FUTURUM CAPITAL GESTÃO DE ATIVOS LTDA. (“Futurum”) recognizes the importance of its partners, directors, employees, collaborators, administrators, and persons connected to them (“Members”) being able to manage and develop their own financial resources and the financial resources of their dependents through investment and short- and long-term strategies.
However, due to possible conflicts of interest inherent in our business and our industry, Futurum has implemented standards and limitations designed to minimize these conflicts and help ensure our focus on fulfilling our duties as fiduciary agents of our clients.
In general, the buying and selling of securities and other financial instruments by Members, for their own benefit, is permitted provided that it does not constitute: (i) use of inside information; (ii) conflict of interest; or (iii) negative interference in the performance of professional activities.
Futurum encourages personal investments in managed collective vehicles, such as investment funds.
Futurum believes in the importance of Members aligning their own personal interests with the interests of our clients. Consequently, Members are encouraged to invest in products recommended by Futurum, if available and when appropriate.
In addition to those listed in Futurum's other policies, set out below are the main requirements and restrictions applicable to personal trading by Members, by members of their immediate family and other financial dependents: (i) The Member must hold the securities for a minimum period of 14 calendar days from purchase, and may sell them only after the 15th day; and (ii) Futurum's Compliance Department has the authority to deny any personal trade by a Member if the security is included in, or is being considered for purchase or sale by, any of the funds under its management.
Futurum's Compliance Department, in cases where it deems there to be a well-founded suspicion of conduct inconsistent with what is provided for in this Policy, must submit the matter to management review so that the appropriate measures may be taken.
Members' applications and investments made for their own benefit in the financial market must be guided so as not to negatively interfere with the performance of professional activities. In addition, such investments must be fully segregated from transactions carried out in the name of Futurum, so as to avoid situations that may constitute conflicts of interest. Members may not, in any way, use information obtained as a result of their role as professionals at Futurum to obtain economic and/or financial advantages through investment or divestment in financial assets.
Members may not, moreover, encourage unauthorized third parties to acquire them, for their own benefit or that of third parties, by using inside information obtained as a result of their relationship with Futurum.
Whenever any conflict-of-interest situation is detected, even if only potential, Futurum Members are required not to carry out the transaction or to dispose of their personal investment position. In this case, they must immediately notify the Compliance Department in writing.
Members must inform the Compliance Department if they obtain any material non-public information related to one or more financial assets. In that case, the Compliance Officer will assess the need to classify such financial assets, as well as their issuers, as restricted. Material non-public information means any information that, if made public, could impact the market price of financial assets.
Members are prohibited from carrying out capital market transactions related to any financial asset classified as restricted, which shall be defined by the Compliance Department and made available for consultation by Members.
Members acknowledge and agree to submit, when requested, to the Compliance Department a report declaring their personal investments in shares, real estate funds, debentures, and other securities and financial instruments that are classified as restricted, in order to verify compliance with the principles established in this Policy.
Futurum Gestão will not actively manage its own resources; its cash will be used exclusively for the payment of expenses and distribution of profits to the partners, and will be invested exclusively in government bonds, third-party DI investment funds with daily liquidity, and bank certificates of deposit from first-tier banks.
This Policy, as well as other applicable provisions of Futurum's other codes and policies, especially the sections of the Code of Ethics relating to Conflict of Interest and Inside Information, must be observed by all Members.
Any questions or further clarification regarding the interpretation or application of the obligations and guidelines contained herein must be addressed to the Compliance Department.
This securities trading policy will be reviewed annually, or whenever necessary, by the Compliance Department of Futurum, whenever possible together with the securities portfolio manager, in order to remain up to date with legislation and best management practices
