Circular Letter CVM/SIN 06/2019

SECURITIES COMMISSION

Sete de Setembro Street, 111/2-5th and 23-34th Floors – Center – Rio de Janeiro - RJ – CEP: 20050-901 – Brazil Tel.: (21) 3554-8686 - www.cvm.gov.br

Circular Letter No. 6/2019/CVM/SIN Rio de Janeiro, June 14, 2019

To securities analysts

Subject: Information or communications of an institutional and advertising nature.

1. This Circular Letter aims to guide securities analysts on the best way to comply with CVM Instruction No. 598 (“ICVM 598”), by providing clarifications on the correct observance of provisions of the aforementioned regulation. Observing the recommendations listed below will contribute to minimizing potential deviations and raising awareness among participants regarding the appropriate manner of communicating with the public concerning the activity of providing securities analyst services.

2. The content addressed in this Circular Letter is the result of questions raised by market participants and investors, and perceptions arising from the supervision work of the technical area.

3. For the purposes of Article 14 of ICVM 598 and the norms provided in Article 5, Item I, of the same Instruction, including with regard to the adoption of the "calm and moderate language" guideline provided in the regulation, communications and information disclosed to the market by securities analysts will be understood as regular if they:

I. Demonstrate that they are the opinion of the author, with guarantees of return of any kind prohibited. This prohibition does not include the possibility of the author expressing – in the advertising piece – their projection regarding specific return percentages, emphasizing that it is their personal opinion.

II. Are accompanied by a warning regarding the risks related to the investment addressed, evidencing that:

a. past returns, when mentioned, are based on facts capable of demonstration, serving only as historical reference and not as a guarantee of future returns;

b. investments involve risks and may result in losses, including the total invested capital, or even the need for additional contributions, as applicable;

and

c. the values and return percentages were estimated based on information available at the time and considered reliable in the analyst's assessment.

4. Furthermore, regarding the recommendations contained in items I and II.a, to ensure a language that does not inappropriately attribute a perception of certainty to these returns for the recommended assets, we suggest the use of terms that confer this connotation, such as, for example, "may," "possible," "possibility," "projected," "potential," among others.

Sincerely,

Digitally signed by
DANIEL WALTER MAEDA BERNARDO
Superintendent of Institutional Investor Relations