Companhia Brasileira de Distribuiçao Netherlands B : Policy on The Disclosure, Use of Material Information and on the Preservation of Confidentiality

Index
1. PURPOSE....................................................................................................................	2
2. SCOPE.........................................................................................................................	2
3. GLOSSARY.................................................................................................................	2
4. GENERAL GUIDELINES...........................................................................................	4
4.1. Persons to whom this Disclosure and Adhesion Policy applies.................................	4
4.2. Duties and Responsibilities........................................................................................	4
4.3. Exception to the Immediate Disclosure of Relevant Information..............................	6
4.4. Duty to Keep Material Information Confidential.........................................................	6
4.5. Obligation to Indemnify.............................................................................................	7
4.6. Disclosure and Negotiation Committee......................................................................	7
4.7. General Conduct and Prudential Rules Guidelines.....................................................	8
4.8. Term...........................................................................................................................	8
4.9. Amendments..............................................................................................................	8
4.10. FINAL PROVISIONS.............................................................................................	9
5. PENALTIES.................................................................................................................	9
6. REFERENCES...........................................................................................................	10
7. ANNEXES.................................................................................................................	10

1. PURPOSE

This Disclosure Policy has the purpose of providing for rules to be observed by the Investor Relations Officer and other Persons Bound regarding the disclosure of Material Information and the preservation of confidentiality of Material Information, which has not yet been

disclosed to the public. The Company's Disclosure Policy was prepared under the terms of

the applicable regulation governing capital markets.

Any questions concerning the provisions hereof, the applicable regulation issued by the Brazilian Securities and Exchange Commission (CVM) and/or the need to disclose information to the public shall be clarified by the Investor Relations Officer.

2. SCOPE

Valid for all Employees of GPA's Business Areas and Units and audiences that relate to the Group, such as, but not limited to Third Parties, Clients, Public Authorities and Shareholders.

3. GLOSSARY

Upon the adoption and interpretation of this Disclosure Policy, the terms listed below shall have the following meanings:

Controlling	A shareholder or group of shareholders bound by a shareholders'
Shareholder	agreement or under common control, which holds direct or indirect
	control over the Company, under Law No. 6404/76, as amended
	from time to time.
Managers	Officers and members, both permanent and deputy, of the
	Company's Board of Directors.
Material Act or Fact	Any (i) decision made by a Controlling Shareholder; (ii)
	resolution made by the annual meeting or the Company's
	Managers; or (iii) any other act or fact of a political- administrative,
	technical, business or financial-economic nature which has
	occurred or is related to the Company's businesses, and which may
	substantially affect: (a) the trading price of the Company's
	securities or related thereto; (b) investors' decisions to purchase,
	sell or keep such securities; or (c) investors' decisions towards
	exercising any rights inherent to their capacity as holders of
	securities issued by the Company or related thereto.

Stock Exchanges	It means BM&FBovespa, as well as any other stock or other over-the-
	counter markets, organized for the trading of securities in general in
	which the Company holds Securities subject to trading.

Disclosure	and	A body intended to assist the Company's Investor Relations Officer,
Trading Committee	created with the purpose of helping them in performing their duties
		before the CVM.
Members of the Fiscal	The members of the Fiscal Council of the Company, both permanent
Council		or deputy, once summoned, elected by a resolution of the Company's
		Shareholders' Meeting.
CVM, the	Brazilian	Investor Relations Officer. The Company's Officer responsible for
Securities	and	providing information to investors, to the CVM, and to Stock
Exchange		Exchanges, as well as for updating the Company's registration as a
Commission.	publicly-held company with the CVM.
Former Managers:	Managers who no longer hold the position of Managers in the
		Company.
Material Information	It means any decision made by a Controlling Shareholder, resolution
		made by the Annual Meeting or the Company's management bodies
		or any other act or fact of a political-administrative, technical,
		business or financial-economic nature which has occurred or is
		related to the Company's businesses, and which may substantially
		affect: (i) the trading price of Securities; (ii) investors' decisions to
		purchase, sell or keep such Securities; or (iii) investors' decisions
		towards exercising	any rights inherent	to their capacity of
		s ecurities holders.	An exemplificative list	of situations that may

be defined as Material Information is provided by Article 2 of CVM Ruling No. 358/2002, CVM Instruction No. 358, dated January 3, 2022, as amended. Law No. 6.404/76, Law No. 6.404, dated December 15, 1976.

Persons Bound to the Company, its direct or indirect Controlling Shareholders, Managers, Members of the Fiscal Council or members of any other agencies with technical or consulting attributions, created by statutory provision or whom, as a result of their position or function at the Company, its Parent Company, Subsidiaries or Associates, is aware of the information related to the Material Information, as well as other professionals which had expressly acceded to the Company's Confidentiality Preservation and Material Information Use and Disclosure Policy. Associated companies, the companies in which the Company has significant influence, without controlling it, under paragraphs 1, 4 and 5 of Article 243 of Law No. 6404/76, as amended. Controlled Companies, the companies in which the Company, directly or through other companies, is holder of partner's rights that ensure thereto, in a permanent manner,

preponderance in corporate deliberations and the power to elect the majority of managers. Parent Companies, companies controlling the Company, directly or indirectly, which have or may have such quality under the terms of Law No. 6.404.76 and its further amendments.

Participation Agreement, participation agreement hereto, to be executed according to the template contained in Annex I hereto. (v) Securities. shares, debentures, subscription warrants, receipts and subscription rights, promissory notes, put or call options, indexes and derivatives of any kind or, still, any other securities or collective investment contracts issued by the Company or referenced thereto, which are considered securities by legal definition.

4. GENERAL GUIDELINES

4.1. Persons to whom this Disclosure and Adhesion Policy applies

• The obligations provided by this Disclosure Policy also apply, for purposes of express accession, to Bound Persons.
• Bound Persons shall expressly adhere hereto, upon execution of the Participation Agreement, under the terms of Exhibit I.
• The Company shall keep at its headquarters the list of persons who have executed the Participation Agreement, with their respective identification and personal data, position or function, address and enrollment number with the Ministry of Finance Corporate Taxpayer Registry (CNPJ) or Individual Taxpayer Registry (CPF).

Whenever changes or alterations are made to individual or personal data, the persons bound by the Participation Agreement shall immediately inform the Company about such alterations, by communicating them to the Investor Relations Officer, who shall update and keep them always available to the CVM.

• The Participation Agreements shall remain filed at the Company's registry office for as long as the persons bound thereby remain connected with the Company, and for at least five years following termination thereof.

4.2. Duties and Responsibilities

• The Investor Relations Officer shall:

1. disclose and inform the CVM and the Stock Exchanges, immediately after becoming aware, of any material act or fact concerning the Company's business, deemed to be a Material Information;
2. Care for the broad and immediate dissemination of Material Information, simultaneously in the Stock Exchanges and in all markets where the Company holds

Securities subject for trading, as well as to investors in general; and

1. Provide the competent agencies, upon demand, with all additional clarifications concerning the disclosure of such material act or fact.

• The communication of Material Information to CVM and the Stock Exchanges shall be made immediately by means of a written document, which shall describe in detail the acts and/or facts occurred, indicating, as possible, the amounts involved and other clarifications necessary for full understanding thereof by CVM, the Stock Exchanges and the general market related to the Material Information regarding this disclosure.
• Documents containing Material Information shall be disclosed to the public (i) on the webpage of the news portal "Portal NEO1" (http://www.portalneo1.net), as per the option given by CVM Ruling 358 and (ii) on the Company's webpage
  (http://www.gpari.com.br).
• Whenever a Material Information is spread by any means of communication, including information to the press, or at meetings held by trade associations, investors, and analysts or with selected audience, either in the country or abroad, the Material Information shall be disclosed simultaneously to CVM, the Stock Exchanges and the market in general on the webpages indicated in the previous item.
• Any Bound Persons who become aware of acts or facts that may be deemed to be Material Information shall proceed to the immediate communication thereof to the Investor Relations Officer.
• Once any Bound Persons who become aware of a Material Information find that an omission has occurred upon disclosure thereof, which should otherwise had been disclosed under the terms of the laws and the prevailing regulation, they shall communicate said Material Information to the Investor Relations Officer immediately, so that the latter be able to immediately disclose it, or communicate said Material Information to the CVM, if the omission persists.
• Whenever unusual oscillations in the price or quantity of traded securities issued by the Company or related thereto are verified, or in which Material Information has failed to be provided to the Company, the Investor Relations Officer shall inquire the persons with access to Material Information in order to provide to the market an official statement by the Company.
• The Material Information shall be disclosed preferably before the opening or following the closing of the trading hours at Stock Exchanges. If the latter are not functioning simultaneously, the disclosure shall be made in compliance with the trading hours of Stock Exchanges established in Brazil.