Circular Letter CVM/SEP 07/20

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
Seven of September Street, 111/2-5th and 23-34th Floors, Center, Rio de Janeiro/RJ – ZIP: 20050-901 – Brazil - Tel.:
(21) 3554-8686
Cincinato Braga Street, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – ZIP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – ZIP: 70712-900 – Brazil - Tel.:
(61) 3327-2030/2031 www.cvm.gov.br
Circular Letter No. 7/2020-CVM/SEP
Rio de Janeiro, August 26, 2020.
Subject: Presentations of "lives" with the presence of executives of publicly held companies

Dear Director of Investor Relations/Legal Representative,

1. We have verified that the existence of uncertainties regarding the effect of the Covid-19 pandemic on the performance of companies, as well as the modifications in work routines that have occurred in recent months, have fostered the more frequent holding of "lives," that is, "live" transmissions of presentations with the presence of executives of publicly held companies, usually organized by a third party, not the company itself.

2. First, we emphasize that the same rules provided for in the norms dealing with the disclosure of information apply to such events, notably those that regulate the disclosure of relevant information (CVM Instruction No. 358/02) and establish general rules on the content and form of the information that issuers must observe (articles 14 to 19 of CVM Instruction No. 480/09), especially article 16, according to which the issuer must disclose information in a comprehensive, equitable, and simultaneous manner to the entire market.

3. Regarding the publicity of events of this nature, even if held on platforms open to the general public, it is important to note that, since they do not appear on the company's Corporate Events Calendar and are organized by persons or entities unrelated to the company's administration, we recommend that a Market Notice be issued in advance, informing the date, time, and internet address where the "live" will be broadcast, which will feature the participation of some representative of the company.

4. Furthermore, according to article 30, item XIV, of CVM Instruction No. 480/09, the issuer must send via the Empresas.NET System the material presented in meetings with analysts and market agents, on the same day as the meeting or presentation. And, in accordance with the guidance contained in item 4.20 of CIRCULAR LETTER/CVM/SEP/No. 2/2020, "for the equitable treatment of all market participants, this material must be sent before or simultaneously with the start of the meeting, containing all relevant information that will be addressed in it."

5. This same guidance applies to the information to be disclosed in the aforementioned "live." Even if there is no visual presentation, in slides or any other format, the Market Notice informing about the holding of the event must also contain a list of the topics to be discussed, and potentially the questions that will be asked, which must be obtained from the organizers if there is no pre-defined agenda agreed upon with the company.

6. Again citing CIRCULAR LETTER/CVM/SEP/No. 2/2020, "if during the meeting there is the disclosure of information additional to that contained in the presentation material used, for example, as a result of questions formulated by meeting participants, these must be included in this material, which must be resubmitted via the Empresas.NET System, without prejudice to the provisions of article 3 of CVM Instruction No. 358/02, in cases where such information constitutes a Relevant Fact."

7. If it is not possible to disclose the content of the presentation in advance, due to the impossibility of obtaining such information from the organizers, or due to a free-format presentation style, we recommend that the "live" be held outside of trading hours, preferably after market close, so that the IR team has time to prepare the material that must be disclosed after the end of the event in the Empresas.NET System, containing the main information disclosed at the event and that is not contained in documents already disclosed by the company.

8. It is important to mention, finally, that, due to the scenario mentioned, this letter highlights and details guidance already contained in CIRCULAR LETTER/CVM/SEP/No. 2/2020 and does not present innovations regarding the obligations provided for in Law 6.404/76 and CVM Instructions 358/02 and 480/09.

Sincerely,

FERNANDO SOARES VIEIRA
Superintendent of Corporate Relations

Document electronically signed by Fernando Soares Vieira, Superintendent, on 08/26/2020, at 08:35, based on art. 6, § 1, of Decree No. 8.539, of October 8, 2015.
Circular Letter 7 (1082563) SEI 19957.005870/2020-56 / pg. 2

The authenticity of the document can be checked on the site https://sei.cvm.gov.br/conferir_autenticidade, informing the code verifier 1082563 and the CRC code B577BBF0.
This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 1082563 and the "CRC Code" B577BBF0.
Reference: Process No. 19957.005870/2020-56 SEI Document No. 1082563 Circular Letter 7 (1082563) SEI 19957.005870/2020-56 / pg. 3