Investment. - Dow Jones Sustainability World Index. - Corporate Sustainability Index – ISE. - Carbon Efficient Index - ICO2. 7