Rules, Procedures, and Internal Controls Manual BRAM Bradesco Asset Management

Rules, Procedures, and Internal Controls Manual BRAM Bradesco Asset Management MP_8231_0070 01 27/06/2016 1 / 12

Table of contents 1. OBJECTIVE... Erro! Indicador não definido. 2. DEFINITIONS... Erro! Indicador não definido. 3. SCOPE... Erro! Indicador não definido. 4. REVIEW... Erro! Indicador não definido. 5. INTERNAL CONTROLS SYSTEM... Erro! Indicador não definido. 6. CONFLICT OF INTERESTS... Erro! Indicador não definido. 7. RULES FOR THE TREATMENT OF SOFT DOLLARS... Erro! Indicador não definido. 8. RULES OF SELECTION, RECRUITMENT AND SUPERVISION OF SERVICE PROVIDERS Erro! Indicador não definido. 9. PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM... Erro! Indicador não definido. 10. BUSINESS CONTINUITY PLAN... Erro! Indicador não definido. 11. CONFIDENTIALITY RULES... Erro! Indicador não definido. 12. INFORMATION SECURITY SYSTEMS... Erro! Indicador não definido. 12.1. General Rules for Information Security... 10 13. TRAINING PROGRAM... Erro! Indicador não definido. 13.1. Learning path... 11 13.2. TreiNet... 11 14. PENALTY... Erro! Indicador não definido. MP_8231_0070 01 27/06/2016 2 / 12

1. OBJECTIVE Establish guidelines that guarantee, through appropriate Internal Controls, the continued compliance with the standards, policies and existing regulations relating to investments, the activity of portfolio and securities management and ethical and professional standards. This document aims to establish the procedures adopted by the organizational structure in place at Bradesco Asset Management (BRAM). 2. DEFINITIONS For the purposes of this Manual, the words and expressions listed below shall have the following meanings, when began with capital letters, in the singular or in the plural form: (i) Manager of Securities Portfolios: conforming to ICVM 558, an individual or corporation, as applicable, that performs in a professional manner and is duly accredited by the Securities and Exchange Commission ("CVM") the activities related, directly or indirectly, to the operation, maintenance and management of a portfolio of securities, including the application of funds in the securities market on behalf of an investor; (ii) BRAM: Bradesco Asset Management S.A. DTVM., hereinafter referred to as a company, a duly authorized investment manager to manage portfolios of securities by the CVM; (iii) Conflict of Interest: a set of conditions in which professional judgment concerning a primary interest tends to be unduly influenced by a secondary interest; (iv) Internal Control: a set of regulatory activities and actions formally established by the Organization, in order to reduce financial losses or damage to the institution s reputation, increase the quality of the accounting, financial and management information, and safeguard compliance with laws, regulations, codes of conduct and self-regulation; (v) Managed Portfolio: portfolios managed by BRAM this is the composition of a portfolio of investments by an asset manager formally hired directly by the investor, for selection, acquisition, disposal and management of the risks inherent in such investments, as described in the service contract; MP_8231_0070 01 27/06/2016 3 / 12

(vi) Funds: mutual funds under the management of BRAM a collective of resources in the form of open, closed or pooled funds, intended for investment in financial assets, securities, and/or other goods as provided for in the applicable legislation; and (vii) Related Parties: directors, employees, interns, outsourced employees and operators involved in the business activities of BRAM. 3. SCOPE This Manual applies to all Related Persons, especially to those who, through their duties, could have or do have access to confidential or privileged information, and must comply with the procedures described. This Manual complements the Bradesco Organization s Code of Ethical Conduct, and the Bradesco Organization s Code of Ethical Conduct of Financial and Capital Market these are also required knowledge for all Managers, Employees, and Collaborators. 4. REVIEW This manual should be reviewed, at least once a year and/or at any time, according to relevance, to ensure its suitability for the process, and requires the generation of a new revision. 5. INTERNAL CONTROLS SYSTEM The provisions of this chapter are in line with the Internal Controls and Compliance Policy of the Bradesco Organization. The structure of Internal Controls adopts mechanisms for evaluation and reporting of the control environment, in order to provide reasonable assurance regarding the proper conduct of business and achievement of specified objectives, in accordance with laws and external regulations, policies, standards, and procedures, codes of conduct and self-regulation. The methodology of internal controls used by the Organization was developed based on aspects of business, information technology, and governance. It consists of a cycle divided into eight phases, which provide systematic monitoring of internal controls. For the implementation phase, there is the involvement of MP_8231_0070 01 27/06/2016 4 / 12

Departmental managers (first line of defense) and the area of Internal Controls (second line of defense) as well as work carried out by Internal Audit (third line of defense) evaluating the effectiveness of the internal controls system. In this context, the Department of Integrated Risk Control ( DCIR ) is responsible for exercising and subsidizing the risk management and internal control processes. Its functions are performed by professionals with the exclusive role of advising the Organization in the understanding and application of regulations, standards, and procedures related to internal controls, as well as supporting the implementation of methodologies, concepts, criteria and tools aimed at management of activities, with descriptions of all tests carried out. The management of internal control adopted by the Organization is supported by internationally recognized structures (ERM - Enterprise Risk Management COSO (2013) Entity Level Control (ELC) - PCAOB and Control Objectives for Information and Related Technology (COBIT) and meets the recommendations and requirements of local and foreign regulators. 1 The DCIR has a structure of Internal Control Agents ("ICAs") to advise, assist and monitor the implementation and enforcement of regulations, policies, standards and procedures, and in the evaluation of the implementation of internal controls to mitigate operational risks within BRAM. The Director Responsible for Internal Control must support managers in identifying, assessing and responding to risk, making sure the control is performed regularly and effectively, and to recommend, where necessary, corrective action or an action plan to ensure acceptable levels of risk in the processes of management of securities portfolios. 6. CONFLICT OF INTERESTS BRAM has a standard that establishes the guidelines for the identification, management, and mitigation of potential or actual conflicts of interest that may exist during the performance of third-party asset management for the purpose of preserving and protecting the client interests and ensure independence in management. 1 Source: External Audit Report. MP_8231_0070 01 27/06/2016 5 / 12

Additionally, BRAM has established rules and procedures for the physical and computing segregation of all activities carried out at the company. 7. RULES FOR THE TREATMENT OF SOFT DOLLARS For the handling of the receipt of gifts and benefits (soft commissions) BRAM uses the Internal Regulations of the Bradesco Organization 2 and the Code of Conduct and Ethics of the Bradesco Organization 3 as guidelines, which prohibits to accept, obtain, fund, grant, pay, promise, sponsor or authorize, directly or indirectly, any benefit, monetary or not, in any manner whatsoever, in favor of the person or anyone that may represent an improper relationship. 8. RULES OF SELECTION, RECRUITMENT AND SUPERVISION OF SERVICE PROVIDERS In the case of managed portfolio, CVM Instruction 558 authorizes contracting with third parties, duly authorized, and where appropriate, authorized in the exercise of their respective activities for the provision of additional services to portfolio and securities management. In hiring service providers, the Outsourced Services Procurement and Management Policy and Procurement Policy of Bradesco Organization should be observed. In addition, to the organizational policies and procedures, BRAM uses criteria defined in internal procedures for selecting, contracting and supervision of service providers through: The process of "Due Diligence": that is based on a previous analysis, in which the service provider must allow access to information, documents and, if necessary, conducting a visit, in order to verify that the corporate structure and operation of the service provider is compatible with the exercise of activities for which they are to be hired; Evaluation and formal approval in committees; and Monitoring with semiannual reviews. 2 Normative System Number 01.033 Version: 02 Updated: 12/03/2015 3 Normative System Number 01.002 Version: 04 Updated: 08/07/2015 MP_8231_0070 01 27/06/2016 6 / 12

9. PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM The Bradesco Organization considers Prevention as part of its institutional commitment and responsibility to society. In light of this, it has policies, standards, and procedures aligned with ethical principles reproduced in its codes of conduct, and invests in training its managers and employees and Related Parties, to observe and comply with the provisions of the Customer Registration Information Policy 4 ; Know Your Customer Policy 5 ; Know Your Administration and Employee Policy 6 and Know Your Customer Normative 7. To be observed and enforced among the practices 8, we quote: a) The achievement or maintenance of a relationship with a client that should always be guided from the perspective of transparency and fairness of activities within the concept of "Know Your Customer", not only for commercial and/or for-profit interest that this client can provide in their relationship with the Bradesco Organization; b) Client data registration should be accurate, complete, updated, timely and thoroughly analyzed, ensuring its reliability and consistency, creating an understand their activities, source(s) of income and assets, average invoices, in addition to economic and financial profiles; c) In the case of corporate clients, the registration information should cover individuals authorized to represent them as well as its controllers. When there is participation of a corporation in the capital of the client, this should also be identified, including their representatives until it reaches an individual characterized as the final beneficiary; d) It should be taken into account at the beginning or maintenance of a relationship involving a Politically Exposed Person PEP, domestic or foreign, their families and/or related persons, that there are specific procedures in order to commence a relationship for the establishment of permanent business or to continue an existing relationship, with the enhanced monitoring of 4 Normative System Number 01.030 Version: 04 Updated: 01/26/2016 5 Normative System Number 01.018 Version: 05 Updated: 01/26/2016 6 Normative System Number 01.019 Version: 06 Updated: 01/26/2016 7 Normative System Number 01.759 Version: 01 Updated: 03/02/2016 8 Normative System Number 01.759 Version: 01 Updated: 03/02/2016 MP_8231_0070 01 27/06/2016 7 / 12

transactions and movements of these clients, as per the Politically Exposed Persons Corporate Standard - Account Opening and Maintenance 9. Every precaution should be taken for the timely identification of clients, investors, savers and those purchasing goods and/or services, domestic or foreign, maintaining full knowledge of transactions carried out, acting in this was to prevent operations and/or situations which exhibit evidence of being directly or indirectly related to any criminal infraction. When this refers to the Liabilities of the Funds under Management of BRAM, information on movements of shareholders (account holders and non-account holders) are centralized in an internal system, making it possible to identify the transactions carried out. For Assets, BRAM also considers issues of the Prevention of Money Laundering when making investment decisions to preserve the financial return of the managed assets, as well as in the care of their clients through products tailored to the demands and needs of each audience. Relying on methodologies, public surveys, and visits to invested companies, reports are generated by BRAM s analysis team, which are considered in the recommendations of buying and selling stocks, influencing the formation of portfolios, also used in support for investment decisions. In the case of the identification of suspected cases, these are deliberated upon at BRAM s Committee for Prevention and Money Laundering and Financing of terrorism. Thus, as for operations whose issuer or counterparty is involved with suspected money laundering or terrorist financing, a decision is made if the assets will remain invested or not. 10. BUSINESS CONTINUITY PLAN Taking the Continuity Management Policy of the Bradesco Organization as a guideline, and in line with the Business Continuity Management Standard 10, BRAM s Business Continuity Plan, aims to act in a planned and organized way before the occurrence of incidents, preserving the continuity of the areas of business considered as critical. 9 Normative System Number 01.757 Version: 01 Updated: 03/02/2016 10 Normative System Number 01.017 Version: 02 Updated: 01/02/2016 MP_8231_0070 01 27/06/2016 8 / 12

Employees are directed to the Business Continuity Site, which is fully operational, so that in the event of an incident, there will be no interruption of management and controls. 11. CONFIDENTIALITY RULES For the good and faithful performance of BRAM s activities, it is necessary that employees have access to confidential information, normally understood as all information disclosed that is not public, regardless of the medium used, whether written, visual, physical, electronic (Confidential Information), to perform their duties is up to all Related Parties to commit themselves their successors to secrecy and not using Confidential to gain personal advantage. The Code of Conduct and Ethics of the Bradesco Organization 11 considers privileged information that which relates to acts or facts not disclosed to regulators, Stock Exchanges or other similar entities and, simultaneously, to shareholders and investors in general through distribution and publication by media outlets. The Code of Ethical Conduct for Financial and Capital Market Professionals of the Bradesco Organization 12 provides duties and rules on the confidentiality and protection of information assets, and on the handling of insider information, and Related Parties to its observance. 12. INFORMATION SECURITY SYSTEMS The Information Security Corporate Policy of the Bradesco Organization is the guideline for this chapter. Information security consists of a set of controls, including policies, processes, organizational structures, rules, and safety procedures. Its objective is the protection of client and company information, in terms of confidentiality, integrity and availability 13. Below is an illustration of information security cycle: 11 Available at: www.bradecoasset.com.br <Governance> 12 Available at: www.bradecoasset.com.br <Governance> 13 http://www.bradescoseguranca.com.br (accessed in June/2016). MP_8231_0070 01 27/06/2016 9 / 12

http://www.bradescoseguranca.com.br/html/seguranca_corporativa/pf/seguranca-da-informacao/processos.shtm Accessed in June/2016 12.1. General rules for information security 14 a) All of the Organizations equipment must be checked by Security and Monitoring Corporate Solutions; b) There should be restricted access to content on the Internet that does not comply with business activities and/or that which violate the ethical and legal principles that guide the Organization's activities; c) There must be technological solutions for network monitoring, with the aim of protecting sensitive information in accordance with pre-established rules; d) Changes in operating systems and other equipment settings of the Organization should only be carried out by the responsible technical area; e) Basic Corporate Profiles should be developed, evaluated and approved before they become official; f) Record obtained from monitoring can be used as evidence to show a violation of the Policy and Information Security Corporate Standards, which may serve as evidence in administrative and/or legal processes; g) The documentation of the specific access permits and/or justifications must be retained for verification; h) Any exceptions to the Corporate Profiles being monitored by Corporate Solutions should be documented and authorized, with an understanding of the risks involved; i) The management/control of exception authorizations should be configured with basic settings; 14 Normative System Number 05.251 Version: 06 Updated: 07/10/2016 MP_8231_0070 01 27/06/2016 10 / 12

j) In the event of information security incident, the Office of Inspector General shall be informed; 13. TRAINING PROGRAM This chapter is in line with the Strategic Statements for the Management of Human Resources of the Bradesco Organization, and with the Training and Development Policy of the Bradesco Organization. Annually, BRAM estimates the budget for investment in the training and development of skills of its employees. After approval of the budget by the Executive Board, BRAM plans the implementation of learning solutions with the UniBrad Universidade Corporativa Bradesco, which takes on the management of the budget. 13.1. Learning Path 15 Learning paths suggested by UniBrad are designed to facilitate employee career planning, with alternatives that take into account activities that have been planned technical or managerial the level of experience in the role and the competencies that each Professional requires to focus in on their full development. 13.2. TreiNet 16 The investment in the training and development, by way of actions that provide the potential for our employees to improve, is fundamental in the career strategy adopted by Bradesco. This way, the Organization offers all employees equal learning opportunities, in any location, the Organization offers a number of distance learning media, the highlight being TreiNet, which has content that meets internal and external policies and standards, in addition to good governance practices. Periodically, the Organization is inspected by regulatory agencies, which require that all employees be trained on a number of topics, as they seek to ensure the Organization's compliance with the regulations, the safety of employees, in addition to reliability in the relations with clients. 15 Normative System Number 04.1041 Version: 02 Updated: 09/25/2016 16 Normative System Number 04.765 Version: 07 Updated: 05/25/2016 MP_8231_0070 01 27/06/2016 11 / 12

The training available on TreiNet includes Information Security, Prevention of Money Laundering and Financing Terrorism, Ethics and Conduct, Internal Controls, Anti-Corruption, among other topics. With obligatory courses, the study of content, on the IntraNet, and on completing an evaluation, on TreiNet, must occur, exclusively, at the place and time of work. TreiNet is an important learning tool offered by the Bank to benefit its employees, enabling them to broaden their knowledge and manage their own personal growth plan. 14. PENALTY Any breach of the rules and procedures described in this document is subject to administrative penalties set by the CVM, as well as self-regulation of capital market entities, without prejudice to the civil and criminal liability for damage directly caused to the Fund and Portfolio Managed, its Shareholders and the market, as provided for in current regulations. MP_8231_0070 01 27/06/2016 12 / 12