CVM Instruction No. 598, of May 3, 2018, Provides for the activity of securities analyst (Revoked)

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 Provides for the activity of securities analyst. THE PRESIDENT OF THE SECURITIES AND EXCHANGE COMMISSION - CVM hereby makes public that the Board, at a meeting held on April 18, 2018, in view of the provisions of arts. 1, item VIII; 8, items I and III; 15, § 1; 18, item I, subparagraph “b”; and 27 of Law No. 6,385, of December 7, 1976, APPROVED the following Instruction:
CHAPTER I – DEFINITIONS AND SCOPE
Art. 1 Securities analyst is a natural or legal person who, professionally, prepares analysis reports intended for publication, disclosure or distribution to third parties, even if restricted to clients. § 1 For the purposes of this Instruction, the term “analysis report” means any texts, monitoring reports, studies or analyses on specific securities or on determined securities issuers that may assist or influence investors in the investment decision-making process. § 2 Public exhibitions, presentations, videos, meetings, conference calls and any other unwritten manifestations, whose content is typical of an analysis report, are equated to analysis reports, for the purposes of this Instruction. § 3 This Instruction does not apply to natural or legal persons who develop risk rating activities. Art. 2 The activity of securities analysis is exclusive to securities analysts accredited by an entity authorized by the CVM, in accordance with art. 4.

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018
CHAPTER II – ACCREDITATION FOR THE ACTIVITY OF SECURITIES ANALYST
Section I – Mandatory Accreditation
Art. 3 Accreditation is mandatory for:
I – natural person securities analysts who carry out the activity autonomously; II – institutions belonging to the distribution system that carry out the activity of securities analyst; and III – any other legal person who carries out the activity of securities analyst.
Section II – Accrediting Entities
Art. 4 The accreditation of securities analysts is carried out by entities authorized by the CVM.
Sole Paragraph. Self-regulatory entities that prove to have: will be authorized by the CVM to promote the accreditation referred to in the caput:
I – adequate structure and technical capacity to comply with the obligations provided for in this Instruction; and II – a self-regulatory structure with technical capacity and independence. Art. 5 Accrediting entities must:
I – adopt a professional code of conduct prepared in accordance with art. 8; II – supervise, in relation to the securities analysts accredited by them:

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 a) compliance with their professional code of conduct; and b) compliance with the provisions of this Instruction; III – punish infringements of their professional code of conduct committed by the securities analysts accredited by them; IV – assess, through ethics and technical qualification exams, whether candidates are fit to exercise the activity of natural person securities analyst; V – assess, in the case of a legal person, the structure and requirements for exercising the activity; VI – institute a continuing education program; VII – keep on file all documents that prove compliance with the requirements contained in this Instruction for 5 (five) years; VIII – maintain an updated register of all securities analysts accredited by them; and IX – disclose on their website a list of accredited securities analysts. Sole Paragraph. The CVM will previously approve:
I – the professional code of conduct mentioned in item I of the caput, as well as any changes; II – the programmatic content of the exams applied by the accrediting entity in accordance with item IV; and III – the continuing education program.

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 Art. 6 Accrediting entities must provide certificates regarding securities analysts accredited by them, as well as natural or legal person analysts undergoing the accreditation process, indicating registration regularity and any penalties applied in the last 5 (five) years. Art. 7 The accrediting entity must send to the CVM:
I – immediately upon knowledge, information about indications of a serious infringement of CVM rules; II – by the last day of the month following the end of each semester or whenever the CVM requests:
a) a report on the supervision and observance of legal and regulatory norms, mentioning the efforts undertaken to ascertain the regularity of conduct, the name and qualification of those involved, whether accredited or not, as well as other measures adopted; and b) a report on the supervision and observance of the norms of its professional code of conduct, mentioning the securities analysts investigated, the scope of the work performed, the irregularities identified, the penalties applied and other measures adopted; III – by January 31 of each year, a report containing the proposed action plan for the subsequent fiscal year; and IV – whenever requested, documents and information mentioned in art. 5, items VII and VIII. Sole Paragraph. The report referred to in item III may be submitted to the CVM as part of the report referred to in item II, subparagraph “a” concerning the second semester of each year.
Section III – Professional code of conduct
Art. 8 The professional code of conduct must provide, at a minimum, for:

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 I – potential conflict of interest situations in the exercise of the securities analyst activity; II – commitment to seek reliable and trustworthy information to be used in analyses, recommendations and presentations made by the securities analyst; III – duty of independence of the securities analyst, including in relation to the person or institution to which they are linked, when applicable; IV – duty to comply with this Instruction and other rules issued by the CVM that deal with the activity of securities analyst; V – applicable penalties when there are infringements of the professional code of conduct; and VI – regulate the forms of communication, advertising and the language used by securities analysts in their interaction with their clients and the general public, in accordance with art. 14.
Section IV – Accreditation of natural person securities analysts
Art. 9 To grant and maintain the accreditation referred to in art. 4, the accrediting entity must require the natural person securities analyst to meet the following minimum requirements:
I – higher education degree;
II – approval in technical qualification exams defined by the CVM; III – unconditional adherence to their professional code of conduct; IV – have an unblemished reputation; V – not be disqualified or suspended from holding a position in financial institutions and other entities authorized to operate by the CVM, by the Central Bank of Brazil, by the

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 Superintendence of Private Insurance – SUSEP or by the National Superintendence of Complementary Pensions – PREVIC; and VI – not have been convicted of bankruptcy crime, prevarication, bribery, extortion, embezzlement, money laundering or concealment of assets, rights and values, against the popular economy, economic order, consumer relations, public faith or public property, the national financial system, or a criminal penalty that prohibits, even temporarily, access to public office, by a final and unappealable decision, except in the case of rehabilitation. Art. 10. The natural person securities analyst and the persons responsible for the activities referred to in items IV and V of art. 11 may not obtain or maintain registration as an autonomous investment agent.
Section V – Accreditation of legal person securities analysts
Art. 11 To grant and maintain the accreditation referred to in art. 4, the accrediting entity must require the legal person securities analyst to meet the following minimum requirements:
I – have its headquarters in Brazil;
II – have the activity of securities analysis in its corporate purpose, except for the legal persons mentioned in art. 3, item II; III – be duly constituted and registered in the National Register of Legal Entities - CNPJ; IV – assign responsibility for the securities analysis activity to a natural person securities analyst accredited by an entity authorized by the CVM in accordance with art. 4; V – assign responsibility for the implementation and compliance with internal rules, procedures and controls and the norms established by this Instruction to a statutory director;

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 VI – its direct or indirect controlling partners must meet the requirements set forth in items V and VI of art. 9; and VII – establish and maintain human and computational resources adequate to the size and area of activity of the legal person. § 1 The assignment of responsibility for the securities analysis activity must be recorded, in the case of the entities mentioned in art. 3, item III, in the articles of association, in the bylaws of the legal person or in the manner indicated by the bylaws. § 2 In the event of an impediment of the person responsible for the securities analysis activity referred to in item IV of the caput for a period exceeding 30 (thirty) days, the substitute must assume said responsibility, and the accrediting entity must be notified, in writing, within 1 (one) business day from its occurrence. § 3 The functions referred to in items IV and V of the caput cannot be performed by the same person. § 4 The person responsible for the securities analysis activity referred to in item IV of the caput cannot be responsible for any other activity in the securities market, within or outside the institution. § 5 It is the responsibility of the person responsible for the securities analysis activity referred to in item IV to define and supervise the guidelines and methodologies adopted in the analyses and respective reports, as well as to verify their consistency and conformity with the institution's premises. § 6 Without prejudice to the provisions of § 4 of this article, the persons referred to in items VI and V of the caput may be responsible for the same activity in controlling, controlled, affiliated or commonly controlled companies.
CHAPTER III – RULES OF CONDUCT
Section I – Rules of Conduct

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 Art. 12. The securities analyst must act with probity, good faith and professional ethics. Sole Paragraph. Analysis reports must be prepared by the analyst, employing all the care and diligence expected of a professional in their position. Art. 13. The securities analyst, natural and legal person, as well as other professionals who effectively participate in the formulation of analysis reports, are prohibited from:
I – issuing analysis reports with the purpose of obtaining, for themselves or for others, undue advantage; II – omitting information about conflicts of interest in the information and communications referred to in art. 14, in analysis reports and in any medium in which the analyst comments on the analysis report; III – trading, directly or indirectly, on their own behalf or on behalf of third parties, securities that are the subject of the analysis reports they prepare or derivatives backed by such securities for a period of 30 (thirty) days before and 5 (five) days after the disclosure of the analysis report on such security or its issuer; IV – trading, directly or indirectly, on their own behalf or on behalf of third parties, securities that are the subject of the analysis reports they prepare or derivatives backed by such securities in a manner contrary to the recommendations or conclusions expressed in the analysis reports they prepared for:
a) 6 (six) months from the disclosure of such report; or b) until the disclosure of a new report on the same issuer or security, if it occurs before the period referred to in subparagraph “a”; V – participating, directly or indirectly, in any activity related to a public offering of securities, including:

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 a) sales efforts for products or services within the scope of the securities market; and b) efforts to attract new clients or work; VI – participating in the structuring of financial assets and securities; VII – participating, directly or indirectly, in any activity related to financial consulting in mergers and acquisitions operations; and VIII – disclosing the analysis report or its content, even partially, to a person who is not part of the analysis team, especially the issuer subject to the analysis or whose securities are subject to the analysis, before its publication, disclosure or distribution through appropriate channels. § 1 The provisions of items III and IV of the caput do not apply to trading in investment fund units, unless:
I – the securities analyst can directly or indirectly influence the administration or management of the fund; or II – the fund concentrates its investments in sectors or companies covered by the reports produced by the securities analyst. § 2 The provisions of item V of the caput do not apply to activities of the securities analyst aimed at investor education, provided that:
I – the securities analyst uses analysis reports without indicating a recommendation; II – the securities analyst does not communicate with investors in the presence of any person linked to the product or service distribution area or to the issuer; and III – the legal person to which the securities analyst is linked has written records of the investors who participated in the investor education activity.

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 § 3 The provisions of item VIII of the caput do not apply:
I – to cases where the factual parts of the report have been disclosed to third parties with the aim of verifying the veracity of the information contained therein; and II – to review by legal advisors and the internal controls area. § 4 The provisions of items III, IV, V, VI and VII of the caput do not apply to operations and activities carried out by other departments of the legal person, provided that the segregation of activities in relation to the analysis department is ensured.
Section II – Forms of Communication
Art. 14. Institutional and advertising information or communications related to the provision of securities analyst services must:
I – be true, consistent and not mislead the investor; and II – use calm and moderate language.
§ 1 The information or communications referred to in the caput cannot contain a promise of future profitability or assure or suggest the existence of a guarantee of future results or risk exemption for the investor. § 2 The norms of this article cover disclosures made through newspapers, magazines, the world wide web, programs, applications, electronic messages or any other similar means of communication. Art. 15. If the information or communications referred to in art. 14 present inaccuracies or improprieties that may mislead the investor, the CVM or the accrediting entity may require:
I – the cessation of the disclosure of the information; and

SECURITIES AND EXCHANGE COMMISSION
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil -Tel.: (61) 3327-2030/2031 www.cvm.gov.br CVM INSTRUCTION NO. 598, OF MAY 3, 2018 II – the publication, with equal prominence and through the vehicle used to disclose the original information, of rectifications and clarifications, explicitly stating that the information is being republished by determination of the CVM or the accrediting entity, as the case may be, and, prominently, what information is being rectified or clarified.
CHAPTER IV – INTERNAL RULES, PROCEDURES AND CONTROLS
Art. 16. The legal person securities analyst must:
I – develop and implement adequate internal rules, procedures and controls to:
a) ensure compliance with the provisions of this Instruction; b) perform their functions independently; c) prevent their commercial interests, or those of their clients, from influencing the outcome of their analyses; and d) identify, manage and eliminate potential conflicts of interest that may affect the impartiality of their analysis reports; II – disclose the set of rules resulting from item I, as well as their updates, on their website; III – communicate to the CVM and the accrediting entity, within up to 5 (five) business days, conduct of analysts linked to it that may constitute an indication of infringement of the rules issued by the CVM; IV – when carrying out other activities that may give rise to potential conflicts of interest, physically segregate the facilities where the analysis team develops its activities; V – grant accrediting entities access to its facilities, files and documents related to the internal rules, procedures and controls related to compliance with this

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL (CVM) Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Center, Rio de Janeiro/RJ – ZIP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 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

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Instruction, so that they may exercise the supervisory functions attributed to them by this Instruction; VI – possess an organizational structure that ensures the impartiality of the opinion issued in analysis reports; and VII – structure the remuneration of its workforce in a manner that preserves its impartiality. Sole Paragraph. The rules, procedures and internal controls resulting from item I of the caput must provide, at least, the following:
I – methods for identifying conflict of interest situations; II – methods for managing conflict of interest situations; and III – type and manner of contact that the securities analyst may have with the issuers subject to their analyses.

Art. 17. Securities analysts that are legal entities must take all necessary measures so that their analysis teams are formed by, at least 80% (eighty percent) of securities analysts accredited by an entity authorized by CVM under the terms of art. 4º.

§ 1º Securities analysts that are legal entities must notify the accrediting entity of the disqualification from the provisions of the caput within 15 (fifteen) days from the date of the beginning of the disqualification, with the appropriate justifications.

§ 2º Securities analysts that are legal entities have 90 (ninety) days, counted from the beginning of the disqualification, to restore the percentage of securities analysts accredited required by this article.

§ 3º The requalification to the percentage of accredited securities analysts required by this article must be communicated to the accrediting entity within 15 (fifteen) days of its occurrence.

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL (CVM) Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Center, Rio de Janeiro/RJ – ZIP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 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

CVM INSTRUCTION No.
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Art. 18. Securities analysts who provide analysis services to administrators of securities portfolios must:
I – annually, by March 31, send to the accrediting entity the list of all portfolio managers for whom they provide the service referred to in the caput; and II – in case of interruption in the provision of such services, notify the accrediting entity within 30 (thirty) days.

CHAPTER V – ANALYSIS REPORT

Art. 19. Analysis reports must be written in clear and objective language, differentiating factual data from interpretations, projections, estimates and opinions.

§ 1º Whenever possible and appropriate, factual data must be accompanied by indication of their sources.

§ 2º Projections and estimates must be accompanied by the relevant premises and methodology adopted.

Art. 20. Analysis reports must be signed by, at least, one accredited securities analyst.

Art. 21. The individual securities analyst signatory of the report under the terms of art. 20 must include in all their analysis reports, clearly and with due emphasis, declarations:
I – attesting that the recommendations of the analysis report reflect solely and exclusively their personal opinions and that they were prepared independently, including with respect to the legal entity to which they are linked, if applicable; and II – informing the investor if he or any of the securities analysts involved in the preparation of the analysis report are in a situation that may affect the

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL (CVM) Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Center, Rio de Janeiro/RJ – ZIP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 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

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impartiality of the report or that constitutes or may constitute a conflict of interest, including, but not limited to cases where:
a) he or any of the securities analysts involved in the preparation of the report have a link with an individual who works for the issuer subject to the analysis report, clarifying the nature of the link; b) he or any of the securities analysts involved in the preparation, their spouses or partners, are directly or indirectly, in their own name or on behalf of third parties, holders of securities subject to the analysis report; c) he or any of the securities analysts involved in the preparation, their spouses or partners, are directly or indirectly involved in the acquisition, disposal or intermediation of the securities subject to the analysis report; d) he or any of the securities analysts involved in the preparation, their spouses or partners, have directly or indirectly, any financial interest in relation to the issuer subject to the analysis report, except for the provision in § 1º of art. 13; and e) their remuneration or that of any of the securities analysts is, directly or indirectly, influenced by revenues from business and financial operations performed by the entity to which they are linked.

§ 1º The securities analyst must inform the content of the declarations provided in item II, if one of the situations set forth therein is verified, in public exhibitions, presentations, videos, meetings, telephone conferences and any other non-written manifestations in which they participate for the dissemination or discussion of the analysis report that they prepared or whose content is typical of an analysis report.

§ 2º The provisions of § 1º do not apply to:
I – meetings with a single client or investor; or II – phone calls in which the securities analyst participates, on one side, and a single client or investor, on the other.

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL (CVM) Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Center, Rio de Janeiro/RJ – ZIP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 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

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Art. 22. Securities analysts that are legal entities are responsible for declaring, whenever applicable, clearly and with due emphasis, in all analysis reports they publish, disseminate or distribute, situations that may affect the impartiality of the analysis report or that constitute or may constitute a conflict of interest.

§ 1º Examples of conflicts of interest, for the purposes of this article, are situations in which the securities analysts that are legal entities, their subsidiaries, their controlling entities or companies under common control:
I – have relevant equity participations in the issuer subject to the analysis report or in which the issuer subject to the analysis report, its subsidiaries, its controlling entities or companies under common control have relevant participations in the securities analysts that are legal entities, their subsidiaries, their controlling entities or companies under common control; II – have relevant financial and commercial interests in relation to the issuer or to the securities subject to the analysis report; III – are involved in the acquisition, disposal or intermediation of the securities subject to the analysis report; and IV – receive remuneration for other services provided to the issuer subject to the analysis report or persons linked to it.

§ 2º The individual securities analyst acting on behalf of a securities analyst that is a legal entity must inform the content of the declarations provided in the caput in public exhibitions, presentations, videos, meetings, telephone conferences and any other non-written manifestations in which they participate for the dissemination or discussion of the analysis report that they prepared or whose content is typical of an analysis report.

§ 3º The provisions of § 2º do not apply to:
I – meetings with a single client or investor; or

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL (CVM) Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Center, Rio de Janeiro/RJ – ZIP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 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

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II – phone calls in which the securities analyst participates, on one side, and a single client or investor, on the other.

Art. 23. Securities analysts are responsible for:
I – sending the analysis reports to the accrediting entity, within 3 (three) business days from the date on which such reports are distributed; and II – keeping the analysis reports archived for 5 (five) years, from the date on which such reports are distributed.

Sole Paragraph. Individual securities analysts who act exclusively linked to legal entities are exempt from the obligation set forth in this
article, such obligation falling, in these cases, to the said legal entities.

Art. 24. The person who distributes, in Brazil, analysis reports on issuers of securities traded in Brazil or with respect to which there is a sales effort in Brazil, prepared by securities analysts resident and domiciled in other jurisdictions, is responsible for obtaining the declarations provided in art. 21 and making the declarations provided in art. 22.

Sole Paragraph. The analysis reports mentioned in the caput are exempt from the requirement contained in art. 20.

CHAPTER VI – PENALTIES

Art. 25. It constitutes a serious offense, for the purposes of the provisions of art. 11, § 3º, of Law No. 6.385, of 1976:
I – the non-observance of conduct rules and the rules, procedures and internal controls established in arts. 12 to 17; and II – the non-observance of the duties of accrediting entities established in arts. 5º to 7º; and

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL (CVM) Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Center, Rio de Janeiro/RJ – ZIP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 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

CVM INSTRUCTION No.
598, OF MAY 3, 2018

III – omitting or providing false information for the purposes of complying with the declarations contained in arts. 21 and 22.

CHAPTER VII - FINAL AND TRANSITIONAL PROVISIONS

Art. 26. CVM Instructions No. 483, of July 6, 2010, and No. 538, of October 23, 2013, are hereby revoked.

Art. 27. Securities analysts that are legal entities must register with an accrediting entity within 180 (one hundred and eighty) days after the entry into force of this Instruction.

Art. 28. This Instruction enters into force on the date of its publication.

Original signed by
Marcelo Barbosa
President