Chapter IV Securities Trading Policy
Section I Securities Holding
4.1- The persons mentioned in items (ii), (iii) and (iv) of item 1.2 of Chapter I of these Policies must disclose if they are holders of securities issued by Ecorodovias, its publicly-held subsidiaries or holding companies, whether in (i) their own name, by (ii) their spouse, from whom they are not legally separated, by their (iii) companion, by (iv) any dependent included in their annual income tax declaration or by (v) corporations directly or indirectly controlled by the persons referred to in items (ii), (iii) and (iv) of item 1.2 of Chapter I of these Policies, as well as any changes in their holding of such securities.
4.2- This notice should be submitted to the Investor Relations Officer, who will, as circumstances require, submit it to the CVM, Bovespa and, if necessary, to the Stock Exchanges and the over-the-counter securities market, as indicated in the form included as Annex II of this Policy.
4.3- This notice must be made by the respective securities holders:
a) immediately upon taking a job position, and
b) within 10 days after the end of the month in which there is any change in the securities held, indicating the balance for the period.
4.4- The persons mentioned in item 1.2 of Chapter I of these Policies, acting alone or together, or representing a common interest, must, through the Investor Relations Officer, disclose to the CVM, Bovespa, to the Stock Exchanges and the over-the-counter securities market, as modeled on the form included as Annex III of this Policy as well as through publication in the widely circulated newspapers habitually used by the Company, any information regarding the acquisition or sale of Significant Shareholding Stake, immediately upon acquiring such stake, as well as any time when the stake rises by 5% (five percent)
4.5- The persons mentioned in item 1.2 of Chapter I of these Policies must report, through the Investor Relations Officer, the sale or cancellation of shares, or of rights to them, any time in which the sale or cancellation of these corresponds, directly or indirectly, to 5% or more of the shares making up Ecorodovias’ capital stock.
4.6- Related Persons, for restrictions and periods of non-trading treated in this section, are persons that have indicated adhesion to these Policies by signing the Terms of Adhesion referred to in item 1.3 of Chapter I.
4.7- Prior to public disclosure of any Relevant Act or Fact, in accordance with the terms of the Information Use and Disclosure of Relevant Act or Fact Policy of Chapter III, the provision of securities investment advice or assistance by Related Persons having knowledge of the Relevant Act or Fact and/or the date of its disclosure is prohibited.
4.8- Trades made directly or indirectly by Related Persons are included in the restrictions mentioned in item 4.7 above., except those made by investment funds in which those Related Persons are quota holders, as long as they are not exclusive investment funds or investment funds whose administrator or portfolio manager’s trading decisions are directly influenced by Related Persons.
4.9- Related Persons must ensure that those with whom they maintain business or professional relationships or relationships of confidence do not trade securities when they have access to undisclosed Relevant Acts or Facts. Therefore, Related Persons should make every effort to make sure that persons with access to Relevant Acts and Facts sign the Terms of Adhesion.
4.10- Trading of securities issued by the Company by Related Persons will be prohibited during any period of acquisition or sale of Company-issued shares, or in the event that a contract to transfer shareholding control of the company has been signed, or if an option or mandate for that purpose has been given, or if there is any intention to promote incorporation, partial or total split-off, merger, corporate transformation or restructuring of the Company.
4.11- The restrictions on trading securities must be observed by Related Persons until the disclosure of the Relevant Act or Fact to the public. However, such restrictions will be maintained, even after the disclosure of the Relevant Act or Fact, if potential trading in securities may interfere with the act or fact associated with the Relevant Act or Fact, to the detriment of the Company or its shareholders,
4.12- Even after public disclosure, the Relevant Act or Fact should continue to be treated as if it had not been disclosed until a reasonable period of time has passed in which the market has had time to receive and understand the Relevant Act or Fact.
4.13- Related Persons must abstain from making any securities trades (i) during the 15 (fifteen) day period that precedes the disclosure of quarterly (ITR) and annual (DFP and IAN) information required by the CVM; (ii) between the date of resolution of the competent body to increase capital stock, pay dividends and interest on capital, and the publication of the respective announcements.
4.14- Related Persons that leave management positions with the Company prior to the disclosure of a Relevant Act or Fact that originated during their term may not trade securities until (i) the end of the six-month period following their departure; or (ii) the public disclosure of the Relevant Act or Fact.