General Provisions

The banking activities are based on existing mutual confidence and on the general public confidence. Therefore, it is essential that every employee of Banco ABC BRASIL S.A. (referred to as the “Bank”) and its affiliates (ABC Group) behave in compliance with the highest and appropriate standards of conduct.

This set of Rules of Conduct describes the expected basic standards needed in our behavior both inside and outside the Bank.

Each member of ABC Group’s staff must receive a copy of this Policy and each employee, within his/her area of responsibility, is required to ensure its compliance so that the values and integrity of ABC Group are maintained.

The Policy must be read together with the Employees’ Internal Regulations, their employment agreement and all and any laws applicable to each operational unit.

In case local laws or standards determine rules of conduct stricter than those set forth herein, such local laws or rules must be observed and given priority.

Thus, stricter local laws or standards shall prevail wherever not conflicting with this Policy.

Clients expect that ABC Group demonstrates a high standard of legality and ethical values. Each employee undertakes the obligation to comply with either expressed content or implied spirit of this Policy and legal requirements.

As an employee or officer of ABC Group, you must guide yourself by the principles set forth in this Policy.

In case any officer or employee has any questions about the concepts and criteria set forth herein, he/she must seek advice from his/her immediate superior, who will consult the Human Resources Department, if necessary.