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Disclosure Policy

1. INTRODUCTION

This Disclosure and Trading Policy establishes the guidelines and procedures governing the disclosure of Material Acts or Facts and the trading of securities issued by Positivo Tecnologia, to be observed by the Directly Related Parties (as defined below). These parties shall sign the respective Declaration of Compliance with this Policy in accordance with the model established in Exhibit 1 of this document.

Positivo Tecnologia shall maintain, at its headquarters, a list of all persons who have signed the Declaration of Compliance, which shall be updated as new persons are added. Copies of the Declarations shall be forwarded to the Chief Financial Officer and Head of Investor Relations. Should there be any amendments to this Policy, the signatories of the Declaration of Compliance shall sign new Declarations and promptly deliver them to Positivo Tecnologia. Said documents shall be made available to the regulatory agencies.

The Declarations of Compliance shall remain filed at Positivo Tecnologia‘s headquarters as long as there is any relationship between the signatories and the Company and for at least five (5) years after said signatories have left the Company.

2. DEFINITIONS

The terms and expressions listed below, when used within this Policy, shall have the following meanings:

Controlling Shareholders – any shareholder or group of shareholders (i) bound by a shareholders’ agreement or under common control exercising controlling power over the Company, pursuant to Law 6404/76 and amendments thereto; and/or (ii) that retains the majority of votes in the shareholders’ meetings and elects the majority of the Board of Directors and executive officers.

Management – the Company’s executive officers and the sitting and alternate members of its Board of Directors.

Material Act or Fact – pursuant to CVM Instruction 358/02, a Material Act or Fact related to Positivo Tecnologia and its subsidiaries refers to any decision taken by the controlling shareholders, any resolution by a shareholders’ meeting or management body of the Company, or any other act or fact of a political, administrative, technical, transactional or economic and financial nature or related to the Company’s business that may have a material influence on: (a) the market price of securities issued by the Company or referenced thereto; (b) the decision of investors to purchase, sell or maintain said securities; and (c) the decision of investors to exercise any rights inherent to the ownership of said securities or securities referenced thereto. Exhibit 5 of this Policy contains a list of examples of Material Acts or Facts.

Commercial Contacts – any person privy to information related to a Material Act or Fact, especially those who maintain commercial or professional relations, or relations of trust, with the Company, such as securities analysts, independent auditors, consultants and institutions belonging to the securities distribution system.

Accredited Brokers – securities brokers accredited by Positivo Tecnologia to trade securities on behalf of the signatories of the Declaration of Compliance.

CVM – Brazilian Securities and Exchange Commission.

Chief Financial Officer and Head of Investor Relations – the Company officer responsible for collecting information on the Company, adapting it to meet the requirements of the financial market and disclosing it to investors, the CVM and the organized securities markets, as well as ensuring that Positivo Tecnologia’s records are always up to date.

Selected Disclosure – the disclosure of material information to any person prior to its disclosure to investors.

Employees and Executives with Access to Material Information – Company executives and employees who, due to their job, role or position with Positivo Tecnologia and its subsidiaries, have access to privileged information.

Former Members of Management – former executive officers and Board members who are no longer part of Positivo Tecnologia’s management.

Privileged or Material Information – any information related to the Company that has not yet been disclosed to the investment community and which may substantially influence: (i) the market price of the Company’s securities; (ii) the decision of investors to purchase, sell or maintain said securities; or (iii) the decision of investors to exercise any rights inherent to the ownership of said securities.

CVM Instruction 358/02 – CVM Instruction 358, of January 3, 2002, which regulates the disclosure and use of information in Material Acts or Facts related to publicly-held companies, as well as the trading of securities issued by publicly-held companies prior to the disclosure of a material fact, among other matters

IPE – system used to send documents to CVM (except quarterly information (ITR), standardized financial information (DFP) and annual information (IAN)).

Organized Securities Markets – stock exchanges and organized over the counter markets that trade securities in Brazil or abroad.

Technical or Advisory Bodies – technical or Management advisory bodies, created in accordance with Positivo Tecnologia’s Bylaws.

Indirectly Related Parties – persons who have the following relations with management, fiscal council members (if applicable) or members of Positivo Tecnologia’s technical or Management advisory bodies: (i) spouse from whom they are not legally separated; (ii) common-law spouse; (iii) any dependent included in the annual individual income tax return; and (iv) companies directly or indirectly controlled by Management, similar bodies or Directly Related Parties.

Directly Related Parties – comprising: (i) Management, controlling shareholders, board members and members of the Fiscal Council (if applicable); (ii) employees and executives with access to material information; (iii) members of any technical or Management advisory bodies currently envisaged, or envisaged in the future, by Positivo Tecnologia’s Bylaws; and (iii) any persons who, in view of their job, role or position in the parent company, subsidiaries or affiliated companies is privy to information related to any Material Act or Fact concerning the Company.

Trading and Disclosure Policy or Policy – refers to this present document denominated Disclosure Policy for Material Acts or Facts and Trading of Securities Issued by Positivo Tecnologia S.A., approved by the Company‘s Board of Directors‘ Meeting of November 20, 2006 and amended from time to time.

Positivo Tecnologia or Company – refers to Positivo Tecnologia S.A., a corporation with headquarters at Rua João Bettega, nº 5200, Bairro CIC, in the city of Curitiba, state of Paraná.

Investor Relations – the various means by which the Company maintains relations with the capital market.

Annual Report – a report with annual general and financial information on the Company, its strategies and its sustainability initiatives (e.g. social and environmental balance).

Simultaneously (or Simultaneous) – the concept of simultaneity related to this Policy in regard to the “simultaneous” delivery of documents to the CVM, organized securities markets and IR Website, is understood as being equivalent to “within one (1) hour”, preferably when the organized securities markets are closed.

Affiliated Companies – companies over whose management Positivo Tecnologia has significant influence without controlling them, “significant influence” being understood as the power to take part in decisions concerning the companies’ financial, commercial and operating policies. Such influence is presumed if the Company retains a direct or indirect interest of ten percent (10%) or more of the voting capital.

Subsidiaries – companies in which Positivo Tecnologia, or companies controlled by it, retains, directly or indirectly, sufficient ownership or partnership rights granting it, on a permanent basis, preponderance in all corporate resolutions and the power to elect the majority of Management.

Declaration of Compliance – an instrument signed by Management, the controlling shareholders, members of Positivo Tecnologia’s technical or Management advisory bodies, employees and executives with access to material information; and any persons who, in view of their job, role or position in the parent company, subsidiaries or affiliated companies is privy to information related to any Material Act or Fact concerning the Company, pursuant to Exhibit 5 of this Policy.

Securities – any shares, debentures, subscription bonuses, subscription receipts or rights, promissory notes, call and put options, and indices or derivatives of any type, as well as any other securities or collective investment agreements issued by Positivo Tecnologia, which are legally deemed to be securities.

IR Website – Positivo Tecnologia’s Investor Relations website.

3. DISCLOSURE POLICY FOR MATERIAL ACTS OR FACTS

The disclosure of Material Acts or Facts is aimed at preventing the undue use of privileged information in the securities market by persons who have access to said information, for their own benefit or for the benefit of third parties, and to the detriment of investors in general, the securities markets or the Company itself. Exhibit 5 of this Policy includes a list of examples of Material Acts or Facts, pursuant to CVM Instruction 358/02.

To this end, this Policy establishes the general procedures to be observed for the disclosure of Material Acts or Facts and the confidentiality of said undisclosed information, in order to ensure that the competent authorities and the securities markets are supplied with complete and timely information on the Company, thereby assuring equal and transparent disclosure to all interested parties, without favoring any to the detriment of others.

Duties and Responsibilities regarding the Disclosure of Material Acts or Facts

Duties and Responsibilities of the Chief Financial Officer and Head of Investor Relations

It is incumbent on the Chief Financial Officer and Head of Investor Relations to:

(i) disclose and announce any Material Act or Fact that has occurred or is related to the Company’s business to the markets, the CVM and the organized securities markets;

(ii) do everything possible to ensure broad and prompt dissemination of any Material Act or Fact;

(iii) disclose Material Acts or Facts simultaneously in all markets in which the Company’s securities are traded;

(iv) when required, provide additional information or clarification regarding the Material Act or Fact to the competent authorities;

(v) in the case of the preceding item, or in the event an atypical variation in the price or traded volume of securities issued by the Company or referenced thereto, conduct an inquiry among those persons with access to Material Acts or Facts in order to determine if they are privy to information which should be disclosed to the market; and

(vi) without prejudice to the other attributes envisaged in CVM Instruction 358/02, to ensure that Material Acts or Facts are amended, added to or republished whenever required by the CVM or the organized securities markets.

Duties and Responsibilities of Directly Related Parties

Directly Related Parties or any persons who, in view of their job, role or position in the Company, parent company, subsidiaries or affiliated companies are privy to information related to any Material Act or Fact shall immediately report said Material Act or Fact to:

(i) the Chief Financial Officer and Head of Investor Relations or, in the absence of same, the Chairman of the Company’s Board of Directors; or

(ii) the CVM, should the Chief Financial Officer and Head of Investor Relations fail to announce or disclose said Material Act or Fact.

Privileged Information and Confidentiality

Directly Related Parties, or members of the Company’s technical or Management advisory bodies with access to privileged information shall (i) maintain the confidentiality of information related to Material Acts or Facts to which they have privileged access until their disclosure to the market; and (ii) ensure that subordinates and third parties in their confidence do the same, being jointly liable with the latter in the event of non-compliance.

Should any person with access to privileged information be uncertain as to the materiality of said information, same should contact the Chief Financial Officer and Head of Investor Relations in order to resolve said uncertainty.

The Controlling Shareholders, Management, members of the Fiscal Council, members of the Company’s technical or Management advisory bodies, or any other employees and executives with access to privileged shall comply with the regulations governing the availability of said information, as well as its use in the trading of securities.

Procedures for the Preparation and Disclosure of Material Acts or Facts

Preparation Procedures

Material information should be reported immediately in detail to the CVM and the organized securities markets in writing, indicating, whenever possible and applicable, the amounts involved and other clarifications the Company may deem necessary.

Disclosure Procedures

Material information shall be disclosed to the public through an announcement in those newspapers habitually used by the Company for this purpose. This announcement may be made in summary format, provided there is an indication of the internet address where the full version may be accessed, said full version to have at least the same content as the text sent to the CVM and the organized securities markets.

Whenever material information is disclosed through any means of communication, including press releases, or meetings of professional associations, investors, analysts or any other select group, in Brazil or abroad, said information shall be simultaneously disclosed to the CVM, the organized securities markets and investors in general.

The Company shall maintain a website where information shall be made available at the same time as it is sent to the CVM and the organized securities markets.

Under no circumstances shall the Company publish Material Acts of Facts solely on its IR website, which should be used to compliment the traditional means of communication used by the Company.

3.3.2.1. Internal Procedures for Communicating and Disclosing Material Information

All the Company’s material information shall be centralized in the person of the Chief Financial Officer and Head of Investor Relations, who is responsible for communicating and disclosing said information.

Any Directly Related Party aware of acts of facts that may be considered as material information shall promptly communicate said information, in writing, to the Chief Financial Officer and Head of Investor Relations.

Should any person with access to privileged information be uncertain as to the materiality of said information, same should contact the Chief Financial Officer and Head of Investor Relations in order to resolve said uncertainty.

In accordance with the applicable regulatory deadlines, especially those established by CVM Instruction 358/02, information on Material Acts of Facts shall be reported to:

(i) the CVM;

(ii) the organized securities markets; and

(iii) the market in general and on the Company’s IR website.

Material information shall be disclosed before or after trading sessions in the organized securities markets. If said markets do not operate simultaneously, disclosure shall occur in accordance with the business hours of the Brazilian organized securities markets.

Material information may, exceptionally, not be disclosed, upon justification and after due analysis, if the Controlling Shareholders, Management or the Chief Financial Officer and Head of Investor Relations (as the case may be), believes that disclosure of same may jeopardize the legitimate interests of the Company.

If the material information is related to operations directly involving the Controlling Shareholders and they opt not to disclose said information, they must inform the Chief Financial Officer and Head of Investor Relations of their decision.

In the remaining cases, when the material information is linked to operations involving the Company, then Management shall decide on the disclosure or not of said information and inform the Company’s Chief Financial Officer and Head of Investor Relations of its decision.

The Controlling Shareholders and Management, through the Company‘s Chief Financial Officer and Head of Investor Relations, may decide to submit the question of disclosing or not material information that may jeopardize the legitimate interests of the Company to the decision of the CVM.

Said request shall be sent to the CVM’s Chairman, in a sealed envelope labeled “Confidential”.

The Controlling Shareholders and Management shall immediately disclose material information, or ask the Chief Financial Officer and Head of Investor Relations to do so, if said information has become known to third parties or in the event of an atypical variation in the price or traded volume of securities issued by the Company.

Positivo Tecnologia will not comment on market rumors concerning the Company, except if said rumors substantially influence the price of its securities.

Disclosure of Information on Securities Trading by Management and Indirectly Related Parties

Management, members of the Fiscal Council, members of the Company’s technical or Management advisory bodies and Indirectly Related Parties shall report, in the form established by CVM Instruction 358/02, to the CVM and the organized securities markets, in accordance with the model included in Exhibit 2 of this Policy, any interest they, or Indirectly Related Parties, retain in securities issued by the parent company or subsidiaries of same (publicly-held companies), as well as any changes in said interest.

Disclosure Procedures

The procedures herein for communicating information on the trading of securities issued by the Company are based on Article 11 of CVM Instruction 358/02.

Management, members of the Fiscal Council and members of the Company’s technical or Management advisory bodies shall report any interest held by them in securities issued by the Company.

The persons mentioned above shall:

(a) also declare any interest held by Indirectly Related Parties; and

(b) communicate said information (i) within five (5) days following each trade; (ii) on the first business day following investiture in a Company position; and (iii) upon presentation of the documentation for registering the Company as a publicly-held company.

The declaration shall include trading in derivatives or any other instruments referenced to securities issued by the parent company or its subsidiaries, providing they are publicly-held companies.

Said declaration shall be forwarded to the Chief Financial Officer and Head of Investor Relations who shall report the information received, in accordance with this item, to the CVM and the organized securities markets, within ten (10) days after the end of the month in which the change of interest takes place, or the month in which the above-mentioned persons are invested.

Disclosure of Information on the Acquisition or Sale of a Relevant Interest

The direct or indirect Controlling Shareholders and the shareholders who elect the members of the Company’s Board of Directors shall inform the Company (in accordance with the model form included in this Disclosure Policy as Exhibit 3) and disclose any information on the acquisition or sale of a relevant interest, in the form established by CVM Instruction 358/02. A relevant interest is defined as an interest corresponding, directly or indirectly, to five percent (5%) or more of any type or class of share representing the Company’s capital stock.

Disclosure Procedures

The procedures herein related to the communication and disclosure of information on the trading of securities issued by the Company involving a relevant interest, are based on Article 12 of CVM Instruction 358/02.

The Controlling Shareholders and shareholders who elect the members of the Board of Directors or Fiscal Council, as well as any individual or corporate entity, or group of persons, operating jointly or representing the same interest, that attain a direct or indirect interest corresponding to five per cent (5%) or more of any type or class of security, shall immediately report the following information to the Company:

(i) the name and qualification of the buyer, indicating their individual or corporate taxpayer’s number;

(ii) the purpose of acquiring said interest and the quantity envisaged, containing, if appropriate, a declaration by the buyer stating that the acquisition is not aimed at altering the Company’s ownership or management structure;

(iii) the number of shares, warrants, subscription rights and stock option rights, by type and class, already held, directly and indirectly by the buyer or related parties;

(iv) the number of share-convertible debentures already held, directly or indirectly, by the buyer or related parties, specifying the quantity of shares subject to conversion, by type and class; and

(v) an indication of any agreement or contract regulating the exercise of voting rights or the purchase and sale of securities issued by the Company.

Persons or groups of persons representing a common interest who retain an interest equal to or more than the above-mentioned percentage, shall also disclose the same information whenever said interest increases by five per cent (5%) of a give type or class of security.

The above obligations shall also be extended to the acquisition of any rights over securities such as the objects of loan operations.

The above-mentioned persons shall also report the sale or cancellation of securities, or the rights related thereto, whenever the holder’s interest in a given type or class of securities reaches five per cent (5%) of the total of said type or class or is reduced by five per cent (5%) of the total of said type or class.

Whenever the acquisition of interest results in, or is intended to result in, a change in the Company’s ownership or management structure, as well as in cases when the acquisition results in the obligation to hold a public tender offer, pursuant to CVM Instruction 361 of March 5, 2002, the buyer shall also publish an announcement in the press, in accordance with Article 3 of CVM instruction 348/02, containing the information provided for in items (i) to (v) above.

The Chief Financial Officer and Head of Investor Relations is responsible for transmitting this information, as soon as it is received by the Company, to the CVM and the organized securities markets, as well as for updating the IAN form in the corresponding field.

4. SECURITIES TRADING POLICY

The Company and its Management, Controlling Shareholders, members of the Fiscal Council, employees and executives with access to material information, as well as members of the Company’s technical or Management advisory bodies and any other persons who, due to their job, role or position with the parent company, subsidiaries or affiliated companies are aware of information related to any Material Act of Fact concerning the Company (Directly Related Parties) shall adopt the appropriate standards regarding the trading of securities issued by the Company or its subsidiaries, using the brokers listed in Exhibit 4 of this Policy.

In general, the Company and Directly Related Parties are prohibited from making use of any information related to Material Acts or Facts that has not yet been disclosed to the market in the trading of securities to their advantage or to the advantage of any third party.

Trading through Accredited Brokers and Lock-up Period

In order to ensure exemplary standards of trading in securities issued by Positivo Tecnologia and its subsidiaries, all trades by the Company and Directly Related Parties – who shall adhere to this Policy – shall only be executed through accredited brokers, in accordance with the list sent to the CVM (Exhibit 4).

Positivo Tecnologia’s Chief Financial Officer and Head of Investor Relations shall instruct the accredited brokers, in writing, not to undertake operations by Directly Related Parties on all dates on which Company trades or informs the accredited brokers of its intention to trade.

Positivo Tecnologia and all parties subject to the conditions set forth in this Policy shall refrain from trading shares issued by the Company during lock-up periods. Said lock-up periods shall be determined by a communication from the Chief Financial Officer and Head of Investor Relations, who is not obliged to justify said determination.

The same obligations apply to parent companies and subsidiaries.

Restrictions on Trading in the Case of Material Acts or Facts Pending Disclosure

The trading of securities by Positivo Tecnologia and Directly Related Parties is forbidden in the following circumstances:

(i) Whenever any Material Act or Fact related to Positivo Tecnologia’s business occurs, of which the Directly Related Parties are aware;

(ii) Whenever there is an ongoing acquisition or sale of Positivo Tecnologia shares by the Company itself, its subsidiaries, affiliated companies or other companies under joint control, or if an option or mandate is granted for the same end;

(iii) Whenever there is an intention to promote the total or partial spin-off, merger, change of corporate status or reorganization of the Company; and

(iv) During the period between the decision of the competent corporate body to undertake a capital increase or reduction, pay dividends, allocate bonuses in the form of shares or derivatives, undertake stock splits, reverse splits or issue other securities, and the publication of their respective notices or announcements.

In regard to the above circumstances, the prohibition on trading shall prevail even after the disclosure of the respective Material Acts or Facts, if the Company believes that such trading will jeopardize the Company or its shareholders. Whenever Positivo Tecnologia decides to maintain the trading veto, the Chief Financial Officer and Head of Investor Relations shall announce said decision through an Official Letter.

Prohibition on Trading Prior to the Disclosure of the Quarterly Information and Financial Statements

Positivo Tecnologia and Directly Related Parties are prohibited from trading in securities issued by Positivo Tecnologia within fifteen (15) days prior to the disclosure or publication, whichever be the case, of the Company’s quarterly information (ITR) and annual financial statements (DFP). This same rule will be apply if the company opts to disclose preliminary operating and financial data prior to the disclosure of its audited results, as envisaged in Exhibit 7 of this document.

Individual Investment Programs shall expressly comply with these restrictions.

During the periods mentioned above, the accredited brokers will be advised by Positivo Tecnologia not to undertake operations for Directly Related Parties.

The prohibitions above do not apply to shares held in treasury acquired through private trading and linked to the exercise of stock options in accordance with the stock option plan approved by Positivo Tecnologia’s Annual Shareholders’ Meeting, or any eventual repurchase of Company shares, also through private trading.

The restrictions on trading envisaged in this Policy also do not apply to Positivo Tecnologia and Directly Related Parties, as of the date of signature of the Declaration of Compliance, providing the investment:

(a) is considered to be long term;

(b) is not undertaken during the period mentioned in item 4.3 above; and, cumulatively,

(c) meets at least one of the characteristics described below:

(i) The subscription or purchase of shares due to the exercise of options granted through the stock option plan approved by the Annual Shareholders’ Meeting;

(ii) The acquisition by Positivo Tecnologia of Company shares for cancellation or maintenance in treasury;

(iii) The use of bonus payments, received as profit sharing, to acquire securities issued by Positivo Tecnologia; and

(iv) The execution, by Directly Related Parties, of Individual Investment Programs.

The purchase of securities by Directly Related Parties during the period referred to in item 4.3 above is permitted, if (cumulatively):

(a) there is no voluntary alteration by the Company by more than two (2) days in the dates envisaged for sending the ITR and DFP forms in the corporate events schedule sent to the BOVESPA;

(b) the acquirer expressly complies with the conditions set forth in the Individual Investment Program;

(c) adherence to the program does not occur when Material Acts of Facts are pending disclosure to the market, and within fifteen (15) days prior to the disclosure of the ITR and DFP forms;

(d) the extension of the Individual Investment Program, even after the end of the period originally envisaged for the participant’s adherence; (i) while Material Acts or Facts are pending disclosure to the market; and (ii) within fifteen (15) days prior to the disclosure of the ITR and DFP forms, until these forms are sent to the CVM and to the organized securities markets; and

(e) the Company is indemnified by the Directly Related Party in question for any losses avoided or gains incurred in the trading of securities arising from any eventual changes to the disclosure dates of the ITR and DFP forms.

The indemnification referred to in item “e” above will correspond to the highest of the following amounts: (i) the value of the trade in question; (ii) the value of any condemnation suffered by the Company or the Chief Financial Officer and Head of Investor Relations due to irregular trading; or (iii) the value of any fine imposed upon the Company, the Chief Financial Officer and Head of Investor Relations or any Directly Related Party by the CVM or the organized securities markets.

Prohibition on the Company’s Acquisition or Sale of Shares issued by Positivo Tecnologia

Positivo Tecnologia’s Board of Directors may not deliberate on the acquisition or sale of Company shares while the events listed below have not been published through a Material Fact:

(i) The signing of any agreement or contract for transferring control of Positivo Tecnologia; or

(ii) The granting of an option or mandate for transferring the control of Positivo Tecnologia; or

(iii) The intention to undertake an incorporation, total or partial spin-off, merger, change of corporate status or corporate reorganization of the Company.

If, after the buyback program has been approved, a fact occurs that matches any of the three above events, Positivo Tecnologia will immediately suspend trading in its own shares until the disclosure of the respective Material Act or Fact.

Prohibition on Trading Applicable Only to Former Members of Management

Without prejudice to the information described in Section 4.8 below, with respect to the Individual Investment Program, Executive Officers who left Positivo Tecnologia before the public disclosure of a business or fact that began during their management period are prohibited from trading in the Company’s securities during the following periods:

(i) For six months after the officer in question has ceased working for the Company; or

(ii) Until Positivo Tecnologia discloses a Material Act or Fact to the market. However this prohibition may extend after said disclosure if the Company believes that such trading will jeopardize the Company or its shareholders.

Whichever of the above two events occurs first shall prevail.

General Provisions Applicable to Trading Restrictions

The Chief Financial Officer and Head of Investor Relations may, without justification or in the absence of any undisclosed Material Acts or Facts, establish periods during which Directly Related Parties may not trade in the securities issued by the Company or referenced thereto. Directly Related Parties shall keep said periods confidential.

The trading prohibitions established in this Policy apply to trades undertaken directly or indirectly by Directly Related Parties, even when executed as follows:

(i) Through a company controlled by them; and

(ii) Through third parties with whom they maintain a fiduciary or share portfolio management agreement, including, but not limited to, investment clubs.

The trading prohibitions established in this Policy also apply to trades undertaken in the organized securities markets, as well as trades held without the intermediation of brokers.

Pursuant to Article 20 of CVM Instruction 358, trades by investment funds whose members are Directly Related Parties are not considered to be indirect trades, providing the following conditions are complied with:

(i) The investment funds are not exclusive; and

(ii) The trading decisions of the fund manager are not subject to influence by the fund’s members.

Individual Investment Program are understood as individual plans for the acquisition or sale of securities, filed at Positivo Tecnologia‘s headquarters, through which Directly Related Parties have indicated their intention of purchasing securities issued by Positivo Tecnologia with their own funds or selling same in the long term.

To this end, the Individual Investment Program must be filed for more than thirty days with the Chief Financial Officer and Head of Investor Relations, indicating, in an approximate manner: (i) if the plan refers to a scheduled investment or divestment; (ii) the amount of funds the interested person intends to invest or the number of securities he or she intends to buy or sell; and (iii) the expiration date of the person’s Individual Investment Program, which must not be less than twelve (12) months. Upon expiration, the interested person shall present a summarized report of its evolution.

Any alterations to said Plan or its compliance: (i) shall not occur if any Material Acts of Facts are pending disclosure or during the fifteen (15) days prior to the disclosure of the ITR and DFP forms; (ii) shall be communicated in writing to the Chief Financial Officer and Head of Investor Relations within ten (10) business days prior to said alteration. In case of unforeseen events, where prior communication is impossible, the reasons and documents justifying non-compliance shall be sent to the Company in writing.

Except in case of force majeure, duly justified in writing, securities acquired through the Individual Investment Program shall not be sold sooner than ninety days as of their acquisition date.

5. POLICY VIOLATION

Any infringement of the provisions established in this Policy constitutes a gross violation and the offender shall be subject to the penalties established by Law 6385/76 and CVM Instruction 358/2002.

The provisions established in this Policy do not detract from the responsibilities arising from any legal implications concerning third parties not directly linked to the Company who are aware of any Material Act or Fact.

6. RESPONSIBLE EXECUTIVE OFFICER

The Chief Financial Officer and Head of Investor Relations is the person responsible for executing and monitoring this Policy.

7. DECLARATION OF COMPLIANCE

Adherence to this Policy shall occur upon signature of the Declaration of Compliance (Exhibit 1) to be maintained, jointly with the list of signatories, in accordance with Article 16, paragraphs 1 and 2 of CVM Instruction 358.

8. VALIDITY AND AMENDMENTS OF THIS POLICY

This Policy will enter into force on the day following its approval by the Board of Directors of Positivo Tecnologia and any amendment or revision should be submitted to the approval of the same Board. This Policy shall not be altered while Material Acts or Facts are pending disclosure.