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COSAN S.A. SP.ADR 1/4 Equity – US22113B1035

January 14, 2025

When looking at ADR’s (or other depository type interests/receipts such as ADS’s), the listing or trading of the actual ADR or ADS is irrelevant. All that matters is the qualifying status of the underlying shares. If the underlying shares are ISA qualifying (because they are listed on a recognised stock exchange or admitted to trading on a recognised stock exchange in the EEA, including the UK), then the ADR (or ADS) automatically qualify (regardless of its listing status).

If the list below of ADRs/ADSs don’t have any underlying shares that are ISA qualifying, then the ADS or ADR won’t qualify for ISA inclusion regardless of its listing. My point being we are not looking at the listing of these ADRs/ADSs we are looking to see if they have any underlying shares that are ISA qualifying (usually information on the company website – investors area).

Regarding the Brazilian B3 exchange, this is problematic for both TISA and ISA managers who use of the HMRC recognised stock exchange list to be able to identify the ‘Sao Paulo’ section of the exchange.

The list recognises B3 (recognised stock exchange), but we are in the same position that we’ve been in for years where, in theory/strictness, ISA managers must be able to identify whether a particular share is listed on what is referred to as Sao Paulo SE part of the exchange (if it actually exists!) which, as far as I know, nobody has ever been able to do!

So since 2008, we’ve confirmed that the Brazilian Mercantile and Futures Exchange (BM & F) Bovespa is recognised stock exchange, albeit the current list references the Sao Paulo Stock Exchange, and accepted the ‘grey’ area where shares are only supposed to be treated as listed on a recognised stock exchange if they are listed on the ‘Sao Paulo’ part of the exchange even though we don’t know how to accurately check this.

So, in summary, the common shares are listed on the B3 Market (see first two links below), which is a recognised stock exchange and in such cases, although we can’t be 100% sure for the reasons we outlined above, we tend to work on the assumption that shares such as this are listed on the former Sau Paulo SE exchange and, on that basis, the common shares would be ISA qualifying meaning that the ADR/S would also be ISA qualifying.

Our stocks – Cosan

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COSAN S.A. SP.ADR 1/4 Equity | A2QQ5P | US22113B1035 | Share Price