This policy unifies two important themes: information disclosure and securities trading.

It regulates the disclosure of material information of Vale S.A. and its subsidiaries and is based upon basic principles such as transparency, information symmetry, fair treatment and respect for investor rights, adherence to the best global investor relations practices, compliance with the specific legislation of Brazil, USA, France and the regulations of the stock exchanges in which Vale’s securities are listed and traded.

This policy also promote the responsible trading of the securities issued by Vale, or related to them, eliminating any presumption of the inappropriate use of information relating to a Material Event or Fact about Vale. An Ato or Fato Relevante is an event or a fact that may significantly influence: the market price of securities issued or guaranteed by Vale or the decisions of investors to purchase, sell or retain such said securities, or to exercise any rights they may have regarding such securities.

In January 27^th, 2019 the Board of Directors of Vale suspended the Shareholder Remuneration Policy that was previously in effect as follows:

1. The shareholder remuneration will be composed by two semi-annual installments, the first in September of the current year and the second in March of the subsequent year¹.

2. The minimum amount of the remuneration will be 30% of the Adjusted EBITDA less Sustaining Investments calculated based on the first half of the year results for the September installment, and on the second half of the year results for the March installment.

3. The Board of Directors may approve additional remuneration through the distribution of extraordinary dividends.

¹ The Board of Directors may declare interest on capital in December of each year, for payment in March of the subsequent year. These amounts will be reduced from the March instalment.

² Minimum remuneration = 0,3 x (Adjusted EBITDA – Sustaining Investments).

To set forth the guidelines and principles to ensure that Related Party Transactions1 and other situations of potential Conflict of Interest2 involving Vale are conducted at Market Conditions, according to best practices of corporate governance and appropriate transparency, always prioritizing the best interests of Vale and avoiding abuses and misuse of company assets.

The main objective of the Risk Management Policy is to establish guidelines and guidance for the integrated management of all risks which Vale System entities are exposed. This policy applies to Vale, its wholly owned subsidiaries and shall be reproduced to its direct and indirect, subsidiaries in Brazil and in other countries, always respecting these companies’ constitutional documents and the applicable law. The principles of this Policy should be applied, whenever possible, by other entities in which Vale has equity interest in Brazil and in other countries. This group of entities, for the purposes of this Policy, is called "Vale System”.

It aims to establish procedures to guide the succession process of the Chief Executive Office (“CEO”) of Vale SA (“Vale” or “Company”) to ensure the continuity of the Company's business, as well as alignment of such process with corporate governance best practices and applicable law.

Aims to establish general guidelines for defining the model and compensation management of the statutory members of Vale’s Executive Directors.

It is designed to be competitive in the global talent market and to allow Vale to be able to attract and retain highly skilled executives with experience and knowledge commensurate with the position required, besides encourage them to execute the strategy and promote the company’s success in the medium and long term, through behaviors and practices aligned with the interests of shareholders and Vale’s values, essential for generating sustainable return.

The compensation practiced by Vale, in addition to being directly impacted by the economic and financial results achieved by the company and the short and long term market value, has as one of its main focuses the improvement and strengthening of health and safety aspects, social progress and the environment.

The purpose of this policy is to reaffirm the commitment of do what is right, reinforcing the compliance culture, to accomplish the main requirements of anti-bribery and anti-corruption laws of the various jurisdictions and countries where Vale and its subsidiaries operate.

It applies to Vale and its wholly owned subsidiaries and must be adopted by its direct and indirect controlled entities in Brazil and in other countries, always in compliance with these companies’ constitutional documents and applicable laws. Adoption of this Policy is encouraged in other entities in which Vale has a participation interest, in Brazil and other countries.