CVM Resolution No. 142 of June 15, 2022

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.gov.br/cvm

RESOLUTION CVM NO. 142, OF JUNE 15, 2022
Ratifies Technical Interpretation ICPC 06 of the Accounting Pronouncements Committee - CPC, which deals with the hedge of net investment in foreign operations.

The PRESIDENT OF THE SECURITIES AND EXCHANGE COMMISSION OF BRAZIL - CVM makes public that the Board, in a meeting held on May 4, 2022, based on §§ 3 and 5 of art. 177 of Law No. 6,404, of December 15, 1976, combined with items II and IV of § 1 of art. 22 of Law No. 6,385, of December 7, 1976, as well as arts. 5 and 14 of Decree No. 10,139, of November 28, 2019,

APPROVED the following Resolution:

Art. 1. The obligation for open companies to apply Technical Interpretation ICPC 06, which deals with the hedge of net investment in foreign operations, issued by the Accounting Pronouncements Committee - CPC, as per Annex “A” to this Resolution, is hereby ratified.

Art. 2. Deliberation 616, of December 22, 2009, is hereby revoked, from the effective date of this Resolution.

Art. 3. This Resolution enters into force on July 1, 2022.

Signed electronically by
Marcelo Barbosa
President

RESOLUTION CVM NO. 142, OF JUNE 15, 2022

ANNEX “A”

ACCOUNTING PRONOUNCEMENTS COMMITTEE
TECHNICAL INTERPRETATION ICPC 06
HEDGE OF NET INVESTMENT IN FOREIGN OPERATIONS
Correlation to International Financial Reporting Interpretations Committee – IFRIC 16

Index Item
REFERENCES
BACKGROUND 1 – 6
SCOPE 7 – 8
ISSUES 9
CONSENSUS 10 – 18
Nature of the hedged risk and amount of the hedged item for which a hedge relationship can be designated 10 – 13 Where the hedging instrument can be held 14 – 15 De-recognition of hedge of foreign operation 16 – 18 TRANSITION 19
APPENDIX – APPLICATION GUIDE

RESOLUTION CVM NO. 142, OF JUNE 15, 2022

References

Technical Pronouncement CPC 23 – Accounting Policies, Changes in Accounting Estimates and Errors
Technical Pronouncement CPC 02 – Effects of Changes in Foreign Exchange Rates and Conversion of Financial Statements
Technical Pronouncement CPC 38 – Financial Instruments: Recognition and Measurement

Background

Many accounting entities have investments in international operations (as defined in Technical Pronouncement CPC 02, item 8). These foreign operations may be controlled, affiliated, joint ventures, or branches. Technical Pronouncement CPC 02 requires the entity to determine the functional currency of each of its foreign operations as the currency of the primary economic environment of that operation. When translating the results and balance sheet of the foreign operation into the presentation currency, the entity must recognize foreign currency differences in other comprehensive income as cumulative translation adjustments until the disposal of the foreign operation.
Hedge accounting for foreign currency risk arising from the net investment in foreign operations shall only be applied when the net assets of that operation are included in the financial statements. The item being hedged against foreign exchange risk arising from the investment in the foreign operation may be an amount of net assets equal to or less than the carrying amount of the net assets of that foreign operation.
Technical Pronouncement CPC 38 requires the designation of the hedged item and the corresponding hedging instrument in the hedge accounting relationship. If a hedge relationship is designated, in the case of a net investment hedge, the loss or gain on the hedging instrument that is determined to be an effective hedge of the net investment must be recognized in other comprehensive income as cumulative translation adjustments and must be included together with the foreign currency differences arising from the translation of the results and balance sheet of the foreign operation.
An entity with many foreign operations may be exposed to a number of different foreign exchange risks. This Interpretation provides guidance on identifying foreign exchange risks that qualify as risks hedged by a net investment in a foreign operation.
Technical Pronouncement CPC 38 allows the entity to designate a financial derivative or non-derivative instrument (or a combination of a financial derivative and non-derivative instrument) as a hedging instrument for foreign currency risk. This Interpretation provides guidance on where, within a group of entities, hedging instruments that are hedges of net investments in foreign operations must be held to be classified as hedge accounting.
Technical Pronouncements CPC 02 and CPC 38 require that the accumulated amounts recognized, in other comprehensive income, as cumulative translation adjustments, related to foreign exchange differences arising from the translation of the results and balance sheet of the foreign operation and the gain or loss on the hedging instrument, which is determined to be an effective hedge of net investment in a foreign operation, be reclassified from equity to profit or loss as a reclassification adjustment when the parent disposes of the foreign operation. This Interpretation provides guidance on how the entity should determine the amounts to be reclassified from equity to profit or loss, both for the hedging instrument and for the hedged item.

Scope
7. This Interpretation applies to the entity that hedges the foreign currency risk arising from its net investment in foreign operations and wishes to classify the transaction for hedge accounting in accordance with Technical Pronouncement CPC 38. For convenience, this Interpretation refers to this entity as the parent and the financial statements in which the net assets of the foreign operations are included as consolidated financial statements. All references to the parent apply equally to the entity that has a net investment in a foreign operation that is a joint venture, an affiliate, or a branch.

This Interpretation applies only to hedges of net investments in foreign operations and should not be applied by analogy to other types of hedge accounting.

Issues
9. Investments in foreign operations may be held directly by the parent or indirectly by its subsidiary or subsidiaries. The issues addressed in this Interpretation are:
(a) the nature of the hedged risk and the amount of the hedged item for which a hedge relationship can be designated:
(i) whether the parent can designate as the hedged risk only the foreign exchange differences between the functional currencies of the parent and its foreign operations, or whether it must also designate as the hedged risk the foreign exchange differences arising from the difference between the presentation currency of the parent's consolidated statement and the functional currency of the foreign operation; (ii) if the parent holds the foreign operation indirectly, whether the hedged risk can include only the foreign exchange differences arising from differences in functional currencies between the foreign operation and its immediate parent, or whether the hedged risk can also include any foreign exchange differences between the functional currency of the foreign operation and any intermediate or ultimate controlling company (if the fact that the net investment in the foreign operation is held through the intermediate parent affects the economic risk of the ultimate parent). (b) where in the group of entities the hedging instrument can be held:
(i) whether an identified hedge accounting relationship can be established only if the entity, hedging its net investment, participates in the hedging instrument or if any entity in the group, regardless of its functional currency, can hold the hedging instrument; (ii) whether the nature of the hedging instrument (derivative or non-derivative) or the consolidation method affects the verification of hedge effectiveness; (c) what amounts should be reclassified from equity to profit or loss as a reclassification adjustment upon disposal of the foreign operation:
(i) when a foreign operation that was hedged is disposed of, what amounts of the cumulative translation adjustments of the parent company, referring to the hedging instrument and that foreign operation, should be reclassified from equity to profit or loss in the consolidated financial statements of the parent company; (ii) whether the consolidation method affects the determination of the amounts to be reclassified from equity to profit or loss.

Consensus
Nature of the hedged risk and amount of the hedged item for which a hedge relationship can be designated
10. Hedge accounting can only be applied to foreign exchange differences between the functional currency of the foreign operation and the functional currency of the parent company.

In hedging foreign exchange risks arising from net investment in foreign operations, the hedged item may be an amount of net assets equal to or less than the carrying amount of the net assets of the foreign operation presented in the consolidated financial statements of the parent company. The carrying amount of the net assets of the foreign operation that can be designated as the hedged item in the consolidated financial statements of the parent depends on whether any other intermediate controlling company of the foreign operation has applied hedge accounting for all or part of the net assets of that foreign operation and whether this accounting has been maintained in the consolidated financial statements of the ultimate parent company.
The hedged risk can be conceptualized as the foreign currency exposure arising from the functional currency of the foreign operation and the functional currency of any controlling company of the group (immediate, intermediate, or ultimate parent) of the foreign operation. The fact that the net investment is held through an intermediate parent does not affect the nature of the economic risk arising from the foreign exchange exposure of the ultimate parent.
Exposure to foreign currency risk arising from net investment in foreign operations can be classified as hedge accounting only once in the consolidated financial statements. Thus, if the same net assets of a foreign operation are hedged by more than one controlling company within the group (for example, simultaneously by the direct and indirect controlling company) for the same risk, only one hedge relationship will be classified as hedge accounting in the consolidated financial statements of the ultimate parent. The hedge relationship designated by a controlling company of the group in its consolidated financial statements does not need to be maintained by another controlling company at a higher level. However, if it is not maintained by a controlling company at a higher level, the hedge accounting applied by the intermediate controlling company must be reversed before the hedge accounting is recognized by the controlling company at a higher level.

Where the hedging instrument can be held
14. A derivative or a non-derivative instrument (or a combination of derivative and non-derivative instruments) may be designated as a hedging instrument in a hedge of net investment in a foreign operation. Hedging instruments may be held by any entity or entities within the group (except in the foreign operation that is being hedged) provided that the classification, documentation, and effectiveness requirements of Technical Pronouncement CPC 38, item 88, relating to the hedge of net investment, are met. In particular, the group's hedging strategy must be clearly documented due to the possibility of different classifications at different levels of the group.

For the purpose of verifying the effectiveness of hedge accounting, the change in the value of the hedging instrument, relative to the foreign exchange risk, must be computed with reference to the functional currency of the parent company against the functional currency whose risk being hedged is measured, in accordance with the hedge accounting documentation. Depending on where the hedging instrument is held, in the absence of hedge accounting, the total change in value may be recognized in profit or loss, in other comprehensive income, or in both. However, the verification of effectiveness should not be affected if the recognition of the change in the value of the hedging instrument is done in profit or loss or in other comprehensive income as cumulative translation adjustments. As part of the application of hedge accounting, the effective portion of the hedge must be included in cumulative translation adjustments. The verification of effectiveness should not be affected by the fact that the hedging instrument is or is not a derivative or by the consolidation method.

De-recognition of hedge of foreign operation
16. When the foreign operation that was hedged is disposed of, the amount reclassified to profit or loss in the consolidated financial statements of the parent company as a reclassification adjustment of cumulative translation adjustments, with respect to the hedging instrument, must be the amount that Technical Pronouncement CPC 38, item 102, requires to be identified. This amount is the cumulative gain or loss on the hedging instrument that was designated as an effective hedge.

The amount of cumulative translation adjustments reclassified to profit or loss in the consolidated financial statements of the parent company with respect to the net investment in that foreign operation in accordance with Technical Pronouncement CPC 02, item 48, must be the amount included in the cumulative translation adjustments of that entity. In the consolidated financial statements of the ultimate parent, the aggregate net amount recognized as cumulative translation adjustments, with respect to all foreign operations, should not be affected by the consolidation method. However, if the ultimate parent uses the direct method or the step-by-step method of consolidation, this may affect the amount included in its cumulative translation adjustments with respect to an individual foreign operation. The use of the step-by-step method of consolidation may result in the reclassification to profit or loss of a different amount than that used to determine the effectiveness of the hedge. This difference can be eliminated by determining the amount related to that foreign operation that would have arisen if the direct consolidation method had been used. This adjustment is not required by Technical Pronouncement CPC 02. However, it is an accounting policy choice of the entity that must be followed consistently for all net investments.
(Eliminated).

Transition
19. Technical Pronouncement CPC 23 specifies how the entity should apply a change in accounting policy arising from the initial application of an Interpretation. The entity does not need to meet these requirements in the initial application of this Interpretation. If the entity designated a hedging instrument as a hedge of net investment, but the hedge does not meet the requirements of hedge accounting of this Interpretation, the entity must apply Technical Pronouncement CPC 38 to discontinue that hedge relationship prospectively.

(The direct method of consolidation is the method through which the financial statements of the foreign operation are converted directly into the functional currency of the ultimate parent. The step-by-step method is the consolidation method through which the financial statements of the foreign operation are initially converted into the functional currency of any of the intermediate parents of the group and, subsequently, converted into the functional currency of the ultimate parent - or the presentation currency if different.)

RESOLUTION CVM NO. 142, OF JUNE 15, 2022

Appendix
Application Guide
This Appendix is an integral part of this Interpretation.

AG1. This appendix illustrates the application of the Interpretation using the corporate structure illustrated below. In all cases, the hedge relationships described would pass the effectiveness test in accordance with Technical Pronouncement CPC 38, although this test is not discussed in this appendix. The parent company, considered as the ultimate parent, presents its consolidated financial statements in its functional currency which is the Euro (EUR). Each subsidiary is a wholly-owned subsidiary. The parent's net investment of £ 500 million in subsidiary B (whose functional currency is the British pound (GBP)) includes £ 159 million, equivalent to the net investment of subsidiary B, of US$ 300 million, in subsidiary C (functional currency US dollar, USD). In other words, the net assets of subsidiary B that do not represent investments in subsidiary C are £ 341 million.

Nature of the risk being hedged for which a hedge relationship can be designated (items 10 to 13)

AG2. The parent can hedge its net investment in each of the subsidiaries A, B, and C for the foreign exchange risk between their respective functional currencies (Japanese Yen, British Pound, and US Dollar) and the Euro. In addition, the parent can hedge the foreign exchange risk between the Dollar and the Pound (USD/GBP) of its subsidiaries B and C. In its consolidated statements, subsidiary B can hedge its net investment in subsidiary C against the foreign exchange risk between the functional currency Dollar and British Pound. In the following examples, the risk being hedged is the spot foreign exchange risk because the hedging instruments are not derivatives. If the hedging instruments were forward contracts, the parent could classify the forward foreign exchange risk.

SECURITY AND EXCHANGE COMMISSION OF BRAZIL (CVM) 7 de Setembro 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 – Corporate Financial Center Building, S.404/4th Floor, Brasília/DF – ZIP: 70712-900 – Brazil - Tel.: (61) 3327-2030/2031 www.gov.br/cvm

CVM RESOLUTION NO. 142, OF JUNE 15, 2022

Amount of the hedged item for which a hedge relationship may be designated (items 10 to 13)

AG3. The parent wishes to protect the foreign exchange risk of its investment in subsidiary C.
Assume that subsidiary A has an external loan of USD 300 million. The net assets of subsidiary A at the beginning of the period are ¥ 400,000 million including the resources from the external loan of US$ 300 million.

AG4. The hedged item may be an amount of net assets equal to or less than the carrying amount of the parent's net investment in subsidiary C (US$ 300 million) contained in its consolidated financial statements. In its consolidated financial statements, the parent may designate the external loan of US$ 300 million in subsidiary A as a hedge of the spot EUR/USD exchange rate variation associated with its net investment of US$ 300 million in the net assets of subsidiary C. In this case, the variation in the exchange rate between EUR/USD on the US$ 300 million of external loan of subsidiary A and the variation in the exchange rate between EUR/USD on the US$ 300 million investment in subsidiary C must be included in the accumulated translation adjustments in the consolidated financial statements of the parent, after the application of hedge accounting.

AG5. In the absence of hedge accounting, the total USD/EUR difference on the US$ 300 million of external loan in subsidiary A could be recognized in the consolidated financial statements of the parent as follows:

variation in the USD/JPY exchange rate, translated into Euro, in profit or loss; and

PARENT Functional currency EUR
SUBSIDIARY A Functional currency JPY
SUBSIDIARY B Functional currency GBP
SUBSIDIARY C Functional currency USD
¥ 400,000 million £ 500 million
US$ 300 million
(£ 159 million equivalent)

CVM RESOLUTION NO. 142, OF JUNE 15, 2022

variation in the JPY/EUR exchange rate in other comprehensive income.

Instead of the designation in item AG4, in its consolidated financial statements, the parent may designate the US$ 300 million of external loan in subsidiary A as a hedge of the spot GBP/USD exchange rate variation risk between subsidiary C and subsidiary B. In this case, the total USD/EUR difference on the US$ 300 million of external financing in subsidiary A would be recognized in the consolidated financial statements as follows:

the variation of the spot GBP/USD exchange rate in the accumulated translation adjustments related to subsidiary C;
the variation in the spot GBP/JPY exchange rate, translated into euro in profit or loss; and
the variation in the JPY/EUR exchange rate in accumulated translation adjustments.

AG6. The parent cannot designate the US$ 300 million of external loans in subsidiary A as a hedge of the EUR/USD exchange rate variation risk and the spot GBP/USD exchange rate variation risk, together, in its consolidated financial statements. A single [instrument] can only protect once the same identified risk.

Subsidiary B cannot apply hedge accounting in its consolidated statements because the hedging instrument is held outside the group containing subsidiaries B and C.

Where in the group can the hedging instrument be held (items 14 and 15)?

AG7. As mentioned in item AG5, the total value variation relative to the foreign exchange risk of the US$ 300 million of external loans in subsidiary A would be accounted for in profit or loss (USD/JPY) and in accumulated translation adjustments (EUR/JPY) in the consolidated financial statements of the parent in the absence of hedge accounting. Both amounts are included in order to assess the effectiveness of the hedge designated in item AG4 because the value changes of the hedging instrument and the hedged item must be calculated with reference to the parent's functional currency Euro against the subsidiary C's functional currency dollar, according to hedge documentation. The consolidation method (direct method or step-by-step method) does not affect the verification of hedge effectiveness.

Amounts reclassified to profit or loss upon disposal of foreign operation (items 16 and 17)

AG8. When subsidiary C is disposed of, the amounts reclassified to profit or loss in the consolidated financial statements of the parent from its accumulated translation adjustments are:

(a) with respect to the US$ 300 million of external loans of subsidiary A, the amount that CPC 38 requires to be identified refers to the total value change relative to the exchange rate risk that was recognized in accumulated translation adjustments as the effective part of the hedge; and

(b) with respect to the US$ 300 million of net investments in subsidiary C, the amount determined by the entity's consolidation method. If the parent uses the direct method, its accumulated translation adjustments, with respect to subsidiary C, will be determined directly by the EUR/USD exchange rate. If the parent uses the step-by-step method, its accumulated translation adjustments, with respect to subsidiary C, will be determined by the accumulated translation adjustments recognized as other comprehensive income in subsidiary B, reflecting the GBP/USD exchange rate converted to the parent's functional currency by using the EUR/GBP exchange rate. The parent's use of the step-by-step consolidation method in previous periods does not prevent the entity from determining the amount of accumulated translation adjustments that will be reclassified when it disposes of subsidiary C as the amount that would be recognized if it had always used the direct method, depending on its accounting policy.

Hedge of more than one foreign operation (items 11, 13 and 15)

AG9. The following examples guide that, in the consolidated financial statements of the parent, the risk that can be protected is always the risk between its functional currency (euro) and the functional currencies of subsidiaries B and C. Regardless of how the hedges are designated, the maximum amounts that can be effective hedges to be included in the accumulated translation adjustments in the parent's consolidated statements, when both operations are protected, are US$ 300 million for the EUR/USD risk and £ 341 million for the EUR/GBP risk.

CVM RESOLUTION NO. 142, OF JUNE 15, 2022

Other value changes due to changes in exchange rates must be included in the parent's consolidated profit or loss. Obviously, it is possible for the parent to designate US$ 300 million only for changes in the spot USD/GBP exchange rate or £ 500 million only for changes in the spot GBP/EUR exchange rate.

Parent holds hedging instruments in USD and GBP

AG10. The parent may wish to protect the foreign exchange variation risk regarding its net investment in subsidiary B as well as that related to subsidiary C. It is assumed that the parent holds suitable hedging instruments denominated in US dollars and British pounds that could be designated as hedges of its net investments in subsidiaries B and C. The designations that the parent can make in its consolidated financial statements include, for example:

(a) a US$ 300 million hedging instrument designated as a hedge of the US$ 300 million net investment in subsidiary C with the risk being the exposure to spot foreign exchange risk (EUR/USD) between the parent and subsidiary C and up to £ 341 million of the net investment in subsidiary B with the risk being the exposure to spot foreign exchange risk (EUR/GBP) between the parent and subsidiary B;

(b) a US$ 300 million hedging instrument designated as a hedge of the US$ 300 million net investment in subsidiary C with the risk being the spot foreign exchange exposure (GBP/USD) between subsidiary B and subsidiary C and up to £ 500 million of the investment in subsidiary B with risk being the spot foreign exchange exposure (EUR/GBP) between the parent and subsidiary B.

AG11. The EUR/USD risk of the parent's net investment in subsidiary C is a different risk from the EUR/GBP risk of the parent's net investment in subsidiary B. However, in the case described in item AG10(a), by its designation of the USD hedging instrument it holds, the parent has already fully protected the EUR/USD risk of its net investment in subsidiary C. If the parent also designated a GBP instrument it holds as a hedge of its £ 500 million net investment in subsidiary B, the £ 159 million of this investment, representing the GBP equivalent of its USD investment in subsidiary C, would be protected twice for the GBP/EUR risk in the consolidated financial statements of the parent.

AG12. In the case described in item AG10(b) if the parent designates the risk being protected as the spot foreign exchange exposure (GBP/USD) between subsidiary B and subsidiary C, only part of the GBP/USD variation in the value of its US$ 300 million hedging instrument should be included in the accumulated translation adjustments of the parent related to subsidiary C. The remainder of the variation (equivalent to the GBP/EUR change on the £ 159 million) should be included in the parent's consolidated profit or loss, as in item AG5. As the designation of the USD/GBP risk between subsidiaries B and C does not include the GBP/EUR risk, the parent is able to designate up to £ 500 million if its net investment in subsidiary B with the risk being the spot foreign exchange exposure (GBP/EUR) between the parent and subsidiary B.

Subsidiary B holds hedging instrument in USD

AG13. It is assumed that subsidiary B has US$ 300 million of debt with third parties, the resources obtained from which were transferred to the parent through a loan denominated in British pounds. Since its assets and liabilities increased by £ 159 million, the net assets of subsidiary B did not change. Subsidiary B could designate its external borrowing as a hedge of the GBP/USD risk of its net investment in subsidiary C in its consolidated financial statements. The parent could maintain the designation made by subsidiary B of this hedging instrument as a hedge of US$ 300 million of net investment in subsidiary C for the GBP/USD risk (see item 13) and the parent could designate the GBP hedging instrument it holds as a hedge of the total investment of £ 500 million in subsidiary B. The first hedge designated by subsidiary B could be verified with reference to the functional currency of subsidiary B (British pounds) and the second hedge, designated by the parent, could be verified with reference to the functional currency of the parent (euro). In this case, only the GBP/USD risk of the parent's net investment in subsidiary C was protected in the consolidated financial statements by the USD hedging instrument and not the total EUR/USD risk. Thus, the total EUR/GBP risk of the parent's £ 500 million net investment in subsidiary B can be protected in the consolidated financial statements of the parent.

AG14. However, the recognition of the £ 159 million loan from the parent to subsidiary B must also be considered. If the loan is not considered as part of its net investment in subsidiary B because it does not satisfy the conditions described in Pronunciamento Técnico CPC 2, item 15, the GBP/EUR exchange difference, arising from its conversion, should be included in the parent's consolidated profit or loss. If the £ 159 million loan from the parent to subsidiary B is considered as part of the parent's net investment, this net investment would be only £ 341 million and the amount that the parent could designate as the hedged item for the GBP/EUR risk would be reduced, consequently, from £ 500 million to £ 341 million.

AG15. If the parent reversed the hedge relationship designated by subsidiary B, the parent could designate the US$ 300 million external borrowing held in subsidiary B as a hedge of its US$ 300 million net investment in subsidiary C for the EUR/USD risk and designate the GBP hedging instrument it holds only as a hedge of up to £ 341 million of the net investment in subsidiary B. In this case, the effectiveness of both hedges could be calculated with reference to the functional currency of the parent (Euro). Consequently, the value change relative to the USD/GBP variation of the external borrowing held by subsidiary B and the value change (GBP/EUR) of the parent's loan with subsidiary B (equivalent to USD/EUR in total) should be included in the accumulated translation adjustments in the consolidated financial statements of the parent. Since the parent has already fully protected the EUR/USD risk of its net investment in subsidiary C, it can protect only up to £ 341 million of the EUR/GBP risk of its investment in subsidiary B.

CVM Resolution No. 142 of June 15, 2022

Lineage: In force