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Join the Fight against Financial Crime and legal/ regulatory and internal Breaches!

The economic damage caused by financial criminal activities (for example fraud, theft, embezzlement, corruption) and other internal or legal/ regulatory misbehavior is constantly increasing. Along with immediate material losses, damage to the reputation can in extreme cases also threaten a company's existence and endanger jobs.

Commerzbank Brasil S.A. – Banco Múltiplo committed itself to fight such misbehavior. With regard to prevention and prosecution of such activities we depend on your assistance. In many cases reports from employees, clients or third parties have revealed such incidents and initiated an investigation and prosecution of these activities.

We therefore decided to introduce a standardised notification system in addition to the existing communication channels, for example via superiors, internal Audit or Compliance. The BKMS^® System (Business Keeper Monitoring System) is an internet based application, which enables employees, clients and third parties to report financial criminal activities and unlawful / company damaging misbehavior (in favor of or against the bank) by name or anonymously out of ethical responsibility or moral conflict at any time of day.

Commerzbank Brasil S.A. – Banco Múltiplo has set up the BKMS^® System to receive reports on financial criminal activities and breaches of legal, regulatory and internal requirements. Reports outside of this focus will not be handled by this system. The BKMS^® System is not an emergency system (see also “What reports should be submitted via the system?”).

This system must not be abused by consciously submitting false or defamatory reports or information. Reports that are intended to denounce or defame other people against one's own better knowledge, will not be tolerated and may have personal consequences or may be prosecuted as a criminal offense.

We value an open communication with our clients and employees and we therefore would like to encourage you to submit your report under your name. Regardless of this we would like to ask you to set up a secured postbox in the system. This will support communication and handling of your submitted report. Your information will be handled strictly confidential.

You can of course also submit your information by written letter to the address or fax number mentioned below.

Please note: that you can only use the BKMS^®-Portal on this internet webpage to submit reports for the below mentioned entity. For reports that concern other Commerzbank Group entities, subsidiaries or other international branches, please use the relevant BKMS^®-Portal on the entity´s internet site or the links as listed on the Commerzbank Group internet site.

Why should I submit a report?: Why should I submit a report?

A positive and honest corporate culture of course requires the observance of legal, regulatory and internal guidelines.

You may have potential information about financial criminal activities or breaches of the before mentioned guidelines that could damage our company and in extreme cases could threaten our existence. With the submission of your report, you can contribute to reveal those activities and prevent potential financial loss and material reputational damage.

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What reports should be submitted via the system?: What reports should be submitted via the system?

Besides financial criminal activities all breaches of legal, regulatory or internal requirements/rules connected to Commerzbank should be reported.

For claims or complaints, our Quality Management Department will offer assistance.

The BKMS^® System is not an emergency system. For an emergency blocking or loss report, please refer to the published official hotlines, mailboxes or contacts.

Further information about the above mentioned possible reporting topics will be provided in the course of the reporting process.

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How does an anonymous report work and how can I set up a postbox?: How does an anonymous report work and how can I set up a postbox?

First of all you will be asked to read an informatory text about the protection of your anonymity (as long as you wish for this) and you will also be requested to answer a security check.

On the following pages you will be asked about the focus of your report as well as about various details. On the report page you need to formulate your report in your own words and answer questions about the case. You are provided with 5000 characters for your personal text, which relates to a full A4 sheet of paper. To support your report you may also upload small data of up to 5MB. Please be aware that documents may contain information about the author.

After sending your report you will receive a reference number which serves as proof that you have sent it. Finally after this you can than set up your own secured “Postbox.” This can then be used to receive feed-back, to answer questions by the person processing the report and this is also how you will be informed about the processing of your information.

Should you already have a secured postbox in the BKMS^® System, you can go straight to your postbox via the “Login” button. You will also need to answer the security check and then you can register with the system.

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How can I receive feedback and yet still remain anonymous?: How can I receive feedback and yet still remain anonymous?

You will receive feedback about the processing of your information from Commerzbank Brasil S.A. – Banco Múltiplo via the secured postbox. The entire correspondence about your report will be directed via this postbox. If you desire you may also remain anonymous throughout this dialogue.

The uppermost priority of the BKMS^® System is the protection of the person placing the report. By setting up your secured postbox you can select your own alias and password. Your report will be kept anonymous by means of encryption and other special security technology. You will not be asked to submit personal information at any point in the reporting process.

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