The policy for the Management of Operational Risk, and Liquidity

PLEASE READ THESE TERMS CAREFULLY BEFORE ACCESSING THE SITE
Last updated on 10 March 2023
1. Purpose
This is the Policy for the Management of Operational Risk, and Liquidity risk (“Policy”) is intended to set out a basic guideline for the management of risk and liquidity in the market, aiming at compliance with the regulations in force and the applicable legislation, best practice in market, the protection of business communication, operational risk and liquidity risk of the Stregu incorporation LTDA. (“Stregu inc.”), in accordance with the regulations of the Central bank and the international best practices.
2. Scope
The Policy applies to all officers, employees and service providers of the Stregu, inc. The management of the risks that are inherent in the activity of the Stregu inc. and, therefore, it is the duty of all to comply with this Policy. It is up to the Administration, and for it to be determined, and the dissemination and implementation of the measures and procedures that will ensure that they define their directions based on the guidance provided in this privacy Policy, taking into account the specific needs and the laws and regulations to which they are subject.
3. Guidelines
3.1 Risk management

3.1.1 Failure protection, and security of sensitive information relating to the credentials of the end-users and with other information you exchange with the goal of making payment transactions;
3.1.2 Failure to identify and authenticate the end-user;
3.1.3 Failure of the authorization of the payment transaction;
3.1.4 internal Fraud;
3.1.5 Fraud, external
3.1.6 the Demands of a labor safety and disability in the workplace;
3.1.7 inappropriate Practices related to the end-users of products and services to the account;
3.1.8 Damage to the physical assets owned or used by the Stregu inc.;
3.1.9 events that could lead to the termination of the activities of the Stregu inc. in payment of, or discontinuation of the services, the payment for services provided.
3.1.10 the Flaws in the systems, processes, or information technology infrastructure;
3.1.11 the Flaws in the implementation, compliance with deadlines and the management of the activities engaged in arrangement of payment.

3.2. Liquidity risk

3.2.1. On the management of Liquidity Risk, the Stregu inc.:

3.2.1.1. Maintain a robust process to update all the levels of the liquid, covering the appropriate assumptions and financial projections for the future based on the budget, and update the forecast.

3.2.1.2. Upgrade your cash flow every day, aiming for at least the next hundred and eighty (180) days, in order to determine the expected levels of liquidity.

3.2.1.3. With respect to the goals of the liquidity of the investments set out in the in-house standard for Financial investments.

3.2.1.4. Evaluate your exposure to the risk in the goods and services in emerging and changing.

3.2.1.5. It displays information related to the Management of Liquidity Risk, the competent authorities of the framework of governance, risk management and the Stregu inc. for information, assessment, and recommendation, as well as to involve the Board of directors of the Executive committee and the Board of Directors in monitoring and decision-making related to the management of liquidity, and alert you with a notice of any possibility of a decrease in the levels of liquidity, which could have an impact on the fulfilment of the commitments and/or the business of the Company.

3.2.1.6. It maintains the Liquidity Contingency Plan up-to-date and approved by the instances of corporate governance, competent, and can be driven by means of the rules stated in the in-house standard for the Management of Liquidity Risk.

3.3. Market risk

3.3.1. On the management of Market Risk, the Stregu inc.:

3.3.1.1. Mitigate the foreign exchange risk resulting from transactions with the card held by foreigners in Brazil, and the creation of any liabilities in the currency of estrangeria is not linked to a derivative or other means of protection, by means of the operations of specific financial or recognition of assets in foreign currencies, which can meet the claims of liquidity as defined in the standard internal Financial assets that are equivalent to the exposure.

3.3.1.2. It uses derivative instruments solely to protect (Hedge) exhibits an effective, binding them, it is mandatory for the assets or liabilities are short, always in a non-rent-seeking.

3.3.1.3. Conducts regular follow-up to the mark-to-market of derivative instruments, as well as to reflect the necessary changes in the accounting records.

3.3.1.4. You submit to the non-trading derivatives for the evaluation of the accounting for its categorization as a Hedge Accounting, with the aim of reducing or eliminating the volatility occurred in the result of the accounting for the company.

3.3.1.5. Hire operations, finance, and fundraising with the aim to support the need for working capital, investment, and refinancing of existing debt. In their confines they are approved on an annual basis by the Board of Directors, as set forth in the articles of association of the Company.

3.3.1.6. Evaluate your exposure to the risk of the market both in products and services, or changes.

3.3.1.7. It displays information related to the Management of the public sector to the competent authorities in the framework of governance, risk management and the Stregu inc. for information, assessment, and recommendation, and it involves a Board of directors, and the Board of Directors in monitoring and decision-making related to the management of market risk that could have an impact on the fulfilment of the commitments and/or the business of the Company.
4. Exceptions
Those situations are the exception, not provided for in this Policy, shall be submitted to the Executive Board for discussion and later reported to the Risk Committee.
4. Exceptions
Those situations are the exception, not provided for in this Policy, shall be submitted to the Executive Board for discussion and later reported to the Risk Committee.
5. Responsibilities
Officers and employees involved in the process:
  • To ensure the separation and the definition of the functions, duties, responsibilities, and delegation of authority which underpin the effective management of the risks, liquidity, and the market.
  • Watch and see by the provisions of this policy and, if necessary, to trigger the areas involved in the process of consulting with situations that involve conflict with this privacy policy, or in case of any situations that may put the Company at risk.
The management of the Treasury:
  • To carry out and manage the financial assets of the Company, in accordance with the rules, signals, and the limits of the in-house standard for Financial investments.
  • Monitor the level of liquidity of the Company by ensuring the existence of resources and lines of credit, instant is sufficient to cover its financial obligations and the monitoring of the exposure to liquidity risk at different time horizons.
  • To monitor the change in the interest rate, exchange rate and other ratios of financial-linked financial instruments held by the Company.
  • Triggering a Liquidity Contingency Plan.
Board of directors, Risk, Compliance, and disease Prevention:
  • Moonitorar the alignment of the risk profile, the apetie risk, and the strategy of the company.
  • To identify, measure, monitor, control, or mitigate in an integrated way, the credit risk, and liquidity to the market.
  • Coordinate and execute all activities related to the assessment of the credit risk of covering the issuers of the card, and Subcredenciadores, taking into account the settings of the volume of the collateral, in addition to commercial establishments, with or without a sales recorded that operates with the product (ARV)
  • To monitor and manage the exposure to the credit risk of covering the issuers of the card, Subcredenciadores, business establishments, with or without sales, deferred;
  • To run the warranties, together with the public Legal entity, in the case of the default of the Issuers of the Card;
  • To operate in conjunction with the Superintendent's office of the Legal, along with the governor of the Card Issuers subject to the influence, in order to retrieve the values of inadimplidos.
  • To run the warranties, together with the Superintendent's office of the Legal, the Subcredenciadores in situations where there is no equity at all.
  • To manage exposure to risk, the liquidity of the Company and to monitor the existence of sufficient funds to cover its financial obligations and the monitoring of the exposure to liquidity risk at different time horizons.
  • To monitor the exposure to market risk by monitoring the change in the interest rate, exchange rate and other ratios of financial-linked financial instruments held by the Company.
  • To propose the methodologies, metrics, and controls related to the management of credit risk, and liquidity to the market.
  • Monitor and report on instances of governance, risk management and the Stregu inc. all indicators and limits the exposure to credit risk, liquidity in the market.
  • To assess the exposure to credit risk, liquidity, and market new products and services, or changes.
  • Prepare, review, and request for the activation of the contingency plan of the facility.
  • Develop an annual report on the management of financial risks, and put them on the agenda briefing to the Committee on the Risks and the Board of Directors.
The management of the Engineering Department, and the bill to:
  • To carry out the procedures for the collection and recovery of a loan to a business have debts that out in the open, with the Stregu inc. (debt).
Oversight of Legal and Government affairs:
  • To perform the extra-and for the judicial guarantees in the event of the default of the Issuers of the Card, after the firing of the Board of directors of the Risk and Compliance committee;
  • To operate in conjunction with the Board of directors of the Risk and Compliance department, with the governor of the Issuers of the Card is subject to the influence, in order to retrieve the values of inadimplidos.
  • To perform extra-legal benefits of Subcredenciadores, after the firing of the Board of directors, Risk, and Compliance, in situations such as lack of liquidity.
7. General Provisions
It is the responsibility of the Board of Directors of the Company to make changes to this policy, whenever you need it.
This policy is effective as of the date of approval by the Board of Directors, and to revoke any documentation to the contrary.