Listing segments

Only common shares

Common and preferred shares

Only common shares

Common and preferred shares (with additional rights)

Common and preferred shares (as per legislation)

Common and preferred shares (as per legislation)

Minimum percentage of outstanding shares (free float)

25% until the 7th year of listing

25% until the 7th year of listing

General rule: 20%            

Alternative rule: 15%, (i) in case of ADTV (average daily trading volume) remains equal to or greater than R$20 million, considering the trades performed in the previous 12 months; or (ii) in the hypothesis of entering into Novo Mercado, concurrently with a public offering, when the offer (a) exceeds R$ 2 billion; or (b) is between R$ 1 billion and R$ 2 billion, provided that the conditions established by the Regulation are being respected. Also, according to item ‘ii’, the company will be able to keep the free float at 15% of its capital stock for 18 months, as long as, by the end of that time period, the ADTV reaches R$ 20 million threshold, which must be consistent for 6 consecutive months.

General rule: 20%            

Alternative rule: 15%, (i) in case of ADTV (average daily trading volume) remains equal to or greater than R$20 million, considering the trades performed in the previous 12 months; or (ii) in the hypothesis of entering into Nível 2, concurrently with a public offering, when the offer (a) exceeds R$ 2 billion; or (b) is between R$ 1 billion and R$ 2 billion, provided that the conditions established by the Regulation are being respected. Also, according to item ‘ii’, the company will be able to keep the free float at 15% of its capital stock for 18 months, as long as, by the end of that time period, the ADTV reaches R$ 20 million threshold, which must be consistent for 6 consecutive months.

General rule: 20%            

Alternative rule: 15%, (i) in case of ADTV (average daily trading volume) remains equal to or greater than R$20 million, considering the trades performed in the previous 12 months; or (ii) in the hypothesis of entering into Nível 1, concurrently with a public offering, when the offer (a) exceeds R$ 2 billion; or (b) is between R$ 1 billion and R$ 2 billion, provided that the conditions established by the Regulation are being respected. Also, according to item ‘ii’, the company will be able to keep the free float at 15% of its capital stock for 18 months, as long as, by the end of that time period, the ADTV reaches R$ 20 million threshold, which must be consistent for 6 consecutive months.

There is no specific regulation

Public offering of shares

There is no specific regulation

There is no specific regulation

Share dispersion efforts, except for offers destined to a restricted public of investors, for example, those for professional or qualified investors (as per Letter 009/2023-DIE)

Share dispersion efforts, applying the same logic as the ones in Novo Mercado (as per Letter 736/2017-DRE)

Share dispersion efforts, applying the same logic as the ones in Novo Mercado (as per Letter 736/2017-DRE)

There is no specific regulation

Prohibition to statutory provisions

Qualified quorum and "immutable clauses"

Qualified quorum and "immutable clauses"

Voting limitation of less than 5% of the voting capital, qualified quorum and "immutable clauses"

Voting limitation of less than 5% of the voting capital, qualified quorum and "immutable clauses"

There is no specific regulation

There is no specific regulation

Composition of the Board of Directors

Minimum of 3 members, which, at least 20% must be independent (according to law/regulation), with unified term of up to 2 years (as per Letter 010/2023-DIE)

Minimum of 3 members, which, at least 20% must be independent (according to law/regulation), with unified term of up to 2 years (as per Letter 010/2023-DIE)

Minimum of 3 members (pursuant to Brazilian Corporations Law), of which at least 2 or 20% (whichever is greater) must be independent with unified term of up to 2 years

Minimum of 5 members, which, at least 20% must be independent, with unified term of up to 2 years (as per Letter 010/2023-DIE)

Minimum of 3 members, which, at least 20% must be independent (according to law/regulation), with unified term of up to 2 years (as per Letter 010/2023-DIE)

Minimum of 3 members, which, at least 20% must be independent (according to law/regulation), with unified term of up to 2 years (as per Letter 010/2023-DIE)

Prohibition of cumulation of positions

Chairman of the Board of Directors and the Chief Executive Officer or Main Officer by the same person

Chairman of the Board of Directors and the Chief Executive Officer or Main Officer by the same person

Chairman of the Board of Directors and the Chief Executive Officer or Main Officer by the same person (as per Letter 010/2023-DIE:  small-sized companies are excluded from this prohibition, in terms with  CVM’s regulation; however it doesn’t apply to companies listed in the special segment)

Chairman of the  Board of Directors and the Chief Executive Officer or Main Officer by the same person (as per Letter 010/2023-DIE:  small-sized companies are excluded from this prohibition, in terms with  CVM’s regulation; however it doesn’t apply to companies listed in the special segment)

Chairman of the  Board of Directors and the Chief Executive Officer or Main Officer by the same person (as per Letter 010/2023-DIE:  small-sized companies are excluded from this prohibition, in terms with  CVM’s regulation; however it doesn’t apply to companies listed in the special segment)

Chairman of the Board of Directors and the Chief Executive Officer or Main Officer by the same person.

Board of Directors’ duties

There is no specific regulation

There is no specific regulation

Statement on any public tender offer for the acquisition of shares issued by the company (with minimum requirements, including alternatives to the tender offer available on the market)

Statement on any public tender offer for the acquisition of shares issued by the company (with minimum requirements)

There is no specific regulation

There is no specific regulation

Financial Statements

As per legislation in force

As per legislation in force

As per legislation in force

Translated into English

As per legislation in force

As per legislation in force

Disclosure in English simultaneously with the disclosure in Portuguese

There is no specific regulation

There is no specific regulation

Material Information or Benefit distribution information (Notice to Shareholders or Notice to the market) and results press releases

There is no specific regulation besides the financial statements (see item above)

There is no specific regulation

There is no specific regulation

Annual public meeting

Optional

Optional

Public meeting (in-person or by any other means that allow remote participation) must be hold until 5 business days after the disclosure of the quarterly and annual financial statements about the information disclosed

Mandatory (in-person)

Mandatory (in-person)

Optional

Calendar of corporate events

Mandatory

Mandatory

Mandatory

Mandatory

Mandatory

Optional

Disclosure of additional information

Securities trading policy

Securities trading policy

Internal regulations of the Board of Directors, its Advisory Committees and the Fiscal Council (if there is one)

Code of Conduct (with minimum requirements)

The following policies with minimum requirements (except the Compensation Policy): (i) Compensation Policy; (ii) Nomination Policy of the Board of Directors, Advisory Committees and Executive Management Board; (iii) Risk Management Policy; (iv) Related Party Transaction Policy; (v) Securities Trading Policy

Disclosure of: (i) annual report of the statutory audit committee covering the points contained on the Regulation; (ii) quarterly minutes of the Board of Director’s meetings, informing the report by the non-statutory audit committee 

Securities negotiation policy and code of conduct

Securities negotiation policy and code of conduct

There is no regulation

Tag-along rights

100% for common shares

100% for common and preferred shares

100% for common shares

100% for common and preferred shares

80% for common shares (as per legislation)

80% for common shares (as per legislation)

Delisting from the Segment/Public Tender Offer

Compulsory Public Tender Offer, at least for the economic value, in case of registration canceling or segment exit, except if there is migration to Novo Mercado

Compulsory Public Tender Offer, at least for the economic value, in case of registration canceling or segment exit, except if there is migration to Novo Mercado or Nível 2

Compulsory Public Tender Offer, at least for the fair price, with minimum acceptance quorum of 1/3 (or higher, as established in the bylaws) of the free float shareholders.

Compulsory Public Tender Offer in case of registration canceling or segment exit

Not applicable

Not applicable

Becoming a Member of the Market Arbitration Chamber

Mandatory

Mandatory

Mandatory

Mandatory

Optional

Optional

Audit Committee

Optional

Optional

Mandatory setting up of an audit committee or statutory audit committee in compliance with the requirements set forth in the Regulation

Optional

Optional

Optional

Internal Auditing

Optional

Optional

Mandatory setting up of an auditing department in compliance with the requirements set forth in the Regulation

Optional

Optional

Optional

Compliance

Optional

Optional

Mandatory setting up of a compliance, internal controls and corporate risks department. It is not allowed the accumulation of compliance and operational functions

Optional

Optional

Optional