B3 S A Brasil Bolsa Balcão : Insider Trading Policy

INSIDER TRADING POLICY

INTERNAL INFORMATION

17/08/2020

INSIDER TRADING POLICY

TABLE OF CONTENTS
1	PURPOSE ....................................................................................................	3
2	SCOPE .........................................................................................................	3
3	REFERENCES .............................................................................................	4
4	RULES GOVERNING INSIDER TRADING ..................................................	4
5	FORMER COMPANY ADMINISTRATORS ..................................................	8
6	RESPONSIBILITIES.....................................................................................	8
7	FINAL PROVISIONS ..................................................................................	10
8	CONTROL INFORMATION ........................................................................	10

2	INTERNAL INFORMATION

INSIDER TRADING POLICY

1 PURPOSE

The purpose of this Policy is to provide guidance on the rules for trading in securities issued by B3 S.A. - Brasil, Bolsa, Balcão and in derivatives based on them.

2 SCOPE

This Policy applies to the following subject persons of B3 S.A. - Brasil, Bolsa, Balcão, its subsidiaries and affiliates abroad, B3 Bank, BSM Market Supervision, Cetip Info Tecnologia S.A., B3 Social, and other associations (Subject Persons and Company, respectively):

• Members of the Company's Board of Directors (Board Members);
• Members of the supporting Committees to the Company's Board of
  Directors, created pursuant to the Company's Bylaws (Committee Members);
• Members of the Company's Management Board (Management Board Members);
• Other employees, interns, trainees and services providers physically located at the Company's facilities (Employees, for the purposes of this Policy);
• Spouses of Board Members, Committee Members and Employees not judicially or extrajudicially separated, life partners and economic dependents included in annual tax returns (Related Persons);
• Companies directly or indirectly controlled by Board Members, Committee Members, Employees and Related Persons (defined together with Related Persons as Connected Persons);

3	INTERNAL INFORMATION

INSIDER TRADING POLICY

• Third parties with whom Board Members, Committee Members and Employees have a fiduciary or portfolio management agreement (Third Parties); and
• The Company.

1. REFERENCES
2. • Brazilian Federal Law 6385/1976;
   • Brazilian Federal Law 6404/1976;
   • Brazilian Securities and Exchange Commission (CVM) Instruction 358/2002;
   • The Company's Bylaws;
   • The Company's Code of Conduct and Ethics; and
   • The Company's Disclosure Policy.
3. RULES GOVERNING INSIDER TRADING

4.1 Nonpublic material information

Subject Persons are prohibited from trading in securities issued by the Company or derivatives based on them while in possession of nonpublic material information.

The ban on trading in securities issued by the Company or derivatives based on them while in possession of information on a material event ceases to apply as soon as the Company discloses the information concerned.

4.2 Trading blackout periods

Subject Persons are forbidden to trade in securities issued by the Company or derivatives based on them during the trading blackout periods stipulated by the

4	INTERNAL INFORMATION