Disclosure Policy
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- 1 - Preliminary Considerations
- 2 - Disclosure Policy and Use of Relevant Information
- 3 - Trade Policy
- 4- Duties and Responsibilities of the IRD
- 5 -Final Provisions
- 6 - Appendix I - Model of Adhesion Contract to the Policy on Disclosure, Use of Relevant Information, and Trading of Securities issued by Randon S.A.- Implementos e Participações
- 7 - Appendix II - List exemplifying Relevant Acts or Facts
- 8 - Appendix III - Model of Trading Report of Securities issued by Randon S.A.- Implementos e Participações
- 9 - Appendix IV - Model of Individual Investment Program
1 - PRELIMINARY CONSIDERATIONS
1.1. Introduction
This manual (“Manual”) contains the Disclosure Policy and Use of Relevant Information, as well as the Trade Policy concerning securities issued by Randon S.A.- Implementos e Participações (“Company”) approved of by the Board of Directors at a meeting held on June 14, 2002 and revised by the same body at a meeting held on September 14, 2009, during which this consolidation was approved.
1.2. Purpose
Set forth directives and procedures which shall be complied with when disclosing and using Relevant information, and when trading securities issued by the Company.
1.3. Scope
The directives and procedures contained in this Manual shall be followed by the following persons: controlling shareholders, Officers/ members of the management, members of the Audit Board, members of any bodies with technical and consulting functions created by statutory provisions, and also by any other persons who, due to their functions or positions in the Company or in its subsidiaries or other companies under common control, may hold Relevant information on the Company, herein defined as Binding Persons.
1.3.1. The persons listed above must adhere to the respective Term of Adhesion to the present Manual, articles 15, § 1st, item I and 16, § 1st of CVM Directive 358/02, according to the model enclosed to this Manual (Enclosure I).
1.3.2. Persons related to the ones listed on item 1.3 include spouses or partners, descendants and any other dependents included in the annual Income Tax Return, and companies controlled by such persons, defined in this Manual as Related Persons.
1.4. Definitions
The terms and expressions below, as used in this Manual, will have the following meanings:
“Controlling Shareholders” or “Controlling Company”: the shareholder or group of shareholders bound by a shareholders` agreement or under common control which holds control of the Company by operation of Law no, 6,404/76.
“Administrators”: the members of the Board of Directors and Executive Board acting on their own or on behalf of the Company.
“Relevant Act or Fact”: any decision made by a controlling shareholder, resolution by the General Meeting or management bodies of the Company, or any other act or fact of political-administrative, technical, trading or economic-financial nature which has or is related to the business of the Company which may substantially affect: (i) the price of the securities of the Company or related securities; (ii) investors` decision to buy, sell or hold securities; and (iii) investors` decision to exercise any rights associated with their position as holders of securities issued by the Company or related to it. The Appendix II of this Manual contains a list exemplifying the sort of situations that may involve such Relevant Acts or Facts.
“Stock Exchanges”: the stock exchanges where the Company has securities accepted for trading.
“Company”: Randon S.A. Implementos e Participações
“Members of the Audit Board”: the members of the Audit Board of the Company, sitting or substitute members, whenever the Board is installed during shareholders` general meeting.
“Control”: Power effectively exercised to conduct social activities and provide guidance for the functioning of the company`s bodies, directly or indirectly, based on facts or on the law. The persons connected by a shareholders` agreement or under common control, who hold shares that assure them the majority of the shareholders` votes and who were present in the last three general meetings of the Company - even if they are not holders of the shares assuring them the absolute majority of the voting capital - are deemed as having control in spite of being considered separately.
“CVM”: refers to the Comissão de Valores Mobiliários (Securities and Exchange Commission).
“Investor Relations Director” or “IRD”: the Company director responsible for providing information to investors from the public, to CVM and to the Stock Exchanges, as well as for keeping the Company`s registration up-to-dated.
“Former-Administrators”: former directors and Board of Directors members, who are no longer part of the management of the Company.
“Relevant Information”: information related to the Company which may substantially affect the price of the securities, not yet disclosed to the investor public.
“CVM Directive 358”: CVM Directive no. 358, of January 3, 2002, subsequently amended by CVM Directive 369, of June 11, 2002, and by CVM Directive no. 449, of March 15, 2007, which provides about the disclosure and use of Relevant Information, about the trade of securities issued by listed companies, and other issues;
“Manual”: Manual for Policy on Disclosure, Use of Relevant Information, and Trading of Securities issued by Randon S.A.- Implementos e Participações;
“Bodies with Technical and Consulting Functions”: the bodies of the Company created by statutory provisions, with technical functions or installed to advise its administrators.
“Binding Persons”: controlling shareholders, administrators, audit board members, members of any bodies with technical or consulting functions created by statutory provisions and also by any other persons who, due to their functions or positions in the Company or in its subsidiaries or other companies under common control, may hold Relevant information on the Company.
“Related Persons”: persons who are related to the Binding Persons included in this Manual: (i) spouses; (ii) partners; (iii) descendants and any dependents included in the annual Income Tax Return; and (iv) companies directly or indirectly controlled by the Binding Persons.
“Individual Investment Program” or “Program”: the Company`s own investment programs provided in § 2nd of Article 15 of ICVM Directive no. 358, also defined as the individual program of purchase or sale of securities filed at the Company, by which the Company and the “Binding Persons” have indicated their commitment to invest with their own funds, in the long term, or disinvest securities issued by the Company. The Appendix IV of this Manual shows a model of an Individual Investment Program.
“Affiliate Companies”: companies over which the Company has influence on its management, without controlling them.
“Subsidiary Companies”: companies which are directly or indirectly controlled by the Company
“Securities”: the term “securities” includes any shares, debentures, subscription bonus, subscription receipts and rights, promissory notes, call and put options, indices and derivatives of any type, as well as any other securities or collective investment agreements issued by the Company which, by legal decision, are deemed to be securities.
1.5. Principles
All Binding Persons shall act in conformity with principles of good faith, loyalty and truthfulness, and also with the general principles herein established, taking into account that transparent, precise and timely information is the main instrument available to the investor public, specially to the shareholders of the Company, to whom equitable treatment must be ensured.
2 -DISCLOSURE POLICY AND USE OF RELEVANT INFORMATION
2.1. Purpose of Disclosing Relevant Information
The disclosure of Related Acts or Facts intends to assure investors of the availability, in due course and in an efficient and reasonable manner, of the information they need to make their investment decisions, thus ensuring the best possible symmetry when disclosing information, and thus preventing the improper use of Relevant Information in the stock market, by people who have access to it, either for their own advantage or for third parties` advantages.
2.2. Methods of Disclosure of Relevant Acts or Facts
2.2.1. The Relevant Information must be simultaneously disclosed to CVM and to Stock Exchanges and its disclosure shall be made by means of announcements published in the newspapers used by the Company. Such announcements may contain a summarized description of the Relevant Information provided that it indicates the Internet address where a full description of the Relevant Information is available to all investors and the contents are at least as detailed as the text sent to CVM and Stock Exchanges.
2.2.2. The Relevant Information shall be released, preferably, before or after the closing of business on the stock exchanges. If it is imperative that a relevant fact or act be disclosed during trading hours, the IRD may do it and simultaneously request that the Stock Exchanges suspend trading of the Company-issued securities for the period of time necessary for adequate dissemination of the Relevant Information.
2.2.3. The Binding Persons shall inform any Relevant Act or Fact that they have knowledge of to the IRD, who is the person responsible for disclosing them to the proper bodies and press.
2.2.4. If the Relevant Fact or Act is not to remain undisclosed, as in certain cases provided by law, and even so the IDR`s fails to disclose it, the Binding Persons will only be exempt from responsibility if they immediately notify the Relevant Act or Fact to CVM.
2.2.5. Whenever there is doubt regarding the nature of a given Relevant Act or Fact, it is the responsibility of the IRD to decide about it. To this end, the IRD may consult with the members of the Board of Directors.
2.2.6. In meetings with trade associations or entities, investors, analysts, or selected members of the public, concerning matters that may be deemed as a Relevant Act or Fact, the IRD or another person appointed for this purpose shall be present, or the content of such meetings shall be reported to the IRD, so it can be simultaneously released to the securities market.
2.3. Confidentiality Obligations
The Binding Persons shall keep confidential any Relevant/Insider Information which they have access to until such Information is disclosed to the market, as well as endeavor to ensure that their subordinates and third parties of their trust do likewise. Whenever there is doubt on the relevancy of any information, the Company`s IRD shall be contacted so he/she can resolve it.
2.4. Exception to Immediate Disclosure of Relevant Act or Fact
Relevant acts or facts may remain undisclosed in exceptional cases if the controlling shareholders or administrators conclude that their disclosure may pose a risk to the legitimate interests of the Company. In this case, it is the IRD`s duty to follow up the quotation, price and volume of trades of the securities issued by the Company, and if he/she verifies an atypical fluctuation in these elements, the Relevant Act or Fact shall be immediate disclosed, even if the Company had previously decided not to disclose it.
2.5. Disclosure of Forecasts
The Company eventually may disclose forecasts and/or estimates relative to the behavior of its market sector or to its own future performance, provided that they are always accompanied of the following note:
This presentation contains future information. Such information does not consist of historical facts, but reflects the goals and expectations of the Board of Directors of Randon S/A. .- Implementos e Participações. The words “anticipates”, “wishes”, “expects”, “forecasts”, “intends”, “plans”, “ foresees”, “estimates”, “hopes” and similar words, whether written and/or spoken, seek to identify statements that necessarily involve known or unknown risks.
Known risks include uncertainties that are not limited to the impact of competitiveness of prices and products, acceptance of the products abroad, competitors` behavior, official approvals, type and fluctuation of currencies, regularity in the supply of raw Relevants and operation, among others. The Company reserves the right not to update this presentation upon new information or future events. The Company does not hold responsibility for operations or investment decisions made with basis on the information contained in this presentation.
2.6. Comments on Rumors
It is the policy of the Company not to comment on rumors. When questioned about any rumor, the Company will state: “it is our policy not to comment on rumors or speculations”. If, however, the rumors are affecting the price or volume of trades of the securities issued by the Company, there may be the need of making a pronouncement confirming or denying reports. This subject shall be assessed by the IRD and, if it is the case, resolved by the Board of Directors.
2.7. Disclosure of Information on Trades
The directors, members of the Board of Directors, Audit Board, and of any bodies with technical or consulting functions created by statutory dispositions must inform the company about the holders and trades of securities issued by the company itself, or by its controlling or controlled companies, when these are listed companies.
2.7.1. The communication shall be made by filling out and sending the form included in the Appendix III of this Manual, observing the following:
(a) in the first working day upon taking the job position ; and
(b) within 5 (five) days after the end of the month in which there is any change in the securities held, indicating the balance for the period.
2.7.2. When the Binding Persons are individual persons, they shall also indicate the securities held by the Persons Related to them, as well as those held by controlled companies, either directly or indirectly.
2.7.3. The notice this item refers to should also include information on the purchase or sale of significant controlling stake, pursuant Article 12 of ICVM 358 Directive.
2.7.4. The Company shall send the afore-mentioned information to CVM and to the Stock Exchanges within 10 (ten) days of the end of the month in which there were changes in the positions held, or of the month in which the Binding Persons were sworn in.
3 -TRADE POLICY
3.1. Purpose of the Trade Policy
This Trade Policy of Securities issued by the Company intends to lay down rules and procedures to be followed by the Company and by the Binding Persons while trading securities issued by the Company, or referred to them, so as to preserve transparency in the trades.
3.2. Trade Prohibition
The Company and the Binding Persons are prohibited, without prejudice to the exceptions applicable to the trades verified with basis on this Trade Policy, to trade any security issued by the Company in the following events:
(a) in the period between the date on which they became aware of the relevant information (Relevant Act or Fact) and the date such information is disclosed to the market.
(b) in the 15 (fifteen) days the precede the disclosure of the Company`s quarterly information (ITR) and annual information (DFP).
(c) if there is the intent to engage in an incorporation, total or partial spin-off, merger, transformation or corporate restructuring;
(d) with regard to the controlling shareholders, whether direct or indirect, and administrators, whenever the Company itself (shares kept in treasury), its controlled companies, subsidiaries or other societies under common control may be acquiring or selling shares issued by the Company, or if an option or mandate for this purpose has been granted.
The Binding Persons will receive a notice from the IRD, or from whoever this latter appoints to do so, informing the dates and/or periods during which they shall preclude from trading securities issued by the Company (“Black-out Period”). The IRD is not obliged to inform the reason determining the “Black-out Period”, which shall be treated in secrecy by their addressees.
3.2.1. The prohibition herein stated shall also apply, in the situations mentioned in the above item, to:
(a) the administrators who leave management positions with the Company prior to the disclosure of a business transaction or fact originated during their term until the end of the six-month period following their departure, or until the public disclosure of the Relevant Act or Fact, whichever occurs first;
(b) those who have a commercial, a professional relationship, or a relationship of trust with the company, such as independent auditors, securities analysts, consultants and institutions that are part of the distribution system, upon which it is incumbent to check on the communication of the Relevant Information prior to engaging in the trading of securities issued by the Company or related to them;
(c) the Related Persons.
3.2.2. The prohibition provided in item “a” of item 3.2. does not apply to the purchase of shares held in treasury through private trading arising from the exercise of call options, in accordance with the stock option plan approved at the general meeting.
3.2.3. The Board of Directors may not decide on the purchase or sale of its own shares while the following information does not become public through the publication of the Relevant Act or Fact on the:
(a) entering into any agreement or contract aimed at transferring the controlling stake of the company;
(b) granting of an option or mandate for the purpose of transferring the controlling stake of the Company; or
(c) existence of an intent to promote the incorporation, total or partial spin-off, merger, transformation or corporate restructuring.
If, after approval of the share repurchase program by the Board of Directors one of the events referred to in this item occurs, the company shall suspend the operations with its own shares until the specific Relevant Fact is disclosed.If, after approval of the share repurchase program by the Board of Directors one of the events referred to in this item occurs, the company shall suspend the operations with its own shares until the specific Relevant Fact is disclosed.
3.2.4. The prohibitions provided in item “a” of item 3.2 and item 3.2.3. shall cease as soon as the Company discloses the respective Relevant Act or Fact to the Securities Market. However, such prohibition shall be maintained, even after the disclosure of the Relevant Act or Fact, in the event that the trading of securities may interfere with trading conditions at the expense of the Company and its shareholders.
3.2.5. Under no circumstance, the Company shall trade its own shares during the prohibition periods established in ICVM 358 Directive, as well as in those provided in this Policy.
3.3. Exceptions to Trading Prohibition
The prohibition to trading securities issued by the Company, laid down in the present Trading Policy, does not apply to the Binding Persons when:
(a) the trades of the Company`s securities are carried out by investment funds of which the Binding Persons are members, provided that said funds are neither exclusive investment funds or funds whose portfolio manager`s trading decisions are influenced by the Binding Persons.
(b) it refers to the exercise of the subscription preference right concerning shares previously purchased; and
(c) it refers to private trading among the Binding Persons, deemed as such those carried out outside Stock Exchanges.
3.4. Individual Investment Program
Provided that the prohibition/ restriction on trading securities of the Company during the 15 (fifteen) days that precede the disclosure of the Company`s quarterly information (ITR) and annual information (DFP) is applied, the Binding Persons may indicate an Individual Investment Program which will show their commitment to buy securities with their own funds, or sell securities held by them. Such Program shall be implemented irrespective of the existence or not of undisclosed Relevant Acts or Facts.
3.4.1. The Individual Investment Program shall be filed with the Company 15 (Fifteen) days prior to the first trade foreseen on it and shall include:
(a) the nature of the scheduled operations, whether purchase or sale;
(b) the amount of funds that the participant intends to invest or desinvest or the number of securities he/she seeks to buy or sell, as well as the trading respective dates;
(c) the validity term, which shall not be shorter than 12 (twelve) months);
(d) the identification of the securities brokers which will mediate the trades;
(e) the identification of the Related Persons;
(f) the irrevocable and unchangeable commitment of the participant, except for a legitimate and plausible reason, of performing the purchase and sale operations previously established on the dates foreseen on it; and
(g) in case of investments, the commitment not to sell the securities acquired in the scope of the Program earlier than 6 (six) months from the date of acquisition, except in event of force majeure, duly justified in writing.
3.4.2. The Program must not be carried out if there is any Relevant Act or Fact pending disclosure (of which the interested person does not know about), nor during the 15 (fifteen) days preceding the disclosure of the ITR and DFP earnings results.
3.4.3. While an investment program is in force (purchase) a desinvestment program (sale) cannot be in place, and vice-versa;
3.4.4. The IRD may refuse filing with the Company a Program that does not comply with this Policy or with the current legislation and, when requested, he/she shall inform CVM and the Stock Exchanges about the programs filed with the Company.
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4 - DUTIES AND RESPONSIBILITIES OF THE IRD
The responsibilities of the IRD are:
(a) Disclose and endeavour to ensure the extensive dissemination of the Relevant Act or Fact related to the Company`s business, immediately after he/she becomes aware of it;
(b) Promote the execution and monitoring of the Policies contained in this Manual and handle all communications among CVM (SEC), the Stock Exchanges and further members of the Securities Market;
(c) Act as the main spokesperson of the Company in matters pertinent to the Securities Market;
(d) Promptly respond to any requests for additional clarification, corrections, amendments or republication of Relevant Acts or Facts;
(e) Receive information on the quantity, characteristics and method of acquisition of securities being traded in the securities market, issued by the Company and by controlled or controlling companies listed on stock exchanges, where the Binding Persons hold securities, as well as any change in their positions, and disclose such information to CVM and Stock Exchanges.
5 - GENERAL PROVISIONS
5.1. The Board of Directors may, at any time, make changes in the Policy contained in this Manual. Such changes shall be promptly informed by the IRD to the Binding Persons, CVM and Stock Exchanges and shall become effective to all at the date in which the Adhesion Agreement is signed.
5.2. The Policy provided in this Manual may not be changed while there is any undisclosed Relevant Act or Fact.
5.3. Any violation of this Policy by the Binding Persons shall be immediately informed to the Company`s IRD;
5.4. The Binding Persons who do not comply with the provisions contained in this Manual shall compensate the Company for all losses that the Company may have as a result of such non-compliance;
5.5. The violation of the terms established in this Policy may be deemed as a serious infringement pursuant § 3rd. of Article 11 of Law 6,385/76. Additionally, the utilization of information based on Relevant Acts or Facts that have not been disclosed yet may be considered as a crime and will be subject to imprisonment for 1 (one) to 5 (years), in addition to a penalty, pursuant Article 27-D of Law 6,385/76.
Caxias do Sul, September 14, 2009.
6 - Appendix I
Manual for Policy on Disclosure, Use of Relevant Information, and Trading of Securities issued by Randon S.A.- Implementos e Participações.
Adhesion Contract
By this present instrument, [insert name and qualification], resident and domiciled in (a)on [address], enrolled with the Private Taxpayers` Registry (CPF) under no. [insert number] and bearer of the (a)Identity Card RG no. [specify number and issuing body], hereinafter referred to as “Declarant”, in the capacity of [specify position, job or relation with the Company] of Randon S.A. Implementos e Participações, a publicly held corporation with head Office in Caxias do Sul, State of Rio Grande do Sul, on Abramo Randon Ave., 770, Interlagos District, enrolled with the General Taxpayers` Registry (CNPJ) under no. 89.086.144/0001-16, hereinafter referred to as simply the “Company”, hereby declares to have full knowledge of Policy on disclosure, Use of Relevant Information, and Trading of Securities issued by Trading S.A.- Implementos e Participações, which governs the internal policy on the use and disclosure of relevant information concerning securities issued by the Company, received a copy of such Manual, and is bound to base his/her actions always in compliance with the rules established therein. The Declarant signs this Adhesion Contract in 2 (two) identical copies in the presence of the 2 (two) undersigned witnesses.
Caxias do Sul, [date]
[Name of the Declarant]
Witnesses:
| 1. | 2. |
| Name: | Name: |
| ID: | ID: |
| CPF: | CPF: |
7 - Appendix II
Manual for Policy on Disclosure, Use of Relevant Information, and Trading of Securities issued by Randon S.A.- Implementos e Participações.
List Exemplifying Relevant Acts or Facts
(a) execution of an agreement or contract providing for the transfer of the Company`s shareholding control even if under suspensive or resolutive condition;
(b) change in the Company`s control, inclusively by means of the execution, amendment or termination of shareholders’ agreement;
(c) execution, amendment or termination of shareholders` agreement to which the Company isd a party or intervenor, or which may have been validated in the company`s competent book;
(d) joining or withdrawal of a partner maintaining with the Company a contract of operational, financial, technological or administrative cooperation;
(e) authorization for the trading of securities issued by the Company in any market, domestic or overseas;
(f) decision to cancel the registration as a publicly-held Company;
(g) incorporation, merger or spin-off involving the Company or affiliate companies;
(h) transformation or winding-up of the Company;
(i) change in the company`s shareholders` equity structure;
(j) change in accounting criteria;
(k) renegotiation of debt;
(l) approval of a stock option plan;
(m) change in the rights and advantages of the securities issued by the Company;
(n) split or grouping of shares or granting of share bonuses;
(o) acquisition of the Company`s shares to be held in treasury or cancellation and sale of shares then acquired;
(p) Company`s profit or loss and attribution of cash dividends;
(q) Execution or extinguishment of agreement, or failure in its performance, when the expectation thereof is of public knowledge;
(r) Approval, change or discontinuance of project or delay in its implementation;
(s) Initiation, re-initiation, or interruption of the manufacturing or commercialization of a product or service;
(t) Discovery, change or development of technology or resources owned by the Company;
(u) Change in projections disclosed by the Company;
(v) Filing for composition with creditors, petition for or confession of bankruptcy or the filing of a lawsuit, which may affect the Company`s economic-financial condition;
8 - Appendix III
Manual for Policy on Disclosure, Use of Relevant Information, and Trading of Securities issued by Randon S.A.- Implementos e Participações.
Model of Trading Report of Securities issued by Randon S.A.- Implementos e Participações.
Administrators, Audit Officers and Related Persons - Article 11 - CVM 358/2002 Directive
On ............/........ (date)
( ) only the following operations with securities and derivatives have been performed, according to Article 11 of CVM 358/2002 Directive.
( ) operations with securities and derivatives have not been performed, according to Article 11 of CVM/368/2002 Directive. My current position of securities and derivatives is as follows:
| Company`s Name: | |||||
| Name: | CPF/CNPJ: | ||||
| Qualification: | |||||
| Initial Balance | |||||
| Security/ Derivative | Characteristics of Securities | Quantity | % of interest | ||
| Same Kind/Class | Total | ||||
| Final Balance | |||||
| Security/ Derivative | Characteristics of Securities | Quantity | % of interest | ||
| Same Kind/Class | Total | ||||
| Controlled Company`s Name: | |||||
| Name: | CPF/CNPJ: | ||||
| Qualification: | |||||
| Initial Balance | |||||
| Security/ Derivative | Characteristics of Securities | Quantity | % of interest | ||
| Same Kind/Class | Total | ||||
| Final Balance | |||||
| Security/ Derivative | Characteristics of Securities | Quantity | % of interest | ||
| Same Kind/Class | Total | ||||
9 - Appendix IV
Manual for Policy on Disclosure, Use of Relevant Information, and Trading of Securities issued by Randon S.A.- Implementos e Participações.
To
Randon S.A. Implementos e Participações
Attn: Investor Relations Director
Individual Investment Program for Securities issued by
Randon S.A. Implementos e Participações
By means of this Individual Investment Program, ruled by the Trading Policy of Securities issued by Randon S.A.- Implementos e Participações (the Company), I hereby commit to invest or disinvest Securities of the Company in compliance with the applicable legislation and laws provided in said Trading Policy, and also with the following conditions:
| Nature of Operations: | ( ) Investment/Purchase | ( ) Disinvestment/Sale |
| Identification of the Related Persons: |
|
|
| Securities Brokers mediating the Operation: | ||
| Program Validity Term (no shorter than 12 months): | ||
| Quantity of securities to be traded or monetary amounts involved, and respective dates: | ||
| Additional Information: | ||
By adhering to/ signing this Program, I hereby commit to:
(a) acting in compliance with the rules of the Program on an irrevocable and unchangeable manner, except for justified and legitimate reasons;
(b) following the provisions of CVM 358 Directive, of January 3, 2002, as amended;
(d) in case of investments, not selling the Securities acquired through this Program for a minimum term of 6 (six) months) from the date of acquisition, except for force majeure reasons; and
(e) within the period of 5 (Five) days from the end of the month in which the acquisition or sale of securities occurred, providing information to the Company, as foreseen in the Information Disclosure Policy.
Caxias do Sul, [complete date].
[name and signature]