I. Objective and Scope
The objective of this Activity Segregation Policy ("Policy") of FUTURUM CAPITAL GESTÃO DE ATIVOS LTDA., a Brazilian limited liability company headquartered in the City of São Paulo, State of São Paulo, at Rua Girassol, nº 1033, room 10, Vila Madalena, ZIP 05433-002, registered under CNPJ/ME nº 48.818.002/0001-19 ("Futurum" or "Company"), is to establish the rules governing the conduct of all employees, collaborators, and administrators of Futurum ("Members") regarding the segregation of the activities conducted by the Company.
All Members must act individually to ensure compliance with the provisions of this Policy, as well as other policies, manuals, and codes that govern the full functioning of Futurum.
II. Physical Segregation of Activities
Futurum has physical access control for employees to its premises, ensuring physical segregation between different areas and lines of business, especially between the area responsible for managing securities portfolios and the areas that carry out consulting activities on various business matters.
The physical segregation of these activities aims to prevent both Members' access to certain information that may lead to potential conflicts of interest and the leakage and disclosure of confidential information.
The different areas and lines of business of Futurum have access restrictions for Members, so they are only authorized to access the areas where their specific activities are carried out. Members' access to unauthorized areas is prohibited, unless:
(i) previously approved by the Compliance Department; and
(ii) a member of the Compliance Department accompanies the respective Member during access.
III. Systemic and Electronic Segregation
The virtual and physical files of the different areas and lines of business of Futurum are maintained in physical and virtual spaces with access restricted only to authorized Members, in order to:
(a) ensure the segregation of activities required by applicable regulation;
(b) prevent the dissemination of confidential information; and
(c) avoid conflicts of interest.
The systems used by Futurum do not allow Members from different areas to access information, messages, or files of other Members. There is a set of procedures and barriers to prevent the flow of confidential information between different areas and lines of business.
IV. Confidentiality
Members must always pay attention to the content of the information and files they access due to their professional duties and may not, in any way, transmit confidential information to other Members or third parties.
Files, documents, or confidential information must not be left in freely accessible areas, nor on work desks.
All files related to their respective areas must be saved in the area directories, which can only be accessed by Members who have the required authorization. Employee access to network directories will occur upon determination and approval by the Compliance Department.
V. Granting Access
For granting access, the criterion of "least privilege" will be adopted, according to which Members will only have access to the files, information, and resources strictly necessary for the development of their activities and contained in the directory of their respective area.
The tools, systems, and directories have the necessary access control, with established processes for the creation and recurring change of passwords, as well as means to ensure the security of these passwords (mechanisms that make it difficult to identify others' passwords).
VI. Responsibility
Each Member is responsible for knowing and following the guidelines and procedures set forth in this Policy. Each person in a supervisory role is also responsible for those under their supervision. The person responsible for the Compliance Department is responsible for monitoring and verifying compliance with the Company's policies and procedures. Non-compliance with the policies and procedures will be documented and reported to the head of the Compliance Department for corrective measures to be taken.
