Operating Rules and Parameters June 2021

Elaborated by: Compliance Approved by: Executive Management Classification of information: Public

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INTRODUCTION

Genial Institucional Corretora de Câmbio, Títulos e Valores Mobiliários S.A. (hereinafter referred to as “Genial Institucional” or ”Genial”), according with the provisions of the country’s capital market regulators, the Comissão de Valores Mobiliários – Brazilian Securities and Exchange Commission (hereinafter referred to as “CVM”) and B3 S.A. – BRASIL, BOLSA, BALCÃO – Brazilian Stock, Commodity and OTC Exchange (hereinafter “B3”), sets forth hereby its operating rules and parameters related to the registration and execution of trade orders, settlement of trades and custody of securities related to the activities in the B3 markets (hereinafter referred to as “RPA”).

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Index INTRODUCTION ...... 2 1. REGISTRATION AND IDENTIFICATION OF CLIENTS ...... 5 1.1. Registration ...... 5 2. ORDERS ...... 6 2.1. Types of orders accepted ...... 6 2.2. Forms of issuing orders ...... 7 2.3. Authorized persons to issue or transmit orders ...... 7 2.4. Trading via electronic systems ...... 8 3. HOURS FOR RECEPTION OF ORDERS ...... 8 4. RISK MANAGEMENT ...... 8 5. REGISTRATION AND REFUSAL OF ORDERS ...... 10 5.1. ORDER REGISTRATION ...... 10 6. VALIDITY OF ORDERS ...... 13 7. CANCELLATION OF ORDERS ...... 13 7.1. Order cancellation after the confirmed deal ...... 14 8. ORDER EXECUTION...... 14 8.1. Execution ...... 14 8.2. Order execution for default ...... 14 8.3. Order execution by court order ...... 14 8.4. Operational costs ...... 15 9. CONFIRMATION OF ORDER EXECUTION ...... 15 10. RELATED PERSONS ...... 15 11. DISTRIBUTION OF TRADES ...... 15 11.1. Specification of trades at B3 ...... 16 12. SETTLEMENT OF TRADES ...... 16 13. INVESTMENT MONITORING ...... 17 14. CUSTODY OF SECURITIES AND FINANCIAL ASSETS ...... 17 15. STOCK LOAN ...... 18 16. RECORDING SYSTEM ...... 18 17. TRANSACTIONS WITH SECURITIES VIA INTERNET, THROUGH HOME BROKER AND DMA ...... 18

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17.1. Home Broker ...... 18 17.2. “Direct Market Access” or “DMA” ...... 19 18. PREVENTION OF MONEY LAUNDERING AND THE FINANCING OF TERRORISM ...... 20 19. INFORMATION SECURITY AND BUSINESS CONTINUITY ...... 20 20. GENERAL PROVISIONS ...... 21

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1. REGISTRATION AND IDENTIFICATION OF CLIENTS

The procedures for identifying, registering and maintaining Clients will be governed by current regulations and legislation, in particular ICVM 617/2019, which provides for the prevention of money laundering and terrorism financing, and CVM Resolution 35/2021, which establishes rules and procedures to be observed in transactions carried out with securities in regulated securities markets.

Before starting its trading in the organized securities markets with Genial, the Client must provide all the information requested, by filling out the registration form and providing copies of the supporting documents, if requested.

The Brokerage Agreement regulates the main rights and obligations between Genial, the Client and B3. The Agreement is attached to this RPA and is updated in accordance with B3's regulations and circular letters and is applicable to any transaction brokered by Genial in relation to B3 or any other over-the-counter markets.

In accordance with the requirements of CVM Instruction 617/2019, the registration update must occur between a minimum period of 24 (twenty-four) months and a maximum period of 60 (sixty) months, according to the client's risk analysis.

If the Client does not update its registration within the periods established by Genial, the account may be blocked for new operations until the registration is properly updated.

In the process of identifying and registering clients, among other mandatory data, Genial requests the following information:

I. Type of client;

II. Profession and/or field of activity of the client;

III. Investment profile (Suitability);

IV. Identification of Politically Exposed Person (“PPE”);

V. Identification of Related Person, pursuant to current regulations;

VI Identification of final beneficiary(ies);

VII. Identification of "US Person", for the purposes of FATCA (Foreign Account Tax Compliance Act) and pursuant to Normative Instruction RFB 1571/2015.

Genial may present the information provided by the Clients, as well as their respective documents, for possible presentation to B3, regulatory body, self-regulatory body or even to the Judiciary, if requested.

1.1. Registration

Individuals and legal entities may open an account at Genial by completing the registration form and sending other applicable documents, such the suitability questionnaire. All documents must be sent physically, unless instructed otherwise by Genial. Such documents must be sent to Genial, which in turn will evaluate them for account opening purposes.

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In the case of registration of a Non-Resident Investor, Genial will meet the requirements set out in the rules issued by CVM.

Genial may contract, through a specific contract, another member brokerage firm to operate on behalf and to order in the markets managed by B3.

2. ORDERS

2.1. Types of orders accepted

Pursuant to CVM Resolution 35/2021, "Order" will mean the act whereby the client determines that a brokerage firm will trade or register a transaction through the trading or registration systems of B3, SELIC and /or Tesouro Direto, on the Client’s behalf and under the conditions specified by the Client, observing the form of transmission indicated in the registration form.

Genial will accept the types of orders described below, for operations in the cash, forward, options, futures, swap, and fixed income markets, provided that the Client meets the other conditions established in this document:

(i) Market Order – an order in which the client specifies only the quantity, characteristics of assets or rights to buy or sell, and must be executed at the time it is received.

(ii) Managed Order – an order in which the client specifies only the quantity and characteristics of the assets or rights to buy or sell, and Genial, at its discretion, is responsible for determining the time and the systems in which the orders will be executed.

(iii) Competing Managed Order – an order that is issued concurrently with one or more Managed or Discretionary Orders for the same asset, in the same condition, competing in the execution. In trades carried out through Competing Managed Orders, only after the execution of the Orders, trades are allocated to the respective clients, according to the average execution price.

(iv) Discretionary Order – an order that is given by a portfolio manager or by whoever represents more than one client, in which the client representative establishes the conditions under which the order should be executed. After its execution, the client representative will indicate the name(s) of the final client(s) to be specified, quantity of assets or rights to be assigned to each one of them and the respective price.

(v) Limited Order – an order that must be executed only at a price equal to or better than that specified by the client. All orders executed via Home Broker are considered Limit Orders.

(vi) Financing Order – an order composed by a purchase or sale order of assets or rights in a certain market and simultaneously another sale or purchase order of the same assets or rights in the same or in another market.

(vii) Stop Order – an order in which the client specifies the price from which the order should be executed. The Stop limit order becomes a limited order as soon as the trigger price is reached.

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(viii) Matched Order – an order whose execution is linked to the execution of another order of the client, with or without a price limit.

(ix) Monitored Order – an order in which the client, in real time, decides and determines to Genial the conditions for execution of the trade.

If the Client does not specify the type of order related to the operation he intends to execute, Genial may decide the one that best meets the instructions received by the Client, at its own discretion.

Orders with characteristics of more than one of the types described in the items above will be accepted, since they are compatible and at Genial's sole discretion.

Orders received from other Institutions or fund managers will always be considered discretionary or monitored, unless another type is specified among those previously described and accepted by Genial.

The order in which the Client does not specify the type will always be considered a managed order, including discretionary order, unless expressly provided otherwise in this order.

2.2. Forms of issuing orders

Genial will accept orders transmitted verbally and/or in writing, according to the option included in the Client's registration. Genial will accept the orders transmitted according to the conditions established below:

(i) Verbal orders – orders received by telephone or other voice transmission systems duly approved by B3 and Genial; and

(ii) Written orders – orders received electronically ("chat") via Bloomberg, Home Broker, DMA (Direct Market Access), Collocation, Reuters Messenger, Skype, Agência Estado, Trading Platforms and other similar applications duly approved by Genial. All messages via Chat are stored for the minimum period required by current legislation and can be retrieved to resolve any questions that may arise.

Verbal orders via telephone will only be accepted if carried out directly on the operator's institutional telephone. The use of cell phones or any other electronic equipment on the trading desks is strictly prohibited, so that only equipment and means approved by Genial are allowed. Orders must be transmitted by Clients through the means described above and any order transmission carried out by means other than the above procedures will not be accepted.

In case of interruption of the electronic communication systems with Genial, orders may be issued/transmitted by the Client directly to Genial's trading desk(s), through telephones (11) 2137-8888 / (21) 2169-9999. In addition, if necessary, the Client's advisor can also be contacted.

2.3. Authorized persons to issue or transmit orders

Genial will only accept orders issued/transmitted by the Client, by the order issuers registered by the Client or by their representatives or attorneys, provided they are duly authorized and identified in the registration documentation.

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In the case of an attorney, the Client is responsible to present the respective power of attorney to Genial, to be filed with the Client's registration documentation, as well as the Client should inform Genial about the revocation of the mandate in the event of a power of attorney without an expiration date.

2.4. Trading via electronic systems

In electronic platform transactions (Home Broker or DMA), the login, password and other procedures and/or data for accessing the platform are personal and non-transferable, and the Client is fully responsible for any use or order improperly made on its behalf in this form access, including in cases of losses, so that Genial is exempt from any demands or claims.

Genial may block the Client's password in case of suspicion of irregular or atypical use, or at its sole discretion, in which case it shall inform the Client immediately.

Trading via the electronic trading system is an option of the Client, who expressly agrees that Genial will not be liable for any damages suffered due to interruptions in the communication systems arising from failures and/or interventions by any communication service provider, technology or otherwise, and failures in availability and access to the operations system or its network.

Clients, within the specific regulation and authorization of B3, who are registered under a master/manager account, may have orders issued by persons authorized to issue orders in the master/manager account.

In the operation via DMA or Home Broker, Genial may, at its own discretion or that of B3, refuse orders and even suspend the Client's access, immediately and without prior notice, if atypical or technical/operational elements are verified that put the trading environment of B3 or Genial at risk.

In the case of operations via DMA or Home Broker, orders will only be considered accepted after the moment of their effective reception by B3 and return of their acceptance by the information system.

Due to the risks inherent to the means of communication used in B3, DMA's Electronic Trading Systems and in the Home Broker, Genial Institucional cannot be held responsible for transmission problems, interferences or interventions caused by third parties or specific to the means used.

3. HOURS FOR RECEPTION OF ORDERS

Orders will be received during the regular operating hours of the respective markets managed by B3.

Orders received outside the market hours will be rejected.

4. RISK MANAGEMENT

Genial Institucional establishes operational limits and intraday risk controls to its Clients to limit their risk and may refuse, totally or partially, to execute the Orders received or requested by the Client upon immediate communication to the Client. In addition, Genial may determine the reduction of the Client's exposure if the Client does not meet the additional guarantees.

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In the event of the Client's default in complying with any of the obligations established within the deadlines indicated by Genial and/or B3, or determined by the applicable regulations, Genial will be expressly authorized, regardless of prior notice or any other legal action, to settle contracts, rights and assets acquired on its behalf in the B3 stock exchange or clearinghouse, as well as to settle assets and rights given as guarantee of its operations, applying the results of the sale in the payment of outstanding debts, regardless of judicial or extrajudicial notification.

The Client is aware that the non-payment of its contractual or legal obligations may also result in a fine and the inclusion of its name and other registration data in the list of defaulting clients of B3, as well as its inclusion in the non-defaulting registers of public or private companies, bodies and/or entities, that maintain or provide credit protection services (SPC and SERASA, among others) and collection/foreclosure lawsuits.

In operations carried out on the forward, options and futures markets, B3 and/or Genial may additionally, at any time and at their sole discretion, demand extra and/or additional guarantees they deem necessary, subject to any amount and/or term, including for positions already registered, albeit at more restricted levels than those stipulated in the respective current regulatory standards, in order to ensure the full and timely fulfillment of the obligations applicable to the Client due to the operations with options and forwards carried out by Genial.

Genial may, whenever it deems convenient, require the Client to replace the bonds or securities given as guarantee by others, at Genial own discretion.

Genial, at its sole discretion, may condition the acceptance of orders to the fulfillment of the following requirements:

BOVESPA Segment – Variable Income

• Previous deposit of securities to be sold;

• In the case of purchases or transactions that may generate obligations, prior deposit of the amount corresponding to the cost of the transaction;

• Securities to be sold are under custody of Genial;

• In the event of issuance of uncovered options, the prior deposit of securities or guarantees; and

• Additional collateral deposits, at any time, in transactions carried out in future markets.

Even if the aforementioned requirements are met, Genial may refuse to receive any order, at its sole discretion, and whenever it verifies the practice of unlawful acts or the existence of irregularities, notably aimed at creating artificial conditions of price, offer or market demand, price manipulation, fraudulent operations or the use of unfair practices and/or the Client's financial incapacity, as well as the existence of pending registration.

BM&F Segment – Derivatives

• Prior deposit of assets accepted as collateral by B3 in case of opening a position in the derivatives market;

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• In the case of uncovered options, prior deposit may be required (a) of the securities or guarantees, if they are also accepted by B3; or (b) of cash in an amount deemed necessary; and

• Additional deposits of guarantees to the operational limit established for the Client, at any time, in operations carried out in future markets.

In the operation via DMA or Home Broker, Genial may, on its own discretion or that of B3, immediately and without notice, refuse orders and even Client access, if verified, in addition to the conditions set out throughout this item, technical and operational elements that put Genial or B3 at risk.

OTC Segment

• Prior deposit of securities to be sold or, in the case of purchase or transactions that may generate obligations, prior deposit of the amount corresponding to the total or partial cost of the transaction;

• Securities to be sold are under custody of Genial;

• Additional deposits of guarantees to the operational limit established for the Client, at any time, in operations carried out in future markets.

5. REGISTRATION AND REFUSAL OF ORDERS

Genial will register the orders received through a computerized system, which will assign to each order an automatic sequential control number, date of issue and time of receipt. The order will be registered in the market and trading system determined by the Client. In case of omission by the Client, Genial will choose the market and the trading system that presents the best conditions of operational capacity. In case of order competition, the priority for execution must be determined by the chronological criterion.

5.1. ORDER REGISTRATION

When the order is received and accepted by Genial, Genial registers and attributes to each order the corresponding date and time, as well as the registration of the orders includes the following information:

BOVESPA and BM&F Segments

i. Identification code of the client at Genial;

ii. Date, time, and sequential number indicating the chronological sequence of orders;

iii. Details of the order: characteristics and quantities of the securities to be traded;

iv. Nature of the transaction: purchase or sale and type of market - spot, forward, options, futures, pass- through or transactions by Settlement Participants;

v. Price limit and validity, if applicable;

vi. Order type;

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vii. Identification of the issuer/transmitter of the order in the following cases: corporate clients, clients whose portfolio is managed by third parties, or even in the case of the client's representative or attorney-in-fact authorized to issue/transmit orders on their behalf; viii. Indication of the operation of related persons;

ix. Operator identification;

x. Identification of the trade transaction number at B3;

xi. Indication of the status of order received (executed, not executed, or canceled).

For operations carried out through a master account, the indication of the Client's final account must occur within a maximum period of 1 (one) hour after registration. If the account is not informed within the defined period, the Client's allocation will not be allocated to a master account.

The securities held by the Client will be registered in an individualized and segregated position. Financial transactions arising from operations that have securities as their object, or from events relating to these securities, will be credited or debited to the Client's current account, indicated in its registration form.

Genial, at its sole discretion, may:

(i) Execute the order transmitted by the Client through another institution with which Genial has a pass- through agreement;

(ii) Acceptance of orders is subject to the following requirements:

a) prior deposit of securities to be sold or, in the case of purchase or transactions that may generate obligations, prior deposit of the amount corresponding to the transaction;

b) in the case of options, prior deposit of the securities or guarantees, if they are also accepted as collateral by B3, or cash deposit in an amount deemed necessary; and

c) additional collateral deposits, at any time, in transactions carried out in future markets.

(iii) Establish operational limits and/or mechanisms that aim to limit risks to its Client, as a result of price variation and exceptional market conditions, and may refuse to receive orders and/or execute them, upon immediate communication to the Client;

(iv) Even if the above requirements are met, Genial may refuse to receive any order, in whole or in part, by means of immediate communication to the Client, not being obliged to disclose the reasons for refusal, whenever:

a) verify the practice of unlawful acts or the existence of irregularities, notably aimed at creating artificial conditions of price, offer or demand;

b) identify offers or demands in the market with the purpose of price manipulation;

c) identify fraudulent operations;

d) identify the use of inequitable practices and/or financial incapacity; and

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e) identify clients who are, for any reason, prohibited from operating in the securities market or who are subject to restrictions dictated by Genial's internal policies.

When the order is issued/transmitted in written format, Genial will formalize the eventual refusal also in written format.

The Client, in case of non-compliance with any of its contractual or regulatory obligations, is subject to the payment of fines and is responsible for the burden and expenses caused by its default, or that are necessary to comply with the obligations that compete with the Client.

OTC Segment

i. Identification code of the client at Genial;

ii. Details of the order: characteristics and quantities of the securities to be traded;

iii. Nature of the transaction: purchase or sale, type of market, and price;

iv. Identification of the issuer/transmitter of the order;

v. Order type (if applicable);

vi. Indication of the operation of related persons;

Genial must not, under any circumstances, register the transaction in the B3 system on a date different from the trading date, except in cases of scheduling.

Registration of the transaction in the appropriate system on the same date of the trade is mandatory.

Genial, at its sole discretion, may:

(i) Execute the order transmitted by the Client through another institution with which Genial has a pass- through agreement;

(ii) Acceptance of orders is subject to the following requirements:

a) prior deposit of securities to be sold or, in the case of purchase or transactions that may generate obligations, prior deposit of the amount corresponding to the transaction;

b) additional collateral deposits, at any time, in transactions carried out in future settlement markets.

Even if the above requirements are met, Genial may refuse to receive any order, in whole or in part, by means of immediate communication to the Client, not being obliged to disclose the reasons for refusal, whenever:

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a) verify the practice of unlawful acts or the existence of irregularities, notably aimed at creating artificial conditions of price, offer or demand;

b) identify offers or demands in the market with the purpose of price manipulation;

c) identify fraudulent operations;

d) identify the use of inequitable practices and/or financial incapacity; and

e) identify clients who are, for any reason, prohibited from operating in the securities market or who are subject to restrictions dictated by Genial's internal policies.

When the order is issued/transmitted in written format, Genial will formalize the eventual refusal also in written format.

6. VALIDITY OF ORDERS

The orders will be valid according to the period determined by the Client at their issuance/transmission, and the Client is solely responsible for requesting their cancellation before the deadline date and ensuring that there is no duplication.

7. CANCELLATION OF ORDERS

Any order may be canceled while not executed, and must be communicated to the Client, in any of the following situations:

(i) By initiative of the Client;

(ii) By initiative of Genial:

a) when the transaction or circumstance and the available information indicate risk of default by the Client;

b) when it is not compliant with the operational standards of the securities market;

c) when the Client decides to change any of its conditions or if the written order contains an erasure or the order is not sufficiently clear, a new order will be issued, if applicable;

d) by initiative of B3; and

e) when it does not comply with the legal or regulatory rules of the markets managed by B3.

The order not executed within the period preestablished by the Client will be automatically canceled by Genial. The canceled order will be kept in an automatic sequential numbered file, along with the other orders issued.

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7.1. Order cancellation after the confirmed deal

If the market regulatory agencies identify non-compliant situations that imply the cancellation of the operations already carried out, the trades may be cancelled. Therefore, prior confirmations do not represent an irreversible and irrevocable nature.

Pursuant to special auction procedures established by CVM, B3 may also cancel trades previously carried out and send them to auction. Orders will be considered effectively executed when not identified any violation of the rules and deadlines for carrying out the special procedures.

8. ORDER EXECUTION

Order execution is the act by which Genial carries out the order issued/transmitted by the Client through the execution or the registration of the transaction in the markets in which it operates.

8.1. Execution

For execution, orders for operations in the B3 trading systems may be grouped by type of market and security or specific characteristics of the contract.

Orders related to the securities markets managed by B3 in the OTC segment may be grouped by type of asset, settlement date and price.

In case of interruption of Genial's or B3's trading system, Genial will allocate the best efforts to promote the execution of the order, if possible.

Orders issued in person will be sent to the registered Client's e-mail address prior to execution. If the Client attends Genial in person, he will be directed to a meeting room so that he can transmit his orders through the telephone system, with the proper record of the conversation, or electronic system registration.

8.2. Order execution for default

Genial will carry out transactions of purchase and/or sale of securities and rights of Clients who fail to honor their transactions.

Transactions carried out due to default will be subject to brokerage fees, which must be paid by the Client.

8.3. Order execution by court order

Genial will carry out transactions of purchase and/or sale of securities and rights that have been determined by court order or court authorization. After its settlement, Genial will confirm those transactions to the ordering court and to B3.

Transactions carried out due to court order or judicial authorization will be subject to brokerage fees, which must be paid by the Client.

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8.4. Operational costs

Genial and the Client will define, by mutual agreement, the amounts to be paid as remuneration for the intermediation of operations covered by the Agreement, and the Client is obliged to make the payments due on the dates agreed between the Parties.

Fees charged by B3 will be due and supported by the Client. Genial will collect them and transfer the amounts to B3.

Any taxes owed by the Client because of its operations will be withheld or collected by Genial and transferred within the regulatory period to the competent regulatory agency.

Genial may define minimum limits for the value of orders and the value of commissions for the Client to operate through the trading desk, in which Genial will provide other means for the Client to carry out operations at amounts below the limits to be established.

9. CONFIRMATION OF ORDER EXECUTION

Genial will confirm the execution of the orders and the conditions under which they were executed in a timely manner to allow the appropriate control of the Client, through the use of electronic trading platforms or through an email containing the brokerage note on the following day to order confirmation.

Transactions carried out through Home Broker have their confirmation displayed in the Home Broker system simultaneously with their execution.

10. RELATED PERSONS

Related persons are defined under the definitions of CVM Resolution 35/2021, and the following principles must be observed by Genial and the Client:

• Guide its activities by ethical conduct, safeguarding its own reputation and the reputation of Genial;

• Avoid conflict or appearance of conflict of interest between your personal investments and Genial's business;

• Persons related to Genial may only trade securities in accordance with the provisions of Genial's Internal Personal Investment Policy;

• Genial can operate in a proprietary portfolio in the markets traded by B3 and in the over the counter markets and may assume speculative positions and/or for purposes of currency hedge and asset hedge operations, pursuant to applicable legislation and regulations.

11. DISTRIBUTION OF TRADES

Genial will distribute the trades carried out at B3 by type of market, security/contract and by standard/fractional lot, according to the following criteria:

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(a) only orders that can be executed at the time of execution of a trade will qualify for its distribution;

(b) orders from persons not related to Genial will have priority in relation to orders from related persons;

(c) Managed, Financing, Monitored and Matched orders do not compete nor with the other orders, as the trades were carried out exclusively to meet them.

Observing the criteria mentioned above, the chronological order receipt numbering will determine the priority for fulfilling the distribution of the order issued by the Client of the same category, except for the monitored order, in which the Client interferes in real time.

11.1. Specification of trades at B3

The specification of trades executed by Genial in the markets managed by B3, in compliance with Client orders, will be carried out in accordance with the rules established by B3.

In operation via DMA, Co-location and Home Broker, the trade specification occurs directly when placing the order. In case the specification is originally under a master/manager account, it is possible later to make the specification of trades for Clients registered under the master/manager account.

The specification hours of trades may be modified as determined by B3.

12. SETTLEMENT OF TRADES

Genial will maintain, in the Client's name, a checking account intended to record its operations and debits and credits carried out in its name.

The Client undertakes to pay Genial with its own resources, the debts arising from the execution of orders for trades carried out on its own behalf, as well as the expenses related to the trades.

The financial resources sent by the Client via the banking system will only be considered available after the respective confirmation by Genial.

Transfers made by Genial to the non-resident investor Client can be made to the custodian's current account or the portfolio manager designated by the non-resident investor.

If there are outstanding debts on behalf of the Client, Genial is authorized to settle the contracts, rights and assets, acquired on its behalf, as well as to execute assets and rights given as guarantee of its transactions, to the payment of outstanding debts, regardless of judicial or extrajudicial notification. If settlement debts persist, Genial may take the legal measures it deems necessary.

The amounts resulting from the application of fines by B3 for non-compliance with the Client's obligations provided for in B3's Regulations and Rules (available at http://www.b3.com.br/pt_br/) will be debited from the Client's checking account maintained at Genial, being the Client's responsibility to settle the amount of the fine.

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13. INVESTMENT MONITORING

The procedures for identifying the investor profile are governed by CVM Resolution 30/2021.

Genial, in line with the best national and international practices, adopts policies and procedures to ensure an adequate offer of products and services in accordance with the needs, interests and objectives of our Clients. Therefore, it is necessary to evaluate the investor to know his tolerance to risks, his availability of resources and investment time horizon, in order to qualify him for the appropriate investment and protect him from possible inadequate decisions.

The classification of Clients applied by Genial is documented internally in the Suitability Policy, which is widely disseminated to the areas involved in the process.

The deadline for updating the Suitability investor profile follows the same deadline for updating the Client's registration data, which may be brought forward, in accordance with current regulations. If the proper update is not carried out, the account will be blocked until regularization regarding the update of the profile.

14. CUSTODY OF SECURITIES AND FINANCIAL ASSETS

The services that are the object of the Agreement include the safekeeping of assets, updating, receipt of dividends, bonuses, interest, income, exercise of rights in general and other activities related to the Asset Custody Services.

The inflow of funds arising from rights related to securities deposited in custody or in guarantees at B3 will be credited to the Client's checking account at Genial, and the assets received will be deposited in their custody account at B3.

The exercise of subscription rights for assets will only be carried out by Genial upon authorization of the Client and prior deposit of the corresponding cash. Failure to respond in a timely manner and/or inexistence of sufficient balance or non-transfer of funds releases Genial from exercising the right to subscribe for assets.

The Client will receive the monthly statements or emails to the address indicated to Genial, sent by B3, containing, respectively, the list of assets and the amount of deposited gold and other transactions that took place on its behalf, observing that the option for physical receipt of the statement will incur costs to the Client. Additionally, B3 provides on its website the Client's consultation of his statement, upon prior registration.

The custody account, opened by Genial, at B3, will be handled exclusively by Genial.

Genial will provide to its Clients information regarding the custody position and transactions involving assets and maintain control of Clients' positions, with periodic reconciliation between:

a) Orders executed;

b) Positions contained in the database that generate the extracts and statements provided to its Clients; and

c) Positions provided by clearing and settlement entities, if applicable.

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15. STOCK LOAN

Genial agrees in advance with the Client the remuneration rates related to the stock loan transactions and sends the Client the confirmation of the transaction negotiation and the transaction settlement note, detailing the total amount received or paid by the transaction counterparty, the amount charged by Genial and the final amount paid or received by the Client.

16. RECORDING SYSTEM

Telephone conversations held between the Client and the Genial professionals from the Trading Desk and related to transactions intended or carried out by the Clients are recorded.

The content of the recordings may be used as evidence in clarifying issues related to the account and transactions of a particular Client and may be requested by Clients for a period of 30 (thirty) days from the date on which the conversation took place.

Genial will keep, for a minimum period of 5 (five) years, in a safe, complete, and intelligible way, the recordings from the date of issue of the order, all written orders and the registration documentation of the Clients.

Communications via e-mail or instant message are also recorded and their content is kept safe, complete, and intelligible by Genial for a minimum period of 5 (five) years from the date of the communication.

The recording system will contain:

a) date and time of the start and end of each recording of Client calls;

b) the elements that allow the identification of the representative of Genial, trading desk operators and the Client who issued the order;

c) the characteristics and conditions of execution of the order, which must be confirmed by the Client; and

d) controls that ensure the totality of recordings made by each Client, from the beginning to the end of their negotiations.

Genial will keep all recordings made available to B3 and the competent authorities.

17. TRANSACTIONS WITH SECURITIES VIA INTERNET, THROUGH HOME BROKER AND DMA

17.1. Home Broker

Genial offers to their authorized Clients the possibility of transmitting orders through the Home Broker system in the segments authorized for this purpose by B3.

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This system consists of automated service, enabling Clients to place, for immediate execution, purchase and sale orders for securities in the spot market and options and futures, agricultural and financial derivatives segments. Orders sent directly via the Home Broker System will always be considered as written orders.

17.2. “Direct Market Access” or “DMA”

Genial may provide, at its sole discretion, to certain Clients, access to the markets managed by B3 via the Electronic Order Routing System, directly in the electronic trading environment ("Direct Market Access" or "DMA"), provided that they are met by the Clients the requirements and configurations established by B3.

The DMA consists in the provision of an automated transaction intermediation service, where Clients may place orders to buy or sell securities for immediate execution, in the spot, forward and options markets without the need to interact with a Genial operator.

If the order cannot be transmitted via DMA, the Client will have the option of transmitting it directly to Genial's trading desk.

Electronic access systems to the DMA model are, like any automated tool, vulnerable to fraud and hacker activity. Due to the inherent risks of this type of operation, Genial cannot be held responsible for transmission problems, interference, failures, inoperability, or interventions.

In the DMA trading model, trading activities are subject to inspection and monitoring by B3 and by the regulatory and self-regulatory bodies, as well as the Client expressly adheres to the rules and procedures established by them.

Orders sent through the DMA will be accepted and executed only after their effective reception by B3's trading systems and confirmation of receipt has been returned.

The cancellation of transactions transmitted through the DMA will be considered accepted only after their effective reception by B3's trading systems and provided that the corresponding transaction has not been carried out.

The confirmation of the execution of orders received via DMA will be made by Genial through a report issued by the Electronic Order Routing System.

Orders transmitted via DMA will be considered effectively fulfilled when not identified any violation of the securities market rules and after the deadlines for carrying out the special trading procedures provided for in the rules issued by B3 or CVM have expired.

Genial will be responsible for granting the DMA system to be used by the Clients, which will be responsible for the necessary structure for its correct implementation in the place to be agreed between the Client and Genial.

Genial Institucional does not offer order automation algorithms on trading platforms to their Clients.

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18. PREVENTION OF MONEY LAUNDERING AND THE FINANCING OF TERRORISM

Genial has internal controls to prevent and combat money laundering and the financing of terrorism, on its operations and those of its Clients, appropriate to the type of business, which contain the prevention, detection, verification and communication activities segregated in the processes below:

(i) Know your Customer;

(ii) Registration and monitoring of Customer operations, regardless of the amounts involved;

(iii) Retention of Customer registration data, as well as records of operations carried out within the regulatory period;

(iv) Communication of unusual operations to the Financial Activities Control Board – COAF;

(v) Evaluation of products, services and distribution, trading and registration channels;

(vi) Evaluation of business partners and suppliers;

(vii) Ongoing training program on the prevention and combat of money laundering and the financing of terrorism for its employees;

(viii) Risk-based approach, pursuant to ICVM 617/2019.

19. INFORMATION SECURITY AND BUSINESS CONTINUITY

Genial has an Information Security Policy that includes:

(i) logical and physical access controls;

(ii) formal mechanisms for managing access and passwords, logical and physical segregation of conflicting activities;

(iii) external access control and technology security solutions;

(iv) recording and monitoring of all interruptions and/or failures in systems, networks or telecommunication and integrity verification routines;

(v) change management;

(vi) proper backup procedures; and

(vii) managing employees' access to the Internet.

Genial also declares that all critical systems have audit trails to identify date, time, user and types of access.

Additionally, Genial has a Business Contingency Plan suited to the business core and regularly carries out verification and adequacy tests to ensure maximum efficiency and effectiveness of business continuity. Genial's offices have their own power generator that is available for any power outages, being tested weekly.

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20. GENERAL PROVISIONS

Genial controls the risk of its Clients using the operational limit criteria, individually or collectively (master account or economic group), whichever is applicable.

Genial may operate in its own portfolio on markets traded on exchanges and over-the-counter markets, and may assume speculative positions, for hedge purposes or to act as a counterparty in situations of operational error. Its resources are primarily invested in government bonds, investment funds and/or private liquidity bonds, and may also be invested in any other financial assets, in compliance with current legislation.

It is noteworthy that Genial has an “error account”, specifically intended for the entry of operations originated by operational error.

Genial adopts internal rules, procedures and controls, including the use of service providers whose scope is to verify and confirm the Customer's information, aiming at confirming the registration information, maintaining the registrations updated and identifying the final beneficiaries of the operations, according to the legislation applicable to the product and to the market in which it operates, in order to prevent the misuse of the B3 system by third parties, or even, for money laundering, financing of terrorism and/or fraud, being the Client obliged to send, whenever requested, information and documents.

In accordance with current regulations, Genial acts as an administrator of third-party resources, having for this purpose both physical and logic segregation (Chinese Wall) between the possibly conflicting activities. Pursuant to CVM Resolution 35/2011, Genial is prohibited from accepting or executing orders from Clients who are not previously registered, or whose registration is outdated under the terms of this RPA and relevant regulations.

Due to the risks inherent to the means of communication used in Electronic Trading Systems, Home Broker and DMA, Genial cannot be held responsible for transmission problems, interferences or interventions caused by third parties or specific to the means used.

In case of changes in the Genial RPA, all active Clients will be notified through registered emails, as well as the new version of the document will be published on Genial's website.

General Data Protection Law

The Client authorizes Genial to share registration (including suitability) and financial information, as well as active and passive operations, in addition to services provided, with Genial, subsidiaries, controlling companies and under common control with the Broker, and also with other companies, partners and service providers, such as credit protection agencies, data bureaus and anti-fraud companies.

Genial Institucional CCTVM S.A.

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