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The purpose of this document is to present BRF-Brasil Foods SA (hereinafter referred to as BRF or the Company) financial risk management policies, the main focus of which is the market and counterparty risk. This policy conforms to the best international practices and also complies with the standards laid down by the regulatory entities in Brazil and abroad, It establishes guidelines and limits to govern the actions of the areas involved in the implementation of hedging transactions, while observing the criteria approved by the Board of Directors.
This policy will be valid for a maximum period of two years from the date of its last approval by the Board of Directors.
Briefly, risk management at BRF may be characterized as follows:
The main steps of the risk management process are listed below:
The risk management process should be conducted by the Financial Risk Management Committee, whose duty is to assess whether the Financial Risk Management Policy is being fully complied with and to propose applicable alternatives. In addition, the Committee has the power to veto proposals for transactions which, at its discretion, are not appropriate for BRF at the time of their evaluation.
The Financial Risk Management Committee shall meet on a monthly basis or extraordinarily, when necessary.
The Financial Risk Management Committee is a formally constituted body reporting to BRF Executive Board.
The Financial Risk Management Committee may be strengthened by outside consultants contributing independent opinions about the management of the hedging transactions and an evaluation free of conflicts of interest in the transactions and observance of the limits.
The Board plays a key role (1) in the development of a solid financial risk management framework, since it is responsible for the approval of the Financial Risk Management Policy drawn up by the Financial Risk Management Committee risk and (2) in monitoring compliance with this policy by checking observance of the overall limits established.
The Finance and Risk Management Policy Committee will report directly to the Board of Directors and will play a consultative role in relation to the Financial Risk Management Policy, as well as other strategic guidelines for financial risk management and ongoing monitoring of the performance of the Financial Risk Management Committee.
The Board of Executive Directors of BRF will act directly in the management of the financial risk with the following responsibilities:
The Financial Risk Management Committee is the body of the Executive Board responsible for ensuring the implementation of the Financial Risk Management Policy.
The responsibilities of the Financial Risk Management Committee may be described as follows:
In terms of market risks, the duties of traders when handling the transactions in compliance with the Company’s Financial Risk Management Policy are:
With the support of the Financial Risk Management Policy, the main duty of the Risk Management area will be to track, monitor, assess and report the financial risks incurred by BRF. This involves mainly:
The Financial Risk Management Committee may rely on the services of an outside consultant, provided on a monthly basis, to monitor the implementation of the Financial Risk Management Policy. One of the important requisites in the engagement of an outside consultant is to ensure that such person is an independent professional.
This will ensure the governance of the whole financial risk management process in relation to segregation of duties, internal controls, implementation of this policy and reflections on accounting. The internal audit team will have its own schedule and agenda, maintaining its independence, and will have access to Committee meetings.
In order to segregate duties and ensure the independence of the controls and information, the Risk Management area will report directly to the Vice President for Finance, Administration and IR. If needed and at its discretion, it may assess the CEO directly,
Derivative instruments eligible for the implementation of hedging transactions are:
Short positions in options (puts or calls) are permitted, provided that no net premium is received and that the number of call and put options are equal.
Any instrument, transaction, or strategy which, individually or combined, creates any type of additional leverage or contains contractual devices that gives it an additional leverage is strictly barred.
Transactions not listed as Eligible Instruments may be executed solely upon the prior approval by the Board of Directors.
Market risk may be defined as the risk posed by price oscillations of the various risk factors identified in the Company’s transaction. The principal methodology used to measure the Market Risk is the C-FaR - Cash Flow at Risk, which seeks to determine the worst result for the cash flow projected based on the risk factors identified.
To facilitate understanding the market risk involved in BRF activities, the risk factors mapped in this policy are described below.
This section addresses specifically the exposure to variations in foreign exchange rates (USD/GBP/EUR). The main objectives are: identify the origin of the exposure, define a control policy and establish limits for such exposure.
The exposure to foreign exchange rate is derived from the projections of cash flow in foreign currency (type 1) and/or by the balance sheet accounting balances (type 2).
To mitigate the risks arising from type 1 exposure, specific control risk policies will be adopted.
For a better control, two time horizons will be mapped: up to 12 months and over 12 months.
Special hedge accounting will be adopted for both time horizons on exposures arising from highly probable future income up to the specific limits.
This section addresses specifically the exposure to variations in the prices of commodities such as corn, soybean, soybean meal and soybean oil. This exposure may, in turn, be the result of physical purchase projections.
To mitigate the risks arising from full exposure to variation in prices of commodities, specific risk control policies will be adopted. For exposure arising from the operational flow of the purchase of soybean meal/oil and corn, the following parameters must be observed:
This section addresses specifically the exposure concerning transactions linked to the Beef Division, whose main risk factor is the price of Live Cattle [Boi Gordo]. The strategies for origination which may be used include:
Buy for future delivery of Live Cattle at a fixed price or a price to be set.
Hiring of confinement to finish the animal for the market Lean cattle may be owned by the party or owned by a third party.
Acquisition of calves in the pre- or post-weaning period
Purchase of Live Cattle in the spot market.
For this strategy, the following definitions apply:
In its meetings, the Committee will promote the review and assessment of the factors outlined but not detailed in this Policy. It may also, should it see fit, include new factors and, in regular reviews of the Financial Risk Management Policy, detail and propose limits and controls.
Counterparty Risk may be defined as the risk of the counterparty in an agreement not honoring its contractual obligations.
Procedures and limits of authorities are defined below for application in case of changes in the market strategies approved by the Financial Risk Management Committee, as well as for the use of the limits of authority established by this Financial Risk Management Policy.
As defined in the duties of the Financial Risk Management Committee, this Committee is responsible for approving, within its limits of authority, hedge alternatives in accordance with this Policy. Therefore, if there is any change in the strategy outlined for the current month, the person responsible for the traders involved will inform such change and the corresponding reason to the Coordinator of the Financial Risk Management Committee. The Coordinator shall then inform the Committee members. Lack of response from any signatory member will be construed as approval for the new strategy.
For cases requiring higher limits of authority, the item below, 6.2 - Use of Limits of Authority, will apply:
The flow below shows the procedures to be adopted in such cases:

As noted above, the Risk Management area (after informing, or receiving the reason from, the Operational area - 01) has a duty to inform the Financial Risk Management Committee any use which is above (or below) the limit of authority established for the Operational Area - 02.
The Committee will request the Operational Area to correct the position or will agree the strategy/position, provided that it is within its own limit of authority, otherwise it will inform the Executive Board - 03.
The Executive Board, in the same manner of the Financial Risk Management Committee, will request the Operational Area to correct the position or will agree the strategy/position, provided that it is within its own limit of authority, otherwise it will inform the Board of Directors - 04.
The Board of Directors will request the Operational Area to correct the position or will agree the strategy/position.
Notes:
In addition to the levels of authority in the preceding item, the following apply:
Some relevant remarks are set out below:
This item describes the aspects relating to the negotiating and operational procedures of the transactions that will be performed.
At the time of selection of the hedging instruments to be used, the areas involved in the performance of the transactions must have the following knowledge:
As defined in the Accounting Pronouncement Committee - CPC 38 and in the Brazilian Securities Commission - CVM Resolution No. 604, dated November 17, 2009, a financial derivative instrument should be classified as a security held for trading and therefore recorded in the balance sheet as an asset or financial liability at fair value through income, except if the entity designates it as a cover instrument in an effective cover relationship. In this case, the entity must apply optional cover accounting rules ("Hedge Accounting").
For entities that perform cover transactions involving the use of derivative financial instruments to hedge against a specific risk which has been determined and documented (and some non-derivative financial instruments used to hedge the risk of foreign exchange variation), there is the possibility of application of the methodology called hedge accounting. This methodology makes the impacts on the variation of the fair value of derivatives (or other non-derivatives financial instruments) used as hedging instrument be recognized in the result according to the recognition of the item that is the subject matter of the hedge. This methodology therefore ensures that the accounting impacts of the hedging transactions will be the same of the economic impacts, in line with the accrual basis.
This Financial Risk Management Policy will be reviewed and updated on an ongoing basis every year. The highly likely nature of the exports will be revised whenever the Company identifies a significant change in its exports and at least at each annual review of the Policy.
Exceptional revisions will be permitted provided that the reasons are compatible with the urgency. These reviews also must necessarily be submitted to BRF Board of Directors, and the Executive Board may also be consulted.
Futures markets
Originally developed to meet the needs of marketers and agricultural producers to eliminate the uncertainty about the price to be received for certain goods at a future specified date.
Futures contracts
Traded on Commodities and Futures Exchanges, “futures contracts” are standardized contracts that allow the holder to set a price for a particular asset at a future date. The settlement of such contract is financial: the holder will pay (or receive) the difference between the actual price on the date of expiration of the contract and the contracted price. To minimize the risk of the other party in the transaction, the Exchanges require the deposit of a guarantee margin which is adjusted on daily basis.
Derivatives
These may be defined as a private contract, the value of which almost entirely derived from the value of some underlying asset, reference rate or pertinent index. The purpose of using these instruments is to manage the financial risk appropriately.
OTC (Over-The-Counter) Market
This is a contract agreed directly between the parties, in which there is flexibility in relation to maturity, size and settlement. This form of negotiation can present risk for the other party, for not having, in most cases, the deposit of guarantees or daily adjustment.
Forward [A Termo]:
Similar to the futures contract, but not standardized, i.e., traded in the over-the-counter market and, in most cases, presenting a risk to the other party.
Options:
There are contracts that give the holder the right to buy (or sell) a particular asset, on (or until) a specified date at a fixed price. Although they are less liquid than futures contracts, the advantage of these instruments is that they do not have daily adjustments - the difference is paid solely only at the closing of the transaction.
Swap
Swap is a contract to exchange the profitability of Indexers: the holder receives the variation of a particular index, and pays the variation of another index. With this, it expects to obtain a protection against possible differences between the variations of those indexes.
NDF - Non-deliverable forward
This a forward contract for currencies.
Hedge
This is the use of financial instruments to reduce the exposure to variation in a particular market.
Hedge Accounting
This is the description in the Company’s balance sheet of the hedge protecting the exposure of the corresponding account. It also reduces volatility in the financial lines of the balance sheet.
VaR
Value at Risk, this is an estimate of the maximum expected financial loss on a certain asset or set of assets, under normal market conditions, using statistical models.
Stress Testing
The stress test aims to quantify the financial loss under abnormal market conditions, i.e., in a scenario which is different from that observed so far.
BM & FBOVESPA
This is the sole securities, commodities and futures exchange in Brazil.
CBOT
Owned by the CME Group (Chicago Mercantile Exchange),the CBOT (Chicago Board of Trade) is the largest commodities exchange of the world.





Where:
Taxa1 = First rate to be interpolated
Taxa2 = Second rate to be interpolated
Dias1 = Consecutive days from the base date to the first rate to be interpolated
Dias2 = Consecutive days from the base date to the date desired for the interpolation
Dias3 = Consecutive days from the base date to the second rate to be interpolated
Being:
(Taxa1 < Taxa2)
(Dias1 < Dias2 < Dias3)

*CDI = Interbank Deposit Certificate
a. CDI-Indexed Products (Passive End)
Mark to Market: MtM (R$) on date t will be given by

Where:
VN = Nominal value of the transaction made on the base date b
α0 = Percentage of the CDI of the transaction
αt = Percentage of the CDI market on date t
CDIi = CDI rate on date i
b. USD-Indexed Products (Active End)
Mark to Market: MtM (R$) on date t will be given by

C1t,v = Clean foreign exchange coupon valid between dates t and i
DolarPartida = Commercial cash US dollar rate on the date of the transaction
Ptaxt = Ptax800 rate quote on date 0-1
C0 = Coupon (spread) contracted
a. CDI-Indexed Products (Passive End)
Mark to Market: MtM (R$) on date t will be given by

Where:
VN = Nominal value of the transaction made on the base date b
α0 = Percentage of the CDI of the transaction
αt = Percentage of the CDI market on date t
CDIi = CDI rate on date i
b. USD-Indexed Products (Active End)
Mark to Market: MtM (R$) on date t will be given by

C1t,v = Clean foreign exchange coupon valid between dates t and i
DolarPartida = Commercial cash US dollar rate on the date of the transaction
Ptaxt = Ptax800 rate quote on date 0-1
C0 = Coupon (spread) contracted
Mark to Market: MtM (R$) on date t will be given by

Σ = transaction sign ("+" for buy, "-" for sell);
Ct = foreign exchange rate on the date at issue, according to the contract specification or as obtained in the same source described in swap contracts
Ct,f = foreign exchange rate contracted for the final date of the transaction
r = traded currency expected, obtained from the coupon curve without coupon
s = pre rate expected, obtained from the Pre Curve without Cash