Joint Circular CVM/SMI/SIN No. 01/2024

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
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 Joint Circular No. 1/2024/CVM/SMI/SIN Rio de Janeiro, August 30, 2024. To the directors of entities authorized to act as members of the distribution system, responsible for complying with the rules established by CVM Resolution No. 30, of May 11, 2021. Subject: Interpretation of Article 4 of CVM Resolution 30/2021. Dear Sirs, This Joint Circular aims to clarify the interpretation of the Department of Market and Intermediary Relations (SMI) and the Department of Institutional Investor Supervision (SIN) for situations in which the aforementioned entities (“institutions”) register a new client and, in accordance with Article 4 of CVM Resolution No. 30/2021, choose to classify them into risk profile categories without the client answering a specific questionnaire. When these circumstances are present, it is necessary to observe that:
a) the client must necessarily be classified in the category of lowest propensity to assume risk, as established by the institution's internal rules and procedures; b) recommendations of products and services to the client must be limited to those appropriate for the category in question; c) the classification in the category of lowest propensity to assume risk must be communicated to the client upon registration, accompanied by the information that access to other products and services available to other categories depends on the prior and complete application, by the institution, of the provisions of CVM Resolution No. 30/2021 for the determination of the profile, especially its Articles 3 and 4;

Joint Circular 4 (2122165) SEI 19957.013834/2024-90 / pg. 1

d) the client's request to carry out operations with securities that are not appropriate for their profile constitutes sufficient motivation for institutions to adopt the necessary measures for the complete application of the aforementioned Articles 3 and 4; e) the obligations provided for in Article 7, I (alert regarding the absence, outdatedness or inadequacy of the profile) and II (express declaration of the client) of CVM Resolution No. 30/2021 are limited to situations where the client orders the execution of operations, on their own initiative. It is not permissible for such measures to be used by the institution as a pretext for carrying out operations after prior recommendation of products or services not appropriate for the client's profile. Such practice is absolutely prohibited in the cases described and considered a serious offense under Article 16 of the regulation. In assessing compliance with CVM Resolution No. 30/2021, the directors responsible for observing the regulation must pay special attention to the procedures used by administrators, employees and agents of the institution, with regard to the registration, maintenance and contact with clients who fall under the situation of evaluation and classification into risk profile categories without filling out a specific questionnaire. Among other measures that the institution considers pertinent, in periodic monitoring, emphasis should be given to situations that signal the need for differentiated treatment and which may even culminate in the requirement for complete filling out of the investor's profile. Such situations may include (i) occurrences of significant resource contributions by the client, (ii) obtaining atypical financial results; and (iii) abusive use of the declaration provided for in Article 7, II, which may point to an attempt to facilitate the recommendation of products or services not appropriate for the client's profile. The methodologies and differentiated monitoring applicable to situations such as those described above must be provided for and detailed in the institution's policies and regulations, especially in the AML/CFT policy, and be part of the internal risk assessment and internal rules, procedures and controls. Finally, it is worth noting that the above interpretation does not prejudice the application of the regulations already issued by self-regulatory bodies regarding the duty to verify the appropriateness of products, services and operations to the client's profile. Sincerely, ANDRÉ FRANCISCO LUIZ DE ALENCAR PASSARO Superintendent of Market and Intermediary Relations MARCO ANTONIO VELLOSO DE SOUSA Superintendent of Institutional Investor Supervision Joint Circular 4 (2122165) SEI 19957.013834/2024-90 / pg. 2

Document electronically signed by Andre Francisco Luiz de Alencar Passaro, Superintendent, on 08/29/2024, at 15:39, based on
Article 6 of Decree No. 8.539, of October 8, 2015.
Document electronically signed by Marco Antonio Velloso de Sousa, Superintendent, on 08/29/2024, at 20:19, based on Article 6 of Decree No. 8.539, of October 8, 2015.
The authenticity of the document can be verified on the site https://sei.cvm.gov.br/conferir_autenticidade, by entering the verification code 2122165 and the CRC code 026BE7F2.
The authenticity of this document can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2122165 and the "CRC Code" 026BE7F2.
Reference: Process No. 19957.013834/2024-90 SEI Document No. 2122165 Joint Circular 4 (2122165) SEI 19957.013834/2024-90 / pg. 3