Compliance

Program

Get inspired01.

The Program is ours02.

The role of each one03.

Get to Know

the ProgramMonitoring the Program04.

01.

Get Inspired

Compliance Programs have the purpose of

disseminating guidelines to achieve the state of

compliance and business sustainability, making it

possible to increase the prevention of illicit acts,

reduction of financial losses and damage to the

reputation of the institution.

In the financial system, clients and investors have become

concerned about issues related to the reputation and

sustainability of the companies that manage their assets.

These entities need to dedicate greater attention to compliance

with the requirements imposed by the regulatory environment

and to the development of policies to guide and demand ethical

and responsible conduct from their members.

Such Programs establish guidelines for prevention, detection

and correction of practices that are either inappropriate or in

conflict with laws, norms and external and internal regulations,

gaining relevance as an instrument of corporate governance.

ComplianceIs to comply with laws and external and internal regulations

Compliance is a responsibility of all

employees, interns, service providers and

suppliers of the Bank, regardless of their

function . After all, they are the primary

responsible for conducting their processes,

controls and risks.

Compliance

Being in compliance is the act of obeying

the laws, regulations, norms, policies and

procedures, adding to this concept

principles of integrity, ethical conduct, and

even efficiency.

A responsibility

of everyone

The Compliance

Program

The Compliance Program involves the whole

Bank in the mission of ensuring effective

compliance risk management and strengthening

the internal control system, contributing to:

risk mitigation in business

dissemination of the a culture of

internal controls and compliance

inhibition of illicit acts

reduction of financial losses

reputation damage prevention

The Program is aimed at all employees and third parties

that provide services of a permanent, temporary,

exceptional or occasional nature to the Bank.

It also applies to units located abroad, in accordance with

their local laws and international good practices.

It is aligned with the Corporate Strategy, reflecting the

purpose, values and vision shared among the people who

make Banco do Brasil.

Corporate

Strategy

Banco do Brasil

Corporate

Strategy

Banco do Brasil

Strategic Planning is a systematic process in which strategic

guidance is established, that is, the direction to be followed by

Banco do Brasil and it’s Affiliated Entities (ELBBs), seeking better

direction of efforts and allocation of organizational resources.

At Banco do Brasil, the current Corporate Strategy defines the

Strategic Objectives to be pursued by the Organization for the

2018-2022 time horizon, as well as the Macro Ambitions of the

Bank in relation to the Strategic Segments in which the ELBBs

operate. The Corporate Strategy is divided into the Master Plan, the

Market Plan, the Performance Agreements of the Units, and the

Planning of the Strategic Units, providing the alignment and

engagement of the entire Institution to achieve sustainable

results.

PurposeCaring for what people value

Values

Customer FocusInnovationEthicsEfficiencyPublic spiritedReliabilityOwner's sense

Vision

Be the company that provides thebest experiencefor the lives ofpeople and promotesthe developmentof society, in an innovative, efficient andsustainable way.

Purpose, Values and Vision are the elements that inspire and

provide consistency for the company's performance. This is how we

define ourselves, that is how we are, how we wish to be perceived.

And so are we committed to:

Respect all laws related to our business withparticular focus on the sustainability ofoperational and management processes;

Maintain responsible and ethical businessconduct, contributing to the integrity of thenational financial system;

Require of all employees and partners that they ensure compliance with regulations;

Valuing good practices, not toleratingmisconduct and non-compliance with legalobligations or internal rules.

“Banco do Brasil has a

transforming role for people,

for society and for the country”Our commitment

Remember that the Code of Ethics and the

Standards of Conduct must always be respectedin your day-to-day actions and decisions and should alsoserve as a reference for our employees, service providersand suppliers.

02.

The program

is ours

The Compliance Program gives the Bank the

credibility it needs to demonstrate its ethical

positioning and responsible and sustainable

practices in the conduct of its business.

It is composed of integrated and complementary

guiding principles that drive the Bank's

operational activities and business practices,

supported by the pillars of prevention,

detection and correction of deviations from

external and internal laws, rules and regulations

and the Code of Ethics and Standards of

Conduct.

The pillars are supported by a solid base formed

by the culture of Internal Controls and

Compliance, Ethics and Corporate Governance.

The Compliance Program belongs to all of us

Compliance Program

Banco do Brasil

I - Top Management Support – tone from the top

II - Risk assessment

III - Code of Ethics, Standards of Conduct and Compliance Policy

IV - Training and communication

V - Regulatory monitoring

VI - Due Dilligence

VII - Internal controls

VIII – Reporting Channel

IX - Internal investigations and

consequence management

Prevention Detection Correction

Culture of Internal Controls and ComplianceEthics and Corporate Governance

The Compliance Program is sponsored by the Senior

Management, which seeks always to be prepared for the

challenge of inserting the culture of internal controls and

compliance into the day to day work, and of being seen as

an integral part of and partner of the business.

The Senior Management of Banco do Brasil, composed of

the Board of Directors and Executive Board, approved the

implementation of this program, ensuring that the directors

participate actively, aiming to maintain alignment to the

organization's direction, greater operational safety and

greater confidence to investors, suppliers and customers .

Support from

The Top

Knowing the vulnerabilities, risks and

objectives of the company is fundamental to

structuring an assertive assessment,

combining the probability of occurrence and the

impacts that such events would have if they

were observed.

Banco do Brasil has a risk management

structure that aims to identify, evaluate and

measure, control, mitigate, monitor and

report risks, contributing to the maintenance of

the organization's solidity.

Risk

Assessment

The compliance area assists

managers in managing compliance

risk, which can be defined as the

possibility of financial loss or

reputation loss from non-compliance

with applicable laws, regulations,

internal standards, codes of conduct

and guidelines for the business and

activities of the organization.

Risk is the possibility that the outcome of a particular event may be different from the expected result, negatively impacting the company's intention to achieve previously established goals.

The other risks have their own and integrated

governance structure.

The Code of Ethics and the

Standards of Conduct of Banco do

Brasil establish the values and

determine the standard of behavior

that is expected of its functional staff.

They present the commitments and

the guidelines regarding their related

public, duties and behaviors

expected in the work environment.

*The Code of Ethics and the Conduct Standards and the other documents that deal with integrity in business are available in the corporate intranet and also in the internet:

https://dipes02.bb.com.br/pessoas/area.xhtml?area.id=6#!

http://www.bb.com.br/pbb/pagina-inicial/sobre-nos/etica-e-integridade/#/

*The Subsidiaries, Affiliates and Holdings may define their guidelines based on these guidelines, taking into account the specific needs and legal and regulatory aspects to which they are subject.

Code of ethics,

Standards of Conductand Compliance Policy

These instruments reflect the

company's position, are linked to

the various issues related to

conducting business, guiding its

employees along the path of

ethical and legal practices.

The Internal Controls and Compliance

Policy is part of good governance and

aims to establish principles and

guidelines to be observed to ensure the

strengthening of the internal control

system, compliance with compliance

obligations and the effectiveness of

compliance risk management.

Training programs and communication actions are critical to promoting Compliance culture. The

definition of a strategy for elaboration of training and communication plan facilitates the chain and

multiplication of knowledge.

The Bank has carried out training actions, aiming at promoting the training, updating and

specialization of its employees, in matters related to internal controls and compliance, risk

management, safety and other compliance functions.

The communication actions aim to reinforce the issues here addressed, disseminating to all

employees aspects regarding norms and procedures, general and specific policies, using all

available channels.

Training and Communication

The regulatory environment delimits the performance of

companies in conducting business by establishing

restrictions - laws, standards, regulations and rules. Such

restrictions lead to the need to create, modify or adjust

internal processes in order to adapt to the requirements

imposed by this environment, avoiding losses due to fines

and penalties and damage to reputation.

Monitoring

Regulatory

The identification of laws, regulations and standards in the

Bank is carried out in a decentralized manner by process,

product and service managers, within their scope of action,

being also in charge of internalization, publication and

periodic review. It is up to these managers to assess the

compliance status of their processes, products and

services, based on the analysis of related laws,

regulations and rules, promoting the necessary

adjustments in their internal policies and procedures.

Due

Diligence

The administrative and civil liability of legal entities for acts against national or foreign public administration,

imposed by the Anti-Corruption Law (12,846 / 2013), led companies to review their internal processes to

foresee anti-corruption measures, as well as to monitor third parties with which they have contractual

relationship, due to the concept of co-responsibility.

Thus, Due Diligence of third parties becomes an increasingly necessary and relevant practice to minimize

the risks of various kinds, inherent to business with companies and contractors.

Due Diligence – refers to the process of investigation, evaluation and analysis for accepting the risks of commercial transactions, being used in the creation of commercial partnerships and contracting suppliers.

These are processes and practices whereby organizations seek to

ensure that all planned and approved actions are carried out

properly, in order to safeguard assets, the accuracy and reliability of

management information and financial records, the promotion of

operational efficiency and adherence to organization´s policies. Its

purpose is to contribute to achieving the company’s strategic

objectives and its continuing corporate presence.

Internal

Controls

Banco do Brasil has an Internal Control System suitable to its

size and complexity, meeting regulatory requirements and in

line with best governance practices.

They allow employees (domestic and overseas), interns,

apprentices, third parties and business partners, a way to alert

the company, even anonymously, to potential violations of the

Code of Ethics and Standards of Conduct and other policies.

The Complaints channels of Banco do Brasil are easy to

access and are designed to capture and analyze information

received. They are recognized for their credibility and

commitment to protecting the identity of the source and

confidentiality of information.

Reporting

Channel

Reports about behavioral deviations and noncompliance with

internal rules should be sent to our Internal Ombudsman.

Any suspected harmful act that might be defined or described

as corruption should be referred to the “Canal de Denúncia de

Ilícitos”.

• Internal Ombudsman - (061) 3108-7488

ouvidoriainterna@bb.com.br

External Ombudsman - 0800 729 5678

0800 729 0088 For the hearing or speech impairedouvidoria@bb.com.br

Reporting Channel - Portal BB (Atendimento > Reclamaçõese denúncias > Canal de Denúncia de Ilícitos)

Internal Investigations

and Consequences Management

The management should be carried out in an independent

and confidential manner, and the inquiry must be carried out

in a professional and impartial manner, using appropriate

investigative mechanisms.

Banco do Brasil has rules, specific procedures and

defined workflow for the investigation process and

determination of responsibility and disciplinary

control, in a segregated, autonomous and impartial

way.

Non-compliance with the guidelines of the Code of

Ethics and the Standards of Conduct may result in

sanctions, depending on the severity of the

occurrence, its circumstances and the level of

participation of each party involved.

Consequence management requires methodology and

intelligence, with an impersonal process and focus on

establishing the truth.

Banco do Brasil has established an

Integrity Program which provides

for a set of internal mechanisms

and procedures, an incentive to

report irregularities and to

implement the code of ethics and

standards of conduct, with a focus

on anti-corruption measures.

Integrity

Program

Access the Integrity Program

03.

The role of

each one

The role of the Top Management

Maintain proper conduct and ethical attitude, adhering to the Code of Ethics and the Standards of Conduct.

Ensure compliance within the governance of the organization.

Oversee reports concerning the compliance status of the organization, as well as the Compliance Program monitoring and take actions needed to maintain compliance.

Disseminate the culture of internal controls and compliance and promote this program to employees.

Top Management approves and

supports the Compliance Program

Important actions to be taken by the leadership of the Banco

do Brasil:

Ensure adherence to compliance policy

Promote environment control management in his/her team

Encourage the debate on the Compliance Program among the team so as to clarify employee doubts and reinforce the importance of knowing all the guidelines

Protect team members against retaliation due to reports of violations

Ensure that staff members are properly trained in their areas of practice, and encourage training in

internal controls and compliance.

Leadership

Role

Each manager is responsible for

ensuring that all legal obligations

governing their activities are complied

with, which may include identifying,

reporting and managing any breach of

compliance.

It should be an example of good

conduct, to encourage and value such

behavior in his team, ensuring that

everyone conducts their activities

ethically, always in compliance with laws

and regulations.

All

employees’

RoleKnow and comply with the Code of Ethics,

the Standards of Conduct and the

Integrity Program of Banco do Brasil.

Ensure compliance in the conduct of work

activities, observing the responsibilities

assigned to his/her role.

Obey the laws, regulations and internal

rules of the Bank.

Prevent, when detected, the practice of acts

not tolerated in this Program and report any

breach of compliance.

Be an example of ethical conduct

Be Compliant

To act as a compliance agent, contributing to the

dissemination of the culture of internal controls and

compliance in the organization.

04.

Program

Monitoring

The Compliance Program is periodically

monitored by Top Management with the purpose

of evaluating the compliance status of the

guidelines.

Monitoring

the Compliance Program

As of 8 May, 2019Internal Controls Board

controlesinternos@bb.com.br