1. PRINCIPLES AND SCOPE
1.1. The Information Disclosure Policy discipline, within the scope of Vale and the public companies under its control, subject to the provisions CVM Instruction 358, dated January 3, 2002, the disclosure of information that, by its nature, may generate a relevant act or fact and is based upon the following basic principles:
a) compliance of the specific legislation and of the regulations of the Comissão de Valores Mobiliários (CVM) and the Securities and Exchange Commission (SEC);
b) coherence with the best practices in relations with investors;
c) transparency and equal treatment.
1.2. Vale shall make public, with equity and simultaneity, facts or acts of strategic, administrative, technical, business or economical nature, capable of affecting the prices of its securities and influencing the investors' decision to maintain, buy or sell said securities and to exercise any rights inherent to the condition of security holders in accordance with article 2 of CVM Instruction 358.
1.3. The Vale Information Disclosure Policy establishes guidelines that shall be compulsorily observed by its Directors, members of the Board of Directors and of the Statutory Audit Committee and of any and all agencies with technical or consultative functions within the Company and by whomever that, due to his job, function or title at Vale and its affiliates, has knowledge of information relative to a relevant act or fact about the Company.
1.4. The Vale Information Disclosure Policy shall be known to the administrators of its affiliated companies.
1.5. Vale shall not be responsible for the disclosure of information relative to the acquisition or sale, by third parties, of interest corresponding to five per cent or more of types or classes of shares representing its capital stock or rights over these shares and other securities issued by it, in accordance with article 12 of CVM Instruction 358.
2. INTERNAL PROCEDURES FOR THE DISCLOSURE OF INFORMATION
2.1. The Executive Director in charge of Relations with Investors is responsible for the disclosure of information relative to relevant acts or facts, although all other directors are also jointly and severally liable in the cases of disobedience of the standards relative to this disclosure.
2.2. Without prejudice to the provisions in item 2.1, Vale shall have an Information Disclosure Committee. This Committee shall be presided by the Chief Executive Director and shall be made up by the following members: (a) the Executive Director in charge of Relations with Investors; (b) the Legal Department Director; and (c) the General Manager of Relations with Investors.
The main attributions of the Information Disclosure Committee shall be the evaluation of the relevance of the acts or facts that have occurred related to the Company's business and the supervision of the disclosure process of company information to the stock market.
2.3. The Directors, members of the Board of Directors and of the Statutory Audit Committee and of any and all agencies with technical or consultative functions within the Company and all employees that have personal knowledge of a relevant act or fact shall communicate the same to the Executive Director in charge of Relations with Investors.
2.4. Any and all information considered relevant, and which is not yet of public knowledge, and that comes to be disclosed, intentionally or not, in meetings with analysts, seminars with investors, interviews with journalists or any other type of eventuality, shall be immediately made public.
2.5. The disclosure of a relevant act or fact shall be made before the opening or after the closing of the stock exchange market in which the Vale shares are negotiated. Should the disclosure, during the market negotiation period, be imperative, the Executive Director in charge of Relations with Investors shall request, to the Stock Exchange, that the market floor be suspended, up until the complete dissemination of the information.
2.6. The access, at Vale , to information about relevant acts or facts, before their disclosure to the public, shall be limited to the professionals directly involved with the subject at hand, until the time at which its disclosure is deemed opportune.
2.7. The Directors, members of the Board of Directors and of the Statutory Audit Committee and of any and all agencies with technical or consultative functions within the Company and any other persons that, due to his/her job, function or position at Vale, have access to information relative to a relevant act or fact, shall maintain the confidentiality of said information until its disclosure to the public and shall ensure that subordinates and other people of his/her confidence do the same, being jointly and severally liable with them in the case of disobedience. The above-mentioned professionals are, inclusively, subordinated to Confidentiality Agreements celebrated with Vale.
2.8. Relevant acts or facts may, exceptionally, not be disclosed if the Vale controlling shareholders or directors understand that such disclosure jeopardizes the legitimate interests of the Company, in accordance with article 6 of CVM Instruction 358.
2.9. The Vale administrators may submit their decision, to the CVM, to, exceptionally, maintain the confidentiality of relevant acts or facts whose disclosure they understand to endanger the legitimate interests of the Company, in accordance with article 7 of CVM Instruction 358.
2.10. Whenever the Vale Administration decides to maintain the confidentiality of information related to relevant acts or facts and said acts or facts escape their control, the Executive Director in charge of Relations with Investors shall immediately and publicly disclose said information.
3. DISCLOSURE OF FORECASTS
3.1. The Company, by decision of the Information Disclosure Committee, may eventually disclose forecasts relative to the behavior of the markets in which it operates or relative to its own future performance, clearly presenting the premises that support said forecasts, accompanied by the following observation:
"This official communication may include declarations that present the Company Administration's expectations in relation to future events or results. All declarations, when based upon future expectations and not on historical facts involve various risks and uncertainties. The Company cannot guarantee that such declarations will come to be correct. Said risks and uncertainties include factors related to the Brazilian economy and the capital market, which present volatility and can be affected by developments in other countries; relative to the iron ore business and its dependence upon the steel industry, which is cyclic by nature, and relative to the great competitiveness in industries in which Vale operates. To obtain further information on factors that may give origin to results different from those forecasted by the Company, please consult the reports filed with the Comissão de Valores Mobiliários - CVM and with the U.S. Securities and Exchange Commission - SEC, including the most recent Annual Report - CVRD Form 20F."
3.2. Should the forecasts not be confirmed, the Company shall inform the reasons that determined the difference between results.
4. FORMS AND CHANNELS FOR THE DISCLOSURE OF INFORMATION
In accordance with the terms of the pertinent legislation and regulations of the CVM and the SEC, Vale shall simultaneously disclose to the stock market information relative to the Company by means of the following communication channels:
4.1. Publication of communications in the large circulation newspapers normally used by the Company, in accordance with article 3 of CVM Instruction 358;
4.2. Simultaneous circulation of press releases, in the Portuguese and English languages, to the CVM and the SEC, the Stock Market, in Brazil and abroad, in which the Company's shares are negotiated, custodian agents, depository agent of the American Depositary Receipts (ADRs), participants of the capital market, news agencies and wire services through the use of electronic means;
4.3. Telephone conferences and webcasts conducted regularly every three months for the disclosure of results and exceptionally, should they be necessary. The occurrence of these events shall be previously publicly announced to the stock market, indicating the date, hour and telephone numbers for connection. These conferences and webcasts shall be recorded and shall be available for consultation at the CVRD website, www.vale.com, in the Relations with Investors section, for a period of sixty days following their original occurrence;
4.4. Holding of at least 4 (four) public annual meetings with the Associação Brasileira de Analistas de Mercado de Capitais - ABAMEC (Brazilian Association of Capital Market Analysts), being one every quarter. Vale shall publicly announce, beforehand, the date, hour and place of said events;
4.5. Intensive use of the Company website, Relations with Investors section, with versions in both Portuguese and English, for the immediate availability of press releases, presentations conducted during meetings and conferences, operational information, corporate events, payments of dividends and issuance of debt securities, annual reports, quarterly and annual financial statements and documents filed with the CVM and SEC, quotations of Company shares negotiated in São Paulo Stock Exchange and New York Stock Exchange and answers to most frequently asked stock exchange participant questions;
4.6. Active participation in conferences with investors conducted in Brazil and abroad;
5. DISCLOSURE OF INFORMATION ON ADMINISTRATORS AND RELATED PEOPLE'S NEGOTIATIONS
5.1. The Directors, members of the Board of Directors and of the Statutory Audit Committee and of any and all agencies with technical or consultative functions within the Company shall communicate, in writing, in accordance with article 11 of CVM Instruction 358, to the Executive Director in charge of Relations with Investors and, through the latter, to the CVM and self-regulating agencies:
(a) immediately after his/her admission to the job position, the quantity of securities issued by the Company and by affiliated or controlling companies that are publicly traded companies, that he/she eventually possesses at such time, as well as those pertaining to his/her spouse, unless separated de facto or judicially, and of any dependants included in his/her annual income tax statement;
(b) the modifications in the above-mentioned positions, in a maximum time period of 10 (ten) days following the end of the month in which such modification occurred, indicating the balance of his/her position during the period.