The Bound Persons shall keep the confidentiality about the Material Information, which has not been disclosed yet, to which they have access in view of their position or office held, until such Material Information is disclosed to the public, as well as ensure that subordinates and third parties of their trust do the same.

  • Even after its disclosure to the public, the Material Information shall be deemed as not having been disclosed until reasonable time has elapsed so that market participants may have received and processed such Material Information.
  • The Bound Persons shall not discuss Material Information in public locations. Likewise, the Bound Persons shall only discuss issues related to the Material Information with those who need to become aware of such Material Information.
  • Any infringement to this Disclosure Policy verified by Bound Persons shall be immediately communicated to the Bank by the Investor Relations Officer or person appointed by him or her.
  • Should any Bound Person verify that a Material Information not yet disclosed to the public was known by persons different from (i) those who originally became aware thereof; and/or (ii) decided to maintain the Material Information under confidentiality, or also an atypical fluctuation occurred in securities quotation, price or quantity traded, such facts shall be immediately communicated to the Bank through the Investor Relations Officer or person designated by him or her.