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Policies and Corporate Documents

Our policies are intended to transparently inform Vale's positioning and the principles that guide our actions, in setting the Company’s main strategies and managing issues that are critical for the Company and its stakeholders. The policies are instruments through which we can align with market practices, regulations and applicable laws. Know what our policies are.

Policy

Policy of Disclosure of Material Act of Fact and Securities Trading

This policy regulates the disclosure of material information of Vale S.A. (Vale) and its subsidiaries. It also promotes the responsible trading of securities issued by Vale, or related to them, eliminating any inappropriate use of information relating to a Material Event or Fact about Vale ("Privileged Information").

Human Rights Policy

Establishes guidelines and principles for Vale’s actions to respect Human Rights in its projects and operations, throughout its activities and in its value chain, in the regions where Vale is present.

Sustainability Policy

Establishes sustainability guidelines and principles for our projects and operations, reinforcing our commitment to our value that Life Matters Most and our social, environmental and economic responsibility.

Socioenvironmental Investments Policy

Establishes general guidelines for the planning and implementation of socioenvironmental investments.

Climate Change Policy

Establishes the climate change commitments and guidelines for Vale and for entities of Vale System.

Risk Management Policy

Establishes guidelines for the integrated management of potential risks to which Vale System entities are exposed.

Code of Conduct

The fundamental principles that guide Vale's and its subsidiaries' actions are found in our Code of Conduct. These principles must be followed by everyone who acts on behalf of the Company: the executive Board and our employees, interns, contractors and partners.

Anti-corruption Policy

Reaffirms the main requirements of anti-bribery and anti-corruption laws of the various jurisdictions and countries where Vale and its subsidiaries operate, and promotes continuous compliance with such laws.

Suppliers’ Code of Conduct

This aims to guide the relationship between Vale and its suppliers. For Vale, these partnerships are fundamental, because they help Vale to fulfill its mission of transforming natural resources into prosperity and sustainable development.

CEO Succession Policy

Establishes procedures to guide the succession process of the Chief Executive Office ("CEO") of Vale SA ("Vale" or "the Company") to ensure the continuity of the Company's business. To guide the alignment of such processes with corporate governance best practices and applicable laws.

Executive Directors Compensation Policy

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

Sanctions Compliance Policy

Establishes guidelines to ensure that Vale complies globally with sanctions imposed against countries, entities and individuals by the main international rules and regulations in conducting its business.

Related Party Transactions

To set forth the guidelines and principles to ensure that Related Party Transactions¹ and other situations of potential Conflict of Interest involving Vale are conducted according to market conditions and according to best practices of corporate governance and appropriate transparency, always prioritizing Vale’s best interests and avoiding the abuse and misuse of Company assets.

Indemnity Policy

Establishes principles, guidelines, limits and procedures that shall govern the indemnity commitments of Vale or its wholly-owned controlled companies and the members of the Board of Directors, Advisory Committees to the Board, the Executive Board, Vale’s General Counsel and other beneficiaries covered by this Policy.

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