Privacy

IIS (Itaú International Securities) Customer Identification Program

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We will also ask to see your driver’s license, passport or other government issued identifying documents.

If you are a business, we will ask for your business name, a street address and a tax identification number. We will also ask to see government issued documents that will allow us to establish your existence.

Because of the activities of money launderers and terrorists, federal regulations have also required broker dealers to develop, implement and enhance procedures for knowing all their customers. Pursuant to those requirements, all accounts at IIS are subject to daily review (by computer as well as manually) to identify transactions that have incomplete information or fall within a category that the government has described as unusual or suspicious. In order to ensure compliance with the law, we must ask you questions regarding your occupation and nature of business and the expected activity through your account. Additionally, we may need to ask questions about transactions through your account, which often turn out to be innocent. We hope that you will understand the situation by being cooperative if and when we ask questions concerning your transactions – it is the only way we can comply with the law.

September 11, 2001 has changed much of how we live our lives and do business. We at IIS value your account and the business you do with us and we hope you understand that these procedures are designed to protect all of us.

IIS Privacy Policy

At Itaú International Securities, we have a long tradition of integrity and service, which is reflected in the way we serve our customers each day. This consumer privacy statement reflects the policy of IIS.

It describes how “nonpublic personal information”, which includes customer and financial information, may be collected and shared, as well as the steps we take to protect this information from unauthorized access. This policy applies both to current and former customers, and is designed to comply with the privacy provisions in Title V of the Gramm-Leach-Bliley Act, as well as applicable federal privacy laws and regulations.

How we safeguard your information and ensure its accuracy:

• We limit employee access to nonpublic personal information to those who need to know this information to serve customer relationships. We educate our employees about the importance of privacy.

• We maintain physical, electronic and procedural safeguards that comply with all applicable regulatory standards to guard your nonpublic personal information.

• We strive to maintain complete, current and accurate information about you and your accounts. If you request a correction to our records, we will respond in a timely manner.

How we share your information with affiliates:

IIS is a subsidiary of Itaú BBA International plc, a U.K. Bank and an affiliate of Itaú Unibanco Holding S.A., one of Latin America’s largest financial institutions.

Many clients of IIS also do business with one or more of the Itaú affiliates. When appropriate, IIS may share information we collect about you with our affiliates for any of the following reasons:

• Help provide you with better service or perform services on our behalf.

• Respond to communications from you or as you authorize or request.

• Make it more convenient for you to open a new account.

• Allow an affiliate to provide you with information about its products and services that we believe may benefit or interest you.

• Comply with legal and regulatory requirements around the world, and in accordance with applicable laws, rules and regulations. For example, IIS may require to share nonpublic personal information of a customer or prospective customer to Itaú BBA International plc (“IBBAI”), IIS’ parent bank, in connection with IBBAI’s control and supervision of IIS. IBBAI may also share this information with the Prudental Regulation Authority and the Financial Conduct Authority, the regulators responsible for supervising the activities of IBBAI in the U.K. You may instruct us not to share the information about you with our affiliates for certain purposes, as explained under “Limiting

the Sharing of Your Information”.

How we share your information with non-affiliates:

We provide access to information about you to non-affiliates in certain limited circumstances, including:

• To lawyers, accountants and others in connection with their services to IIS' business.

• To help us process transactions for your account.

• When we use another company to provide services for us, such as printing and mailing your account statements.

• When we believe that disclosure is required or permitted under law. For example, we may be required to disclose personal information to cooperate with regulatory or law

enforcement authorities, to resolve consumer disputes, to perform credit/authentication checks or for risk control.

Limiting the sharing of your information.

You may choose to limit the information we share about you with our affiliates and non-affiliates. Specifically, you may instruct us:

• Not to share with our affiliates consumer reports and other personal information about you that may be used to determine your eligibility for credit (for example, information about your income, profession or employment status).

• Not to allow our affiliates to market their financial products or services to you based on information they receive from us about your eligibility for credit or your transactions and experiences with us. If you prefer to limit the sharing of your information, please contact us at 1(305) 416-7813.

• Your choice will be applied to you as an individual or, in the case of a joint account, your choice will apply to the other account holder and will automatically be extended to all of your accounts held by us, as well as to any accounts you may have with our affiliates.

• You may make your privacy choice at any time, and it will remain in effect until you change it. If you choose to limit these types of information sharing, we may continue to share information with our affiliates that identifies you (such as your name), as well as information about your transactions and experiences with us. In addition, our affiliates may continue to use information they receive from us to perform services on our behalf, to respond to communications from you, as you authorize or request, or, if you are their customer, to offer you products or services, or for legal or regulatory compliance. We may also continue to share information about you with affiliates and non-affiliates as permitted or required by law.

Extended Hours Trading Risk Disclosure

This disclosure is provided to customers who will engage in trading outside normal market hours. Such trading involves certain risks explained below.

Risk of lower liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and, as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all.

Risk of higher volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading than you would during regular market hours.

Risk of changing prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening of the next morning. As a result, you may receive an inferior price in extended hours trading than you would during regular market hours.

Risk of unlinked markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hour’s system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.

Risk of news announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of security.

Risk of wider spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.

Risk of lack of calculation or dissemination of underlying index Value or intraday indicative value (“IIV”). For certain Derivative Securities Products (such as exchange-traded funds, ETFs), an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions, an investor who is unable to calculate implied values for certain Derivative Securities products in those sessions may be at a disadvantage to market professionals.

FINRA BrokerCheck 

FINRA BrokerCheck is a free tool to help investors check the professional background of current and former FINRA-registered securities firms and brokers. Brochures containing more details of the tool are available by calling the BrokerCheck hotline at 1 800-289-9999 or online at www.finra.org.

Compliance

Complaints may be directed to:

Itaú International Securities Inc.

Attn: Compliance Department

200 South Biscayne Blvd., Suite 2200

Miami, FL 33131

1 (305) 416-7813

The firm is a member of FINRA and SIPC. IIS maintains an office in Miami, Florida

Policy Statement

• Payment for Order Flow Practices

• SIPC Notification

• Regulation NMS Rule 606/11 AC1-6

• Business Continuity Plan (“BCP”)

IIS Policy on Payment for Order Flow Practices

The Securities and Exchange Commission requires that all registered broker/dealers disclose their policies regarding receipt of “payment for order flow”. This does not change the way we do business with you. If you have any questions, please contact your representative.

WE, ITAÚ INTERNATIONAL SECURITIES INC. (“IIS”), DO NOT RECEIVE COMPENSATION FOR DIRECTING ORDER FLOW IN EQUITY SECURITIES. PERSHING RECEIVES COMPENSATION FOR DIRECTING ORDER FLOW IN CERTAIN EQUITYSECURITIES AND LISTED OPTIONS. THE SOURCE AND NATURE OF THE COMPENSATION, IF ANY, RECEIVED WILL BE FURNISHED UPON WRITTEN REQUEST TO PERSHING LLC (“Pershing”), OUR CLEARING BROKER.

SIPC Information

You may obtain more information about SIPC, including the SIPC brochure, by contacting SIPC at its website www.sipc.org or by phone at 1 (202) 371-8300.

Regulation NMS Rule 606/11ac1-6

A copy of the firm’s quarterly report on order routing is available upon request by contacting your IIS representative or may be obtained at the firm’s Clearing Broker, Pershing’s website, www.orderroutingdisclosure.com.

IIS Business Continuity Plan (“BCP”)

We maintain a BCP that is designed to ensure the continuation or prompt resumption of our business in the event of a Significant Business Disruption (“SBD”).

Such SBD might include a blackout, an act of violence or a severe weather that disrupts our business and/or facilities. IIS’ “BCP” calls for us to contact customers in the event that a SBD is expected to impede customer business. In the event of a SBD, we will make reasonable effort to contact customers promptly if we perceive that the event may impede or significantly delay that customer’s business.

In the event that we experience a SBD, you may contact our Clearing Broker, Pershing, directly to process limited trade-related transactions, cash disbursements and/or security transfers. Instructions to Pershing must either be in writing and sent via fax to 1 (201) 413-5368, or you may call: 1 (201) 413-3635 for additional information or recorded instructions.