financial investment policy - bm&f bovespair.bmfbovespa.com.br/fck_temp/26_129/file/financial...

FINANCIAL INVESTMENT POLICY


Public Use

October, 11 2016

This document is a free translation of the official Policy “Política de Aplicações Financeiras.”

http://www.bmfbovespa.com.br/produtos









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2 October, 11 2016


TABLE OF CONTENTS

1 PURPOSE ................................................................................................... 4

2 GUIDELINES ............................................................................................... 4

3 SCOPE, EXCEPCTIONS, PROHIBITIONS AND GENERAL

CONSIDERATIONS..................................................................................... 4

3.1 Scope ................................................................................................ 4

3.2 Exceptions ......................................................................................... 5

3.3 Prohibitions ........................................................................................ 6

3.4 General Considerations ..................................................................... 7

4 DEFINITIONS .............................................................................................. 8

4.1 Third-Party Funds, BM&FBOVESPA’s Own Funds, Own

Funds of Subsidiaries and Affiliates, in Brazil and Abroad ................ 8

4.2 Authorized Assets .............................................................................. 9

4.3 Derivatives ....................................................................................... 10

4.4 Liquidity ........................................................................................... 10

4.5 Rating .............................................................................................. 10

4.6 Modified Duration ............................................................................ 10

4.7 Authorized Institutions and Sovereign Issuers ................................. 11

4.8 Nature of Return on Investment ...................................................... 11

4.9 Authorized Private Credit Securities ................................................ 11

5 ALLOCATION LIMITS (ANNEXES I AND II) ............................................ 12

5.1 Third-Party Funds in Brazil .............................................................. 12

5.2 Third-Party Funds Abroad ............................................................... 12

5.3 BM&FBOVESPA’s Own Funds in Brazil .......................................... 12

5.4 BM&FBOVESPA’s Own Funds Abroad ........................................... 13

5.5 Own Funds of Subsidiaries and Affiliates in Brazil ........................... 13

5.6 Own Funds of Subsidiaries and Affiliates Abroad ............................ 14

6 RESPONSIBILITIES .................................................................................. 14

6.1 Board of Directors ............................................................................ 14

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6.2 Executive Board .............................................................................. 14

6.3 Chief Financial and Investor Relations Officer ................................. 15

7 CONTROL INFORMATION ....................................................................... 15

Validity ............................................................................................................ 15

1st version: ..................................................................................................... 15

Areas responsible for this document: .......................................................... 15

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1 PURPOSE

The purpose of this Financial Investment Policy (“Policy”) is to establish

principles, guidelines and responsibilities to be observed in managing the

financial investments of BM&FBOVESPA, its subsidiaries and affiliates.

2 GUIDELINES

This Policy has the following guidelines:

a. Guarantee maintenance of the adequate level and availability of liquidity

in financial investments;

b. Limit exposure to market, credit, liquidity and operational risks in

financial investments, assuring capital preservation;

c. Guarantee the sustainability of the business through efficient

management and adequate returns on capital;

d. Avoid speculative exposure to exchange-rate risk in financial

investments.1

3 SCOPE, EXCEPTIONS, PROHIBITIONS AND GENERAL

CONSIDERATIONS

3.1 Scope

a. The Policy applies to BM&FBOVESPA S.A. – Bolsa de Valores

Mercadorias e Futuros (“BM&FBOVESPA”) and its subsidiaries and

affiliates in Brazil and abroad.

b. At this time the subsidiaries and affiliates covered by this Policy are as

follows:

1 For the purposes of this Policy, third-party funds deposited in foreign currency do not represent exposure to

exchange-rate risk, since assets are matched by equivalent liabilities in this case.

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Subsidiaries in Brazil and abroad

Rio de Janeiro Stock Exchange (BVRJ)

BM&FBOVESPA UK

BM&FBOVESPA USA Inc.

Affiliates in Brazil

Associação Bovespa

Associação BM&F

Associação Profissionalizante BM&FBOVESPA

Clube de Atletismo BM&FBOVESPA

Fundo de Garantia da Bolsa de Valores do Rio de Janeiro

Instituto BM&FBOVESPA

c. The Policy will apply automatically to new subsidiaries and affiliates of

BM&FBOVESPA, unless the Board of Directors decides otherwise when

such companies or entities are constituted or invested in.

3.2 Exceptions

a. In light of the operational, administrative and financial autonomy

required by the applicable regulatory framework, BM&FBOVESPA

Market Supervision (“BSM”) and the Loss Recovery Mechanism (“MRP”)

may establish their own policies or formally request operational support

from BM&FBOVESPA for the management of their financial

investments. In the latter case, BM&FBOVESPA will adopt this Policy for

said entities and apply the limits set for BM&FBOVESPA’s Own Funds

in Brazil in the case of BSM and Third-Party Funds in Brazil for MRP.

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b. In light of the operational, administrative and financial autonomy

required by the applicable regulatory framework, this Policy does not

apply to BM&FBOVESPA Bank.

c. Equity investments deriving from strategic partnerships are not

considered financial investments for the purposes of this Policy. Thus

the shares issued by companies, or any financial instruments

purchased by BM&FBOVESPA as a consequence of such investments,

including derivatives, are not covered by this Policy.

d. The position in BVMF3 shares currently held by Associação Bovespa is

hereby authorized as an exception and hence not covered by this Policy.

e. Non-interest-bearing demand deposits in domestic bank accounts linked

to garnishment in the Central Securities Depository of dividend payouts

and other earnings approved by issuers, surplus cash not suitable for

financial investment in time and funds held in investment funds’ bank

accounts are hereby authorized as exceptions and hence not covered

by this Policy.

f. Investment in equities and commodities is permitted only to discharge

specific clearinghouse obligations, comply with court orders, or hedge

liabilities and contingent liabilities against market fluctuations.

3.3 Prohibitions

a. BM&FBOVESPA, its subsidiaries and affiliates either individually or in

aggregate must not hold more than 20% of any issue of federal

government debt securities or Brazilian global bonds, considering all

their financial investments in Brazil and abroad.

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b. Derivatives may be used to hedge only spot positions.2 Directional

positions and leveraged transactions are prohibited.

c. Investment is prohibited in restricted certificates of deposit (CDs),

corporate debentures and any other asset with final credit risk not linked

to an Authorized Institution in Brazil, a Foreign Authorized Institution or

an Authorized Sovereign Issuer.

d. Purchase of private credit securities is prohibited for BM&FBOVESPA.

e. Subsidiaries and Foreign Affiliates that invest in Authorized Private

Credit Securities must not hold, either individually or in aggregate, more

than 20% of any issue of Authorized Private Credit Securities by a

Foreign Authorized Institution, considering all their foreign investments

of Own Funds and Third-Party Funds.3

3.4 General Considerations

a. Investment in investment funds is authorized but only in funds that hold

in their portfolios securities defined as Authorized Assets in this Policy.

The managers, administrators and custodians of these funds must be

Authorized Institutions in Brazil or Foreign Authorized Institutions.

b. For the purposes of calculating compliance with the allocation limits

established in item 5, synthetic transactions (underlying asset combined

with Derivatives Used for Hedging) will be scored in accordance with

their final risk factor.

c. Involuntary non-compliance with regard to the Ratings of Authorized

Institutions in Brazil, Foreign Authorized Institutions and Authorized

Sovereign Issuers resulting from a change in Rating will be tolerated for

2 For the purposes of this Policy, hedging of spot positions includes hedging of proprietary positions and positions originating in derivatives (fixed rate vs DI futures). 3 Applies to publicly issued private credit securities.

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8 October, 11 2016


up to 60 days of the date on which the Rating change is announced,

without characterizing infringement of this Policy.

d. If the Rating of an Authorized Institution in Brazil, a Foreign Authorized

Institution or an Authorized Sovereign Issuer is downgraded because

Brazil’s sovereign rating is downgraded, the resulting involuntary non-

compliance will be tolerated for up to 120 days, within which timeframe

the Policy must be taken before the Board of Directors so that the

classification of acceptable risks can be reconsidered.

e. The Financial & Risk Committee must be informed if any allocation limit

set in accordance with this Policy is breached.

4 DEFINITIONS

4.1 Third-Party Funds, BM&FBOVESPA’s Own Funds and Own Funds of

Subsidiaries and Affiliates, in Brazil and Abroad

a. Third-Party Funds in Brazil: sum of the funds deposited in cash with

clearinghouses as collateral, non-interest-bearing demand deposits in

domestic bank accounts linked to garnishment in the Central Securities

Depository of dividend payouts and other earnings approved by issuers,

and earnings awaiting transfer under BM&FBOVESPA’s management.

b. Third-Party Funds Abroad: sum of the funds deposited in cash with

clearinghouses as collateral and transfers of earnings abroad, under

BM&FBOVESPA’s management.4

c. BM&FBOVESPA’s Own Funds in Brazil: funds belonging to

BM&FBOVESPA held in Brazil (i.e. excluding Third-Party Funds).

d. BM&FBOVESPA’s Own Funds Abroad: funds belonging to

BM&FBOVESPA held abroad (i.e. excluding Third-Party Funds).

4 For the purposes of this Policy, third-party funds deposited in foreign currency do not entail exchange-rate exposure.

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e. Own Funds of Subsidiaries and Affiliates in Brazil: funds belonging

to Subsidiaries and Affiliates held in Brazil.

f. Own Funds of Subsidiaries and Affiliates Abroad: funds belonging to

Subsidiaries and Affiliates held abroad.

4.2 Authorized Assets

a. Authorized Assets for Third-Party Funds in Brazil: federal

government debt securities and repos in federal government debt

securities.

b. Authorized Assets for Third-Party Funds Abroad: demand deposits

(interest-bearing5 or non-interest-bearing).

c. Authorized Assets for BM&FBOVESPA’s Own Funds in Brazil:

federal government debt securities and repos in federal government

debt securities.

d. Authorized Assets for BM&FBOVESPA’s Own Funds Abroad:

demand deposits (interest-bearing or non-interest-bearing) and

sovereign bonds.

e. Authorized Assets for Own Funds of Subsidiaries and Affiliates in

Brazil: federal government debt securities, repos in federal government

debt securities and Authorized Private Credit Securities.

f. Authorized Assets for Own Funds of Subsidiaries and Affiliates

Abroad: demand deposits (interest-bearing or non-interest-bearing),

sovereign bonds and Authorized Private Credit Securities.

5 Financial investments in instruments such as Overnight Lending, Money Market Accounts, Interest-Bearing Accounts and Savings Accounts. Credit risk must be limited to the financial institution in which the funds are invested. Furthermore, the return on financial investments in interest-bearing or overnight accounts is deemed to be floating-rate.

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4.3 Derivatives

Derivatives are contracts traded on the exchange on over the counter solely to

hedge other assets in the Own Funds portfolio.

The value of a derivative is calculated in terms of the notional market value of

the position on the date of calculation.

The use of derivatives is limited to a % Derivatives Limit of 20%.

For the purposes of this Policy, the % Derivatives Limit is calculated as follows:

% Derivatives Limit = (Notional Value of Derivatives) / ((Total Own Funds

Portfolio excluding Notional Value of Derivatives))

4.4 Liquidity

Liquidity is the time in days required for funds not necessarily deposited in a

current account without restrictions on withdrawals to become available for

withdrawal.

4.5 Rating

The credit rating awarded by Standard & Poor’s Ratings Services (“S&P”) or the

credit rating awarded by Moody's Investors Service converted into its equivalent

on the scale used by S&P. For an entity rated by both, Rating shall mean the

lower of the two ratings.

4.6 Modified Duration

Modified Duration is the average weighted duration of a cash flow counted in

calendar days (“CD”), considering the opportunity cost of money and its present

value. For the purposes of calculating the Modified Duration of a portfolio of

financial investments, the Modified Duration of open investment funds and

Treasury bills (Letras Financeiras do Tesouro, LFTs) is deemed to be one day.

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4.7 Authorized Institutions and Sovereign Issuers

a. Authorized Institutions in Brazil: financial institutions whose senior

unsecured debt is rated br.AA- on S&P’s local scale or at least BB on

S&P’s global foreign currency scale.

b. Authorized Institutions Abroad: (i) subsidiaries and branches of

Authorized Institutions in Brazil whose senior unsecured debt is rated at

least BB on S&P’s global foreign currency scale, and (ii) financial

institutions whose senior unsecured debt is rated at least A- on S&P’s

global scale.

c. Authorized Sovereign Issuers: (i) in Brazil, the Federal Government

(Federal Debt Securities), and (ii) abroad, Brazil (Global Bonds) and the

following countries (G7): United States, United Kingdom, Germany,

Canada, Japan, France and Italy as long as the senior unsecured debts

of these G7 countries are rated at least A-.

4.8 Nature of Return on Investment

d. Floating-Rate Return: rate of return unknown at the time the investment

is made (e.g. interbank deposit rate (CDI), Selic, federal funds rate,

Libor, Euribor).

e. Fixed-Rate Return: rate of return agreed at the time the investment is

made.

f. Inflation Return: rate of return pegged to inflation.

g. Exchange-Rate Return: rate of return pegged to a different currency

from that in which the investment is denominated.

4.9 Authorized Private Credit Securities

Certificados de Depósito, Letras Financeiras, Depósito a Prazo com Garantia

Especial do FGC (“DPGE”), Certificates of Deposit, Notes, Bonds, other senior

debt securities issued by Authorized Institutions in Brazil and Foreign

Authorized Institutions, except restricted debt securities with different underlying

risk from the issuer’s, and repos in securities issued by leasing companies

provided these match the definition of an Authorized Institution.

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5 ALLOCATION LIMITS (ANNEXES I AND II)

5.1 Third-Party Funds in Brazil

h. Allocation of 100% to Authorized Assets for Third-Party Funds in Brazil,

always with Authorized Institutions in Brazil and Authorized Issuers as

counterparties;

i. Allocation of 100% to financial investments with Floating-Rate Return;

j. Financial investments must have immediate Liquidity (T0);

k. The portfolio of financial investments must have a Modified Duration of

between 1CD and 90CD.

5.2 Third-Party Funds Abroad

a. Allocation of 100% to Authorized Assets for Third-Party Funds in Brazil,

always with Foreign Authorized Institutions as counterparties;

b. Allocation of 100% to financial investments with Floating-Rate Return;

c. Financial investments must have immediate Liquidity (T0);

d. The portfolio of financial investments must have a Modified Duration of


5.3 BM&FBOVESPA’s Own Funds in Brazil

a. Allocation of 100% to Authorized Assets for BM&FBOVESPA’s Own

Funds in Brazil, in aggregate to federal government debt securities and

repos in federal government debt securities;

b. Allocation of between 85% and 100% to financial investments with

Floating-Rate Return; and between 0% and 15% to financial

investments with Fixed-Rate Return, Inflation Return or Exchange-Rate

Return;

c. Between 90% and 100% of financial investments must have immediate

Liquidity (T0); and between 0% and 10% of financial investments must

have Liquidity between T1 and T90;



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5.4 BM&FBOVESPA’s Own Funds Abroad

a. Allocation of 100% to Authorized Assets for BM&FBOVESPA’s Own

Funds Abroad, with between 85% and 100% in aggregate in demand

deposits (interest-bearing or non-interest-bearing); and between 0% and

15% in sovereign bonds;




Return;


Liquidity (T0); and between 0% and 10% of financial investments must



between 1CD and 90CD;

e. Between 0% and 15% of the sum of BM&FBOVESPA’s Own Funds in

Brazil and BM&FBOVESPA’s Own Funds Abroad (calculated in

Brazilian Real) must consist in aggregate of BM&FBOVESPA’s Own

Funds Abroad and BM&FBOVESPA’s Own Funds in Brazil with

Exchange-Rate Return.

5.5 Own Funds of Subsidiaries and Affiliates in Brazil

a. Allocation of 100% to Authorized Assets for Own Funds of Subsidiaries

and Affiliates in Brazil, with between 80% and 100% in aggregate in

federal government debt securities and repos in federal government

debt securities, and between 0% and 20% in Authorized Private Credit

Securities, always with Authorized Institutions in Brazil and Authorized

Issuers as counterparties;




Return;

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14 October, 11 2016



Liquidity (T0), and between 0% and 40% of financial investments must




5.6 Own Funds of Subsidiaries and Affiliates Abroad

a. Allocation of 100% to Authorized Assets for Own Funds of Subsidiaries

and Affiliates Abroad, in aggregate to demand deposits (interest-bearing

or non-interest-bearing), sovereign bonds and Authorized Private Credit

Securities, with Foreign Authorized Institutions in Brazil and Authorized

Issuers as counterparties;




Return;


Liquidity (T0), and between 0% and 40% of financial investments must




6 RESPONSIBILITIES

6.1 Board of Directors

i. Deciding on revisions to the Financial Investment Policy.

6.2 Executive Board

i. Analyzing the Financial Investment Policy and any revisions,

submitting to decisions of the Board of Directors;

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ii. Identifying risks preventively and risk management as needed,

evaluating the probability of their occurrence, and taking measures to

prevent and minimize them.

6.3 Chief Financial and Investor Relations Officer

i. Enforcing the Financial Investment Policy, managing

BM&FBOVESPA’s funds and those of its subsidiaries and affiliates;

ii. Regularly reviewing the suitability of the Financial Investment Policy

to the requirements of BM&FBOVESPA, its subsidiaries and

affiliates.

7 CONTROL INFORMATION

The above provisions apply immediately to the management of

BM&FBOVESPA’s financial investments and those of its subsidiaries and

affiliates.

Validity: From October 2016.

1st version: 08/20/2015

Areas responsible for this document:

Responsible for Área

Drafting Financial Working Group

Revision Executive Board

Approval Board of Directors

Change log:

Version Item changed Change Rationale Date

1 NA NA NA 08/20/2015

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2 4.7 (a) and (b) Amendment notes rating Decreased rating 10/01/2015

3 - Writing adjustments - 02/18/2016

4 3.2 (c) and 4.7 (a)

and (b) Writing adjustments and amendment notes rating

Decreased rating 23/09/2016


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Annex II

Subsidiaries and Related Entities

Brazil e Foreign

Authorized AssetsFixed Income and Deposit in cashNon-Interest-Bearing Deposits

Interest-Bearing Deposits

Privet Credit Securities Between 0% and 20%

International Sovereing Bonds Prohibited 0%

Federal Government Securities (FGS) N/A

Repos in FGS N/A

EquitiesStocks / Depositary Receipts Prohibited / Note 4 and 5 0% Prohibited 0%

CommoditiesCommodities (gold) Prohibited 0% Prohibited 0%

DerivativesDerivatives (hedge only) * Between 0% and 20% Between 0% and 20%

Nature of ReturnFloating-Rate Between 85% and 100% Between 85% and 100%

Fixed-Rate

Inflation

Exchange Rate

Equities Prohibited / Note 4 and 5 0% Prohibited 0%

Commodities (gold) Prohibited 0% Prohibited 0%

Modified DurationBetween 1CD and 180CD Between 1DC and 180DC 100% Between 1DC and 180DC 100%

Level of LiquidityLiquidity T0 Between / Note 4 and 5 60% and 100% Between 60% and 100%

Between T1 and T90 Between / Note 4 and 5 0% and 40% Between 0% and 40%

Concentration LevelSame Issue - Government Bonds Limited to 20% Limited to 20%

Same Issue - Private Bonds Limited to 20% Limited to 20%

Note 4 - The position in BVMF3 shares currently held by Associação Bovespa is hereby authorized as an exception and hence not covered by this Policy.

Note 5 - Investment in equities and commodities is permitted only to discharge specific clearinghouse obligations, comply with court orders, or hedge liabilities

and contingent liabilities against market fluctuations.

* Considers the total portfolio for calculation of the limit.

Note 3 - Non-interest-bearing demand deposits in domestic bank accounts linked to garnishment of dividend payouts and other earnings approved by issuers,

surplus cash not suitable for financial investment in time and funds held in investment fund's bank accounts are hereby authorized as exceptions and hence not

covered by this Policy.

Between 0% and 15% Between 0% and 15%

Between 80% and 100%

Policy Policy

See note 3 0%

Limited to 100%

Own Funds Own Funds

Brazil Foreign

financial investment policy - bm&f bovespair.bmfbovespa.com.br/fck_temp/26_129/file/financial...

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