Apportionment Policy and Division of Orders and Opportunities

August 2023

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1.INTRODUCTION

 DXA performs professional management of securities portfolios duly authorized by the Brazilian Securities and Exchange Commission (CVM) to perform third-party asset management activities, pursuant to CVM Resolution 21/2021 and focused on private equity assets, which tend to be less liquid and privately traded assets, therefore not subject to orders via brokers or "master account". Notwithstanding, the aforementioned regulation determines the need for an Order Allocation and Division Policy ("Allocation Policy") among the portfolios under its management.

2.OBJECTIVE

 The establishment of the Apportionment Policy seeks to control a fair and transparent allocation of orders and opportunities among the portfolios managed by the same fund manager, with the purpose of ensuring that such orders and opportunities for asset allocation are registered and allocated fairly among them, by grouping the orders, thus providing an equitable and equal treatment among the portfolios and, ultimately, among the investors that have funds managed by the same fund manager.

3.THE RATE

 Given the illiquid profile of the assets invested, the investment funds and portfolios under DXA's management do not admit the grouping of orders, and trades are generally carried out at a single price and individually for each investment of each divestment fund under management or at equal conditions and traded jointly for different investment funds or portfolios managed by DXA.

Should DXA identify opportunities that fit the purpose and policy of different portfolios under management, in order to ensure the above fair and transparent treatment between portfolios, DXA hereby indicates that opportunities will be adopted following the following priority sequence:

i) Investment funds under non-exclusive management and with full discretion of DXA, according to the available capital and obeying any allocation limits;

ii) Exclusive or restricted investment funds whose opportunity validation depends on a committee or shareholder manifestation, allocating the opportunity always following the chronological order of approvals;

iii) Portfolios under management of investors with available capital exceeding R$ 5,000,000.00, allocating the opportunity always following the chronological order of the approvals;

iv) Portfolios under management of investors with available capital greater than R$ 1,000,000.00 and less than R$ 4,999,999.00, allocating the opportunity always following the chronological order of the approvals;

v) Portfolios under management of investors with available capital higher than R$ 200,000.00 and lower than R$ 999,999.00, allocating the opportunity always following the chronological order of the approvals;

vi) Portfolios under management by investors regardless of the available capital under R$200,000.00, allocating the opportunity always following the chronological order of the approvals.

DXA, as the case may be, will set a deadline for investors to manifest themselves, by email or via the platform, following the order of priority defined above, and if the investor does not manifest himself within the deadline, he will always compete with investors of the following items. The priority for investors with more available capital aims at operational simplification and, consequently, the reduction of the investment cost for all involved.

In the case of liquid assets, orders will always be transmitted with the clear and previous specification of the fund or portfolio under management to which they are destined, and apportionment is not applicable.

4.VALIDITY AND VALIDITY

This policy is effective as of the date of its approval and publication on DXA's website.

This Policy shall be reviewed annually, with the possibility of such review being made at shorter intervals should the need arise for legal compliance and/or DXA's needs.

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