Vale S.A. Loss Form

(i) Vale had failed to adequately assess the risk and damage potential of a dam breach at its Feijão iron ore mine especially in light of its experience in 2015; (ii) Vale’s programs to mitigate health and safety incidents were inadequate; (iii) Defendants filed to disclose that Vale’s auditor was not independent, as required under Brazilian mining law; (iv) Defendants failed to disclose that an internal report commissioned by Vale in 2018 to assess the stability of the tailings dam raised concerns over its drainage and monitoring systems; (v) Defendants failed to disclose the existence of information that the dam was at risk of “liquefaction,” the same issue that led to the 2015 collapse of the Samarco dam; and (vi) as a result, Vale’s public statements were materially false and misleading at all relevant times.