Telefônica Brasil S A : Material Fact - CGU Deicision

TELEFÔNICA BRASIL S.A.

Publicly-held Company

CNPJ 02.558.157/0001-62 - NIRE 35.3.0015881-4

M A T E R I A L F A C T

Telefônica Brasil S.A. ("Company" or "Telefônica Brasil"), in compliance with and for the purposes of CVM Instruction No. 358/2002 ("ICVM 358"), as amended, hereby informs its shareholders and the market in general that, on this date, it was administratively sanctioned by the General Comptroller's Office ("CGU"), for the delivery of tickets for the games of the 2014 Men's Soccer World Cup to public agents, one of which took place in the context of marketing actions and institutional promotion of the Company held in 2014, but considered by CGU as incompatible with the terms of article 5, item I, of Law 12.846/2013, due to objective legal responsibility.

Considering the elements analyzed by CGU in the administrative process, including, among others, the absence of damage to the public administration, the non-identification of advantages obtained or intended by the Company due to the tickets offered, its degree of cooperation and high degree of maturity of its compliance program, the sanction stablished by CGU stood at the minimum legal level provided for in article 6, item I, of Law 12.846/2013, that is, in an amount equivalent to 0.1% (one tenth percent) of the Company's gross revenue in the year prior to the initiation of the administrative proceeding, which totals R$ 45,747,320.63.

The Company develops and implements initiatives to ensure the continuous improvement of its compliance program, through an organizational and governance structure that guarantees a performance based on ethics, transparency and respect for applicable laws and standards.

São Paulo, October 16, 2020.

David Melcon Sanchez-Friera

CFO and Investor Relations Officer

Telefônica Brasil - Investor Relations

Tel: [phone]

Email: [e-mail]

Information available at: www.telefonica.com.br/ir