SulAmérica

Internal Audit

The purpose of the internal audit is to assess the adequacy and efficiency of the structure, processing and control of the Company’s products and services, making recommendations and monitoring their implementation as part of risk management.

In addition, the internal audit sets forth mechanisms to minimize legal and regulatory sanctions, financial losses or image risk by creating a robust culture of controls, compliance with standards, good market practices and integrated risk management, in addition to developing preventive measures to fight fraud.

The Company’s Compliance Code is the main tool used by the internal audit.

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Internal Controls and Compliance

SulAmérica disseminates the culture of controls, focusing on ethical principles and strict compliance with the law. Each company employee is a control agent responsible for maintaining internal controls and contributing to their enhancement, always taking into account costs and advantages involved, critical aspects, risks, and possible weaknesses of the processes in their areas.

Since 2004, the Company has been implementing a broad program seeking to ensure compliance with the laws and regulations applicable to the Company‘s activities as well as with internal codes and standards. The Compliance Code is part of this program and comprises the guidelines that must be followed by Company managers and employees in the performance of their duties, in accordance with the term of adhesion they signed. It also highlights the ethical principles and standards of conduct to be adopted.

Moreover, SulAmérica develops campaigns, training sessions, events and workshops aimed at its clients, brokers, partners and employees, so as to strengthen the fraud prevention culture.

The Company also has a communication channel for recording situations that violate the guidelines of the Legal Compliance Program through which messages may be sent to the Compliance, Internal Audit and Fraud Prevention areas.

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Ombudsman’s Office

The Ombudsman’s Office, created in January of 2005, operates in accordance with SulAmérica’s values, arbitrating conflicts between consumers and the Company. The Ombudsman’s Office not only takes into account the rights of customers in the way it operates, but also aims to clarify customers’ duties, seeking the improvement of processes and products by analyzing cases received, thus reducing the risk of losses arising from lawsuits from SUSEP (Superintendence of Private Insurance), BACEN (Central Bank of Brazil), CVM (Brazilian Securities and Exchange Commission), ANS (National Agency for Supplementary Healthcare) or legal actions.

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External Audit

KPMG is the independent auditing company engaged by SulAmérica to render external audit services related to the examination of the financial statements.