Banco do Brasil S A : PLDFTP-C_inglês

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BANCO DO BRASIL

Specific Policy to Prevent and Combat Money Laundering, the

Financing of Terrorism, Financing of the Proliferation of Weapons of

Mass Destruction and Corruption

1. Area responsible for the matter: Institutional Security Unit - USI.
2. Scope: This Policy guides the behavior of Banco do Brasil. Entities Related to Banco do Brasil (ELBB) are expected to define their directions based on these guidelines, considering the specific needs and the legal and regulatory aspects applicable to them.
3. Regulation: CMN Resolution 4557/2017.
4. Review frequency: at least annually, or extraordinarily, at any time.
5. Introduction: This policy guides Banco do Brasil's actions with respect to preventing and combating money laundering, the financing of terrorism, financing of the proliferation of weapons of mass destruction and corruption, and is part of the list of policies associated with operational risk management at Banco do Brasil.
6. For the purposes of this Policy, we consider the following definitions:

1. Money laundering: consists of concealing or disguising the nature, origin, location, disposition, movement or ownership of assets, rights or amounts arising directly or indirectly from a criminal offense.
2. Financing of terrorism: consists of the allocation of funds to terrorists, terrorist organizations or terrorist acts. Funds can be sourced legally or illegally.
3. Corruption: according to Law 12.846/2013, acts qualifying as corruption are those that are harmful to domestic or foreign public administration, committed by legal entities; that threaten domestic or foreign public assets; against the principles of public administration; or against international commitments assumed by Brazil, as defined below: promising, offering or giving, directly or indirectly, an undue advantage to a public official, or to a person related thereto; demonstrably financing, funding, sponsoring or, in any way, subsidizing the practice of the unlawful acts foreseen in the Law; demonstrably using an intermediary individual (known as an orange) or legal entity (known as a front company or shell company) to hide or conceal the real interests or the identity of the beneficiaries of the acts practiced. Regarding bidding processes and contracts: Implies in the frustration or fraud, through adjustment, combination or any other act, of the competitive nature of a public bidding procedure; preventing, disturbing or defrauding the performance of

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any act of a public bidding procedure; removing or seeking to remove a bidder through fraud or offering of an advantage of any kind; defrauding a public bidding process or a contract arising therefrom; fraudulently or irregularly creating a legal entity to participate in a public bidding process or enter into an administrative agreement; fraudulently obtaining undue advantage or benefit from modifications or extensions of agreement entered into with the public administration, without authorization in the law, in the bid invitation notice or in the respective contractual instruments; or manipulating or defrauding the economic-financial balance of agreements entered into with the public administration. Corruption also constitutes of hindering the investigation or inspection activities of public bodies, entities or agents, or intervening in their activities, including in the scope of the regulatory agencies and the inspection bodies of the national financial system.

1. Bribery: an illicit act that consists of inducing someone to perform a certain act in exchange for money, material goods, or other private benefits.
2. Facilitation payment: refers to the payment of small amounts of money or promises of other benefits for the personal benefit of a public official, most often at a low hierarchical level, for the purpose of accelerating a given process. It differs from bribery in that the process in question would be done anyway, but would take longer than desired.
3. Financing of the proliferation of weapons of mass destruction: consists of the direct or indirect provision of funds, by any means, for the purpose of providing financial support, supply, or collection of funds intended for use in the proliferation of weapons of mass destruction. Weapons of mass destruction are defined as devices capable of causing intentional damage on a large scale, such as nuclear, chemical, biological, or toxin weapons.

1. We repudiate and do not tolerate acts of corruption, bribery, extortion, kickbacks, fraud, money laundering, terrorism financing, and any other unlawful practices.
2. We do not authorize any kind of facilitation payment.
3. We prevent money laundering, the financing of terrorism, and corruption practices in doing business in Brazil and abroad, in accordance with the national legislation, with the legislation in force in each country where we operate, and with the legislation of transnational scope.
4. We operate in line with the international commitments assumed by the Brazilian Federal Government with regard to preventing and combating money laundering, the financing of terrorism and corruption, in compliance with the legislation in force.

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1. We encourage and participate in joint actions, within the scope of the National Financial System, to prevent and combat money laundering, the financing of terrorism, and corruption.
2. We adopt procedures in the relationship with public entities, to inhibit the practice of acts of corruption.
3. We adopt practices and controls to prevent and combat money laundering and the financing of terrorism in line with the Wolfsberg Group's principles for correspondent banking.
4. We use parameters established by law for registering transactions and identifying those considered indications of money laundering or terrorism financing, in the development of automated systems for monitoring transactions performed.
5. We use specific parameters for monitoring financial transactions that may be indications of corruption.
6. We keep records related to the procedures of preventing and combating money laundering, the financing of terrorism and corruption in compliance with the legislation in force.
7. We adopt procedures in the development of products and services to inhibit their use for unlawful practices related to money laundering, the financing of terrorism, and corruption.
8. We conduct internal risk assessment to identify and measure the risk of using our products and services for money laundering, the financing of terrorism, financing the proliferation of weapons of mass destruction and corruption, considering the risk profile of: customers; Banco do Brasil, including the business model and the geographical area of operation; operations, transactions, products and services, covering all distribution channels and the use of new technologies; and the activities performed by employees, partner institutions and suppliers.
9. We do not accept the movement of funds through anonymous current accounts or those linked to fictitious holders.
10. In analyzing the operations, we assess the instruments used, the way they are performed, the frequency, the parties and amounts involved, the customer's financial capacity and economic activity, and any indication of irregularity or illegality involving the customer or its operations, for the purpose of detecting signs of money laundering, the financing of terrorism, or corruption.
11. We condition the initiation and maintenance of business relationships with customers who are Politically Exposed Persons on the authorization of senior management.

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1. We adopt due diligence procedures to mitigate the risks of money laundering, the financing of terrorism and corruption, according to the activity, jurisdiction and agents involved.
2. We adopt restrictive measures regarding doing business and maintaining business relationships with customers, suppliers and partners when circumstances reveal evidence of involvement in acts related to money laundering, the financing of terrorism or corruption, in compliance with the legislation in force.
3. We condition the maintenance of correspondence relations with other banks to the existence, in the scope of those banks, of mechanisms for the prevention of money laundering and the financing of terrorism, and contracting to the inexistence of an administrative or judicial conviction in the sanctions of Law 12.846, dated 08/01/2013.
4. When maintaining business relationships with partners and suppliers, we consider the existence, within the scope of these third parties, of mechanisms to prevent corruption.
5. We have adopted procedures to monitor the process of preventing and combating money laundering and the financing of terrorism by senior management, ensuring their commitment to the effectiveness and continuous improvement of the policy, procedures and internal controls required.
6. We maintain specific channels for receiving complaints, including anonymous ones.
7. We investigate indications and accusations of acts of corruption practiced by direct agents or third parties, for the benefit or interest of the Bank, against the public administration, in accordance with the legislation in force.
8. We investigate indications and accusations of acts of corruption practiced by direct agents or third parties, against the assets, principles and commitments undertaken by the Bank, in accordance with the legislation in force.
9. We conduct, in a confidential manner, the registration, analysis and communication processes of financial operations with signs of money laundering or the financing of terrorism to the competent authorities, including in relation to customers, as well as the processes related to the investigation of suspected acts of corruption.
10. We preserve the identity of the whistleblowers as anonymous.
11. We repudiate any acts of reprisal or retaliation against good-faith whistleblowers who choose to identify themselves.
12. We adopt measures to protect good-faith whistleblowing employees in relation to facts arising from their reports.

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1. We notify the competent authorities regarding operations or proposed operations that, in the form of the current legislation, characterize signs of money laundering, the financing of terrorism, and corruption.
2. We collaborate with the public authorities in investigations related to acts harmful to the public administration that result from our activities, in compliance with the legislation in force.
3. We adopt criteria for hiring and employee conduct, with a focus on preventing and combating money laundering, the financing of terrorism, and corruption.
4. We request that our suppliers adopt criteria for hiring and monitoring employee conduct, with a focus on preventing and combating money laundering and the financing of terrorism and corruption.
5. We maintain a specific employee training program on preventing and combating money laundering, the financing of terrorism, and corruption.
6. We request that the bank correspondents who provide services to the Bank carry out training in preventing and combating money laundering and the financing of terrorism.
7. We submit the process of preventing and combating money laundering and the financing of terrorism, financing of the proliferation of weapons of mass destruction, and corruption to an independent auditing company on an annual basis.

Last review date: 12/08/2022.

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