CONTENTS

SELF-REGULATION OF MISSION AND MANDATES ORGANIZATIONAL 04 B3’S MARKETS 06 06 CHART

MARKET GUIDANCE, TRAINING INVESTOR AND INTERNATIONAL FORUMS WHISTLEBLOWER CHANNEL COMPENSATION 07 11 12 MECHANISM (MRP)

SURVEILLANCE BY AUDIT MARKET SURVEILLANCE 15 19 23 INDICATORS

ADMINISTRATIVE ENFORCEMENT 25 29 ACTIVITIES FIGURES, GRAPHS AND TABLES

FIGURE 1 – BSM GRAPH 1 – TRAINING AND GRAPH 2 – COMPLAINTS 06 ORGANIZATIONAL CHART 09 GUIDANCE 11 RECEIVED IN 2018

TABLE 1 – COMPLAINTS GRAPH 3 – NUMBER OF RECEIVED, CONCLUDED AND COMPLAINTS TO THE MRP TABLE 2 – AUDITS HELD 13 IN PROGRESS 14 17 IN 2018

TABLE 4 – IRREGULARITIES TABLE 3 – IRREGULARITIES TABLE 5 – REPORTS IDENTIFIED IN BM&FBOVESPA IDENTIFIED IN CETIP UTVM RECEIVED, CONCLUDED SEGMENT TRANSACTIONS 20 SEGMENT TRANSACTIONS 20 21 AND IN PROGRESS

FIGURE 2 – SCHEMATIC GRAPH 4 – TYPES OF GRAPH 5 – ORIGEN OF THE DIAGRAM OF THE ACCUSED IN PADS PADS INITIATED IN 2018 26 ENFORCEMENT PROCESS 28 INITIATED IN 2018 28

TABLE 6 – SECRETARIAT AND FIGURE 3 – GEOGRAPHICAL ADMINISTRATIVE SUPPORT 30 DISTRIBUTION OF THE AAIS 30 FIGURES 4

SELF-REGULATION OF B3’S MARKETS

B3 S.A. – Brasil, Bolsa, Balcão has a complete infrastructure for the financial and capital market. The main assets are traded, cleared and settled, deposited and registered in its environments, from equities and corporate bonds to currency derivatives, structured transaction and interest and commodity rates. B3’s participants are brokerage houses, securities dealers and banks. 105

This ecosystem has rules that seek for savers (individual, pension for individuals or bodies that supervising the markets operated a fair and equitable environment fund and other investors); of need protection against price by B3, with the aim of maintaining for all agents, so that the market enabling financing sources for fluctuations in a product or their integrity. We believe that can perform its essential role of companies, governments and currency. to promote market integrity is to enabling investment alternatives other institutions; and of hedging BSM is the body responsible for promote the development of Brazil.

BSM is thus built on three pillars:

Knowledge and guidance: Market integrity: Protection for the investor: we provide market guidance, share we monitor all of the transactions in addition to helping maintain knowledge and assist B3’s participants that occur in B3’s markets, audit market integrity in a transparent in adopting the best practices for their participants and when necessary and fair way, our Investor processes and controls. act to prevent repetition of Compensation Mechanism seeks irregularities. to compensate investors harmed by the actions or omission of B3 participants.

In the following pages, we set out the main activities that BSM executed over 2018. 6

OUR OUR • Inspect B3’s participants activities or, when necessary, . bringing disciplinary • Oversee B3’s activities as a administrative processes that MISSION MANDATES market operator and issuer of can result in penalties against listed securities (self-listing). those involved in irregularities. To ensure the integrity of B3’s • Supervise activities (orders, markets and protection of registrations and trades) in B3’s • Take necessary measures to • Manage the Investor investors. markets. preserve the integrity of the Compensation Mechanism market through guidance (MRP).

ORGANIZATIONAL Figure 1 – BSM Organizational Chart CHART

We have budgetary autonomy and a dedicated team. Figure 1 sets out our organizational chart, for the end of 2018. 7

Guidance is a key pillar of our activity. Experience has MARKET shown us that guidance actions positively contribute towards preserving market integrity and investor GUIDANCE, protection. For this reason, we have dedicated ever more time to holding training sessions, workshops TRAINING AND and other forms of educational interactions with the market. INTERNATIONAL Below we have listed some examples of these FORUMS guidance activities. 8

BSM-ANBIMA Joint part this workshop and this is calendar. Taking part in the 2018 participants. These events have Workshop on Abusive expected to be a growing trend at edition were Antônio Carlos been promoted frequently and subsequent events, which are also Ferreira de Souza, president of have proven very productive, as Practices expected to be led by the buy side the Council for Financial Activities they have allowed the specifics of Almost 200 people representing 65 (managers, foundations and other Control (Coaf) and Marcus Vinicius each institution to be dealt with different institutions followed the investors). de Carvalho, who heads Prevention and have granted a level of depth event (in person or via streaming), of Money Laundering and Combat that is not always possible at open which covered manipulative Money Laundering of Terrorism Financing at the meetings. Securities & Exchange Commission practices through layering and Prevention Training spoofing. of Brazil (CVM). Graph 1 shows the number of Followed by around 200 individuals, people trained at the workshops B3 participants and ANBIMA- in person or via streaming, money In addition to workshops aimed for the market and in individual member asset managers took laundering prevention training is at the market, we provide specific training sessions. an established part of our annual training requested individually by 9

In addition to these events, the BSM team provides daily guidance by telephone, email or in Graph 1 – Training and guidance person. This is now common practice and allows better interaction between BSM experts and the 65 market.

In 2018, we initiated a new type of market 2014 guidance: the publication of videos. The first of these videos, launched in December, dealt with same investor trades during auctions. There were also four videos recorded for publication 39 in the first half of 2019, about churning, layering, spoofing and illegal money-passing between 31 accounts. 28

23 23 We also provide speakers for B3 Education 1.600 programs and initiatives such as Programa TOP – which aims to have university lecturers 600 disseminating information about the capital market. 330 3 4 International forums 2015 2016 2017 2018 We take part in the main international forums involving regulators and self-regulators, Number of training sessions Number of guidance sessions Professionals trained with meetings and training sessions from the International Organization of Securities Commissions (Iosco), the Affiliate Members Consultative Committee (AMCC) of Iosco and the Council of Securities Regulators of the Americas (COSRA). 10

Of special note, in 2018 we held a presentation with Iosco’s Committee for Secondary Markets, at the invitation of CVM, regarding our methodology for layering and spoofing identification, which had international repercussions and became a reference for the subject.

Team training and qualification

In addition to events aimed at B3 participants and investors, we have an intensive agenda for our staff. Of note in this regard is International Training that has been held annually since 2011 for BSM and B3 employees, as well as for regulators (CVM and the Central Bank of Brazil), other self-regulators (ANBIMA, Ancord and Febraban) and for the Federal Police, Federal Public Prosecutors’ Officer and the Federal Judiciary.

In the 2018 edition there was discussion, among other things, of trends in investigative and (FINRA – USA), Ricardo Saponara (SAS - Trading Commission (CFTC). In 2018, two enforcement programs, the use of data mining Brazil), Henrique Machado (CVM), Francisco employees took part in this training. and analytics, money-laundering prevention José Bastos Santos (CVM) and Marcus programs, suitability, the calculation of penalties Vinícius de Carvalho (CVM) participated as Due to the ever more intensive use of the and benefits, and challenges in single self- speakers. disciplines of analytics in supervision and audit regulation. processes, we sent two employees to Statistical We also encourage our employees to participate Analysis System (SAS) headquarters in the Corinne Riguzzi (SIX Exchange Regulation – in specific overseas training, such as that United States to take part in reference training Switzerland), Elsa Renzella (IIROC – Canada), offered annually by the Securities and Exchange in the tool, which is used in our data mining Kevin Piccoli (CFTC – USA), Lara Thyagarajan Commission (SEC) and the Commodity Futures activities. 11

WHISTLEBLOWER CHANNEL

Our whistleblower channel was created to allow complaints to be sent about the activity of market professionals, companies traded at B3 and financial intermediaries.

The whistleblower channel is an important source of information for BSM’s inspection activities.

In 2018, we received 71 complaints regarding the issues set out in Table 2.

Graph 2 – Complaints received in 2018

Control failures 17

Market manipulation 14 Irregular activity of 14 a market professional Custody transfer 7

Fraud 4

Information Failure at Listed Companies 3 Artificial conditions of 3 demand, supply or price

Other 9 12

INVESTOR COMPENSATION MECHANISM (MRP)

CVM Instruction 461/2007 governs organized securities markets in Brazil and requires the entire exchange market to have a mechanism to ensure that investors are compensated for losses resulting from an action or omission on the part of exchange market participants.

BSM manages B3’s Investor Compensation Mechanism.

Table 1 sets out the number of complaints received, concluded and in progress within the scope of the MRP since 2012. 13

Table 1 – Complaints received, concluded and in progress

Phase* 2012 2013 2014 2015 2016 2017 2018 Total

Discovery ------415 415

Trial - - - - - 4 85 89

Notification of accused ------133 133

Appeal timeframe ------24 24

Concluded at BSM 200 144 185 235 620 158 122 1,664

Total 200 144 185 235 620 162 779 2,325

*Status on December 31, 2018.

We witnessed a significant rise in four institutions have gone into payments for partially or fully complaints made to the MRP or to the number of complaints to the receivership. The number of accepted claims, totaling BRL calculate the real value of investors’ MRP in 2018 due to the receivership complaints resulting from these 2,243,729.1 losses. In 2018, the Auditing team of the Gradual Investimentos and receiverships can be seen in Graph 3. drew up 583 technical reports on Walpires brokerage houses. Over The BSM audit team is called upon which to base decisions within the the past seven years, another In 2018, we made 82 compensation to assess the technical aspects of scope of the MRP.

1 This does not include partially accepted claims, whose claimants have submitted an appeal to CVM and with claims still pending the autarchy’s consideration. 14

Graph 3 – Number of complaints to MRP

Gradual (May/2018) TOV Walpires (Jan/2016) (Oct/2018) Estratégia (May/2016)

117

80 Diferencial Corval (Aug/2012) (Sep/2014)

662 540 53 86 42 78 73 182 114 144 54 71 84 - 2011 2012 2013 2014 2015 2016 2017 2018

In receivership Other

MRP DIGITAL

In December 2018, MRP’s digital platform went into production. As a result, all communication between the investor, BSM and B3’s participants went from paper to electronic, providing greater security and agility.

An explanatory video with all the guidance required for making a complaint via the MRP Digital platform is published at our website (access here). 15

AUDIT

BSM is responsible for the supervision and direct inspection of markets operated by B3, which are tasks that it performs through audits to assess compliance of the participants’ processes and controls with the applicable laws and regulations. This inspection process occurs through different types of audit, as set out below. 16

Operational audits In the case of Cetip UTVM (OTC models, has also allowed greater called remote audits or audits by market) segment participants, in analysis efficiency, reducing the indicators) assess participants’ In the operational audits, we addition to some of the processes time of the audit team allocated compliance with the regulations, assess compliance of the described above, we assess the with participants and decreasing through the application of participants’ infrastructure, registration and update of asset requested material. normative rules based on data processes and controls with the information, the intermediation treated via statistical software. rules of access to the markets of assets registered at B3 and the In 2018, we began to perform operated by B3, based on the valid physical safekeeping of hard-copy operational audits with the This type of audit tends to be more normative basis. assets. Agribusiness Depositories efficient as it allows analysis of responsible for the safekeeping the entire universe of information, To this end, our audit team In 2018, the BM&FBOVESPA and and maintenance of commodities, not only samples as normally reaches agreement upon and Cetip UTVM segments’ audits as well as activity in the physical occurs with tests executed in maps out the participants’ were integrated. Until then they delivery process foreseen in operational audits. It also reduces processes and controls, and had been performed by discrete agribusiness futures contracts. the observance cost of audit work assesses their existence, adequacy teams from BSM and from Cetip’s This audit encompasses the in the field. and functioning. Self-Regulation Department. assessment of Agribusiness This integration brought synergy, Depository processes as per In 2018, in line with our strategic We assess the following aspects audit timetable optimization and the requirements that B3 has planning, we created the in the case of BM&FBOVESPA wider coverage of the participants established regarding commodity Surveillance by Indicators segment participants: client audited in the OTC segment, warehousing capacity and area, which is responsible for registration; suitability; the encompassing all 37 products activity and regarding registration intensifying the indirect audits receipt, registration and registered with 76 participants in documentation. program. execution of orders; trade 2018. settlement; custody of assets; risk Indirect The following tests were performed management; investment club Joint generation, with the via indirect audits: administration; margin accounts; Surveillance by Indicators area, audits self-employed investment agents; of indicators and audit samples, Complementing operational • compliance with the economic and information technology. using statistical software and audits, our indirect audits (also and financial requirements 17

foreseen in the B3 Access B3 through an intermediary, who is • Assessment of plan of action Manual responsible for monitoring customers’ adequacy and/or compliance portfolio compliance • trades and for setting trading limits. in the Settlement Agreement and the submission of that participants submit to investment club reports To preserve market integrity, it is BSM. • linked person trading via a important for participants to have different participant to that adequate pre-trading risk control • Survey into participants’ which it is linked. systems, which check whether the master letter of credit use. orders entered and positions held by customers comply with certain Pre-operational audits The main activities performed by pre-requisites. BSM is responsible for the audit in 2018 are summarized To become a B3 participant in auditing this tool when the participant in Table 2. a particular access category, requests accreditation of a new an institution must meet trading system with B3. several operating, technological Table 2 – Audits held in 2018 and financial requirements Specific audits which are checked in a pre- Type of audit Number operational audit. We perform specific audits motivated Operational – Trading participants (brokers by complaints received or by requests and dealers) 58 Pre-trading risk tool from the CVM, Central Bank of Brazil Operational – Registration participants and or B3. The major work in this regard audits requalification 70 since 2018 is described below. Operational – Agribusiness Depository 2 Direct Market Access (DMA) Absence of customer orders met by Operational – Self-Employed Investment occurs when the investor the participant’s agents. Agents 490 directly accesses B3’s trading Indirect 0 system by means of an Diagnosis regarding simplified Pre-operational 17 automated connection. Four registration for nonresident investors. Specific 11 models of DMA currently Pre-trading risk tools – DMA 1 operate at B3. • Revision of the Standard Rules of B3’s Operational Qualification Whatever the DMA model, Program (PQO). an investor can only access 18

Market guidance emails, which generally regarded program for 2019 at our website. controls environment, in a way clarification of doubts about rules This allows participants to apply that promotes transparency and Participant guidance is a pillar of and processes. the same approach used for the knowledge-sharing and that BSM’s activity. In 2018, we held 136 BSM audit in the assessment cooperates in market compliance meetings and sent answers to 459 We have published the audit of their processes and internal with the rules.

LEARN MORE bsmsupervisao.com.br 19

MARKET SURVEILLANCE

Surveillance activity seeks anomalies that could be related to irregular activities such as market manipulation; misuse of privileged information; creation of artificial conditions of demand, supply or price; unfair practices; and the irregular performance of activities. All alerts are analyzed by the Market Surveillance team, which may also request clarification from the participants. 20

Market Oversight Reports Table 3 – Irregularities identified in Cetip UTVM segment transactions (Market Oversight Reports Initiated in 2018) When there are signs of irregularities, following the analysis of an alert or Irregularity Number complaint, a Market Oversight Report is initiated. Price manipulation or artificial supply, demand or price conditions 13 Signs of money laundering (money transfers between investors or other irregularities) 8 In 2018, 246 reports were initiated, 27 Unfair practices 2 of which for transactions executed in the Cetip UTVM segment (OTC market) Order registration and control failures 2 and 219 for trades executed in the Registration process failures 2 BM&FBOVESPA segment. Total 27

The main irregularities targeted in these reports are set out in Tables 3 and 4. Table 4 – Irregularities identified in BM&FBOVESPA segment transactions In the same period, 168 reports were (Market Oversight Reports initiated in 2018) completed. Of these, 78 were dismissed and nine submitted for adoption of Irregularity Quantity enforcement measures. Another 81 Price manipulation or artificial market conditions 119 cases were sent on directly to the CVM, Undue use of privileged information 49 as they regarded situations where the offenders are not B3 participants Signs of money laundering (money transfers between investors or other irregularities) 24 (or their employees or agents) and Unfair practices, deprioritization and/or fraudulent transactions 17 therefore outside of the scope of the Irregular portfolio management 2 BSM’s activity. Order registration and control failures 2 Suitability 2 Registration process failures 2 Other irregularities 2 Total 219 21

Table 5 – Reports received, concluded and in progress (Market Oversight Reports in 2018) Summary of market these guidance activities daily by oversight activities in telephone or email. Phase Number 2018 BSM also participates in an intensive Initial caseload (reports in progress on January 1, training routine directly on the 76 Table 5 sets out the overview of 2018) investigations (Market Oversight participants’ premises whenever requested. In 2018, these training (+) Initiated 246 Reports) in 2018. sessions dealt with the combat of abusive market practices and the (-) Dismissed 78 Market guidance prevention of money laundering. (-) Forwarded to CVM 81 As highlighted in section 2 of this In many of these cases there was Annual Report, one of our pillars guidance about analyzing the alerts (-) Forwarded for enforcement 9 of activity is market guidance. that are shared by BSM, described in BSM Market Surveillance performs Box 2. Final caseload (claims in progress on December 31, 2018) 154

SHARING ALERTS WITH THE MARKET

In 2017, BSM began to share alerts with the market. Initially (April November 2017, and in 2018 enhancements were made based on 2017), the alerts shared with participants were about transactions accumulated experience and inputs from the market. showing signs of layering and spoofing. The success of the experience, and demand from participants, The alerts must be analyzed by the participants and, if they meant that we began to share alerts about transactions showing discover an irregularity, they must take measures to prevent signs of money laundering. More specifically, money transfers its recurrence and if such is required communicate it to the between investors, as described in CVM Instruction 301 – Art. competent authorities. 6, subparagraphs II and VII. These alerts began to be shared in 22

Supervision of securities issued by B3

Pursuant to Art. 58 of CVM Instruction 461/2007, BSM is responsible for the analysis of transactions with securities issued by B3, to ensure that as an issuer of listed equities, B3 complies with all of the general rules for issuers. This activity is also performed by BSM Market Surveillance. 23

SURVEILLANCE BY INDICATORS

In 2018, we created the Surveillance by Indicators (SSI) area, which has a multidisciplinary team of economists, auditors, statisticians and data engineers for the performance of modeling, data mining and indicator management activities. 24

The SSI’s activities are thus and implementation of We also execute inter-disciplinary efficiency in the identification and connected to the development systems projects involving all of the B3 gathering of information, as well as of quantitative studies (Data Group, such as a joint project the timely submission of answers Analytics), management of data In compliance with the CVM, since with Fixed Income Depository, to official letters. bases and the development of 2018 BSM has had full autonomy where BSM analysts helped to management dashboards and over the data bases of assets develop a bank CD control tool in Furthermore, SSI has a unit Business Intelligence (BI). SSI also registered at the organized OTC compliance with new rules from responsible for communication monitors BSM’s projects. market environment of B3. the Brazilian Central Bank. and marketing activities and for support in the performance SSI’s main activities include: In 2018, we also reviewed all of The team also monitors Statistical of market guidance activities BSM’s data bases and developed Analysis System (SAS) training for (training, workshops, production of • development, jointly with the a project that seeks to unify the other B3 departments. The course videos and drafting reports for the Market Surveillance team, of bases, allowing greater systemic seeks to train professionals in general public and regulators), as models that seek to identify efficiency. this statistical software, teaching well as the production of content transactions with signs of how to develop queries and more at the BSM website. irregularities Furthermore, we implemented detailed analyses at large data • generation of samples for the important enhancements to the bases. This unit is also responsible for audit team’s work alerts for market surveillance, receiving and monitoring the • processing of indirect audit both those used internally by Other SSI activities complaints sent to BSM and for routines (audits by indicators) the Market Surveillance team managing the Contact Center. • generation of dashboards with and those that are shared by the SSI is also responsible for meeting management indicators of market. the requirements of regulatory Finally, SSI performs financial and BSM’s main activities bodies and other institutions budgetary monitoring of BSM. • monitoring of BSM’s projects, The indirect audits allow such as the Federal Police. The especially those regarding the inspection of a broader range of concentration of this activity development, enhancement OTC products. into the SSI team has enabled 25

ENFORCEMENT

An effective supervision system requires that infractions and identified problems be dealt with appropriately, with education or persuasion measures, or the application of penalties, so that offenders are guided or punished and the problems solved. This disciplinary activity known as enforcement seeks to enhance the standards of conduct of B3 participants and to encourage the adoption of internal controls capable of preventing repetition of the infractions. 26

As described in Figure 2, signs of infractions Figure 2 – Schematic diagram of the enforcement process discovered within the scope of surveillance activities, auditing, complaints to the MRP and complaints received are analyzed and can give Trade Complaints Audit Complaints cause for enforcement actions, varying from Surveillance to MRP recommendations that the institution improve its processes and controls, to the bringing of Disciplinary Administrative Proceedings (PAD). This can result in BSM fining participants in the markets operated by B3, and their agents. Analysis and assessment

Letter of Recommendation and Letter of Determination Arquivamento Enforcement Measures Within the scope of our supervision activities, we may discover signs of irregularities that do not result in Disciplinary Administrative Proceedings (PAD), but which nonetheless require the participants’ attention. In these situations, we Persuasion Measures Punitive Measures can send a Letter of Recommendation or Letter of Determination, as a guidance measure for preventing recurrence. Letters of Recommendation Administrative Process In the Letter of Recommendation, we or Determination recommend that the participant improve its conduct, rules, procedures and/or internal controls. We may also determine that the Judgment or participant adopt a plan of action to improve the Settlement Agreement points singled out in the letter, noting that, in the plan of action, the participant must designate the measures to be adopted and the respective implementation plan. 27

In the Letter of Determination, we BSM Corporate Bylaws foresee the majority being independent for any losses caused by it, alert participants about irregular following penalties. members (ordinary proceedings). including to third parties. practices and determine that • Warning. these practices be curtailed and If convicted, the offender may The Settlement Agreement • Fine. not recur. appeal to the Plenary of BSM’s carries no weight in regard to • Suspension (up to 90 days). Supervisory Board, comprised of 11 the confession of facts, nor to • Temporary disqualification (up In 2018, 84 Letters of members. recognition of the illicit nature of to ten years). Recommendation were sent, conduct analyzed by the PAD. • Other penalties provided for in resulting from irregularities Within the scope of the PAD, the B3’s rules and regulations. identified in indirect audits, Settlement Agreement can be If there is compliance with the such as noncompliance with The administrative proceedings signed at any time as long as the Settlement Agreement, the B3’s economic and financial observe constitutional procedural defendant presents the proposal PAD will draw to a close. If there requirements and transactions principles, such as the right to by the date on which the case is is noncompliance with the by persons linked to another a full defense and the right to judged in the first instance. Settlement Agreement the PAD will participant. There were also 340 an adversarial hearing and are remain on its regular course and Letters of Determination sent. conducted in accordance with The BSM Supervisory Board proceed to judgment. BSM’s Procedural Rules, approved analyzes the Settlement Disciplinary by the Securities & Exchange Agreement proposal and it may In 2018, BSM analyzed 28 accept it, reject it, or make it Settlement Agreement proposals, Administrative Commission of Brazil and are available in Portuguese on the conditional, bearing in mind involving 54 accused parties, as Proceedings (PAD) website www.bsmsupervisao.com. opportunity and convenience, as shown in Graph 4 of which ten were well as the nature and seriousness approved and two were rejected. Infractions of applicable laws br, Legislação e Regulamentação of the infractions that have been and regulations by participants | Leis, Normas e Regras, BSM, analyzed, the prior record of the In addition to the 54 accused in B3’s markets may be subject Regulamento Processual. offenders, procedural economy, there were three proceedings in to Disciplinary Administrative and the realistic possibility of which the participants and agents Proceedings within the scope of The administrative proceedings punishment in concrete cases. involved in suspected irregularities, BSM which, in addition to B3’s are judged in the first instance presented Settlement Agreements participant institutions, involves by the Chief Regulatory Officer The Settlement Agreement requires prior to the initiation of a PAD. their representatives (partners or (summary proceedings) or by a the offender to cease the irregular directors) or agents (traders or panel of BSM’s Supervisory Board practice that gave rise to the Graph 5 shows the origin of the self-employed investment agents). comprised of three members, selected by lot and with the proceeding and pay compensation PADs initiated in 2018. 28

Graph 4 – Types of accused in PADs initiated Graph 5 – Origen of the PADs initiated in 2018 in 2018

19 5

14 12 Audit Official Letter* 7 4 17 Investor Compensation Mechanism Market Surveillance 1 1 2 Trader Self-Employed Self-Employed Brokerage Broker Other Investment Investment House Director Agent Office Agent

* Cases brought for failure to comply with BSM official letters. 29

ADMINISTRATIVE ACTIVITIES

For the full performance of the activities described herein, we have the support of a team of four professionals involved in secretariat and administrative support work. 30

The main tasks of the administrative support Tabela 6 – Secretariado e apoio administrativo em números team are described below. Activity Total Monthly average • Drafting, sending, receiving and controlling Correspondence sent 9,712 809 correspondence Correspondence received 3,225 269 • Scheduling and controlling internal Document digitizing (pages) 100,915 8,410 and external meetings, travel and other Processing of receipts 1,193 99 engagements Flight and hotel bookings 861 72 • Drafting, checking and sending applications for reimbursements and payments (Supervisory Board, CRO, managers, staff) Figure 3 – Geographical distribution of the AAIs • Controlling office material, equipment, conference rooms, subscriptions to 0 0 periodicals RR AP • Documentation – assembling case files, digitizing and filing 13 6 22 • Personal and telephone service 12 7 AM PA MA CE RN The work of this team allows, for example, audit PB 9 PI 0 PE professionals to visit all the participants and 37 1 AC AL their agents, such as self-employed investment TO SE RO 15 62 9 agents (AAI). BA 3 MT 55 37 DF The map below shows the distribution of the 24 GO 201 AAIs in Brazil and exemplifies the complexity Nº of MG of the logistics enabled by the secretariat and 3 48 external MS ES administrative support. AAIs: SP RJ 2.697* 454 PR 1.092 Table 6 shows key statistics for these activities. 145 * External AAIs are self-employed investment SC 154 agents that work in their own offices, not RS allocated at the HQ of a brokerage house, bank or securities dealer. 307