Dec. 19 – BRAVA ENERGIA S.A. (“BRAVA” or “Company”) (B3: BRAV3), in response to the Official Letter n. 343/2025/CVM/SEP/GEA-1, sent to the Company in December 17, 2025 (“Official Letter”), hereby clarifies the news published by the newspaper CNN Brasil, section Economia/Negócios, in December 17, 2025 (link available here).
The contents of the Official Letter are transcribed as follows (free translation):
“Official Letter n. 343/2025/CVM/SEP/GEA-1
Rio de Janeiro, December 17, 2025.
To Mr.
Luiz Felipe Chaves de Carvalho
Investor Relations Officer of
BRAVA ENERGIA S.A.
E-mail: ri@bravaenergia.com
c/c: emissores@b3.com.br
Subject: Request for Clarifications on News Broadcasted – CVM Proceeding No. 19957.018278/2025-29
Mr. Officer,
1. We refer to the news article published today by CNN Brasil, entitled “Brava expects to increase investments to US$ 550 million”, which contains the following statements:
Brava Energia expects to invest US$ 550 million in 2026, with two-thirds allocated to its expansion strategy, which provides for the drilling of four wells between 2026 and 2027, and the remainder to maintenance, said the Brazilian oil company’s Chief Financial Officer, Luiz Carvalho, on Wednesday (17). For this year, projected investments are around US$ 500 million, according to the company’s estimates. […] The investments will allow the company to reach a production capacity of approximately 100 thousand barrels of oil equivalent per day (boed) from 2027 onward, after closing this year at around 90 thousand boed, as expected. […]
2. In view of the foregoing, we hereby determine that you clarify the reasons why you understood that the matter did not constitute a material fact, considering the provisions set forth in CVM Resolution No. 44/21.
3. It should be noted that, pursuant to Article 3 of CVM Resolution No. 44/21, it is incumbent upon the Investor Relations Officer to disclose and communicate to the CVM and, where applicable, to the stock exchange and the organized over-the-counter market entity in which the securities issued by the company are admitted to trading, any act or material fact that has occurred or is related to its business, as well as to ensure its broad and immediate dissemination, simultaneously in all markets in which such securities are admitted to trading.
4. Furthermore, we emphasize that the practice of disclosing to the market its expectations regarding future performance (guidance), both in the short and long term, especially with respect to the financial and operational aspects of its business, involves the preparation of quantitative projections.
5. In this regard, in compliance with the provisions of Article 20, paragraph 1, of CVM Resolution No. 80/22, we hereby determine that, if the statements under consideration are true, the corresponding items of the issuer’s Reference Form be updated.
6. Such statement shall be made through the Empresa.NET System, under the category: Notice to the Market, type: Clarifications regarding inquiries from the CVM/B3, subject: News Published in the Media, and shall include the transcription of this official letter. Compliance with the present request for a statement by means of a Market Announcement does not preclude the potential determination of liability for the failure to timely disclose a Material Fact, pursuant to CVM Resolution No. 44/21.
7. We hereby warn that, by order of the Superintendence of Corporate Relations, in the exercise of its legal powers and based on item II of Article 9 of Law No. 6,385/76 and CVM Resolution No. 47/21, a determination may be made to impose a coercive fine in the amount of R$ 1,000.00 (one thousand Brazilian reais), without prejudice to other administrative sanctions, for failure to comply with the requirement set forth in this official letter, which was sent exclusively by e-mail, by December 19, 2025.
Yours sincerely,”
In response to the Official Letter, the Company clarifies that the references to investments (CAPEX) and production capacity (boed) contained in the News Article have an operational focus, aimed at the Company’s investment capacity and potential production capacity, and should not be construed as projections of results (earnings) or as the practice of providing guidance. The Company emphasizes that it does not adopt a policy of disclosing formal performance projections and, therefore, does not disclose projections (guidance) in its Reference Form.
The reference to investments of approximately US$ 550 million should be understood as an aggregated indication of investment capacity, constructed based on information already disclosed to the market, reflecting (i) the level of CAPEX incurred throughout 2025 (as disclosed in the Company’s periodic communications), combined with (ii) CAPEX amounts associated with the drilling campaign of four producing wells in the Atlanta and Papa-Terra fields, projects that have already been approved by the Company’s competent corporate bodies and widely communicated to the market.
In particular, the Company notes that the contracting/progress of part of the campaign was the subject of a Notice to the Market disclosed on November 26, 2024¹, in which an approximate cost of US$ 147 million was indicated (considering the Company’s interest in both assets), related to the project stages described in such Market Announcement.
Throughout 2025, the Company also reaffirmed the continuity of the projects in various public disclosures, including quarterly earnings materials².
Accordingly, the numerical reference reported in the news article does not represent the announcement of a new budget or an unprecedented corporate resolution, but rather an aggregated reading of information and projects already known by the market. The reference to such investments is closer to a reiteration of factual information already in the public domain than to the disclosure of new information regarding expectations of future performance.
As explained in a CVM precedent (CVM PAS No. 19957.011190/2019-38, decided in 2020), the specific regime imposed on the disclosure of corporate projections is justified because such information is sensitive. Its purpose “is precisely to assist investors in deciding to buy or sell an asset. As is well known, projections, by their very nature, have the potential to influence an investment decision. Therefore, when a company decides to disclose its projections, the CVM requires certain safeguards in their disclosure, especially with respect to the assumptions on which they are based”.
However, as explained, this does not involve new information that would add materiality to an investor’s assessment of the securities issued by the Company.
With respect to the reference to a production capacity of approximately 100 thousand boed as from 2027, it should be interpreted as potential capacity, resulting from the addition of: (i) the Company’s current production (monthly disclosed to the market by the Company and subject to daily monitoring on the website of the Brazilian National Agency of Petroleum, Natural Gas and Biofuels – ANP); and (ii) incremental capacity consistent with wells of similar characteristics associated with the four wells of the drilling campaign referred to above.
The production capacity of these new wells does not represent an estimate of the actual production to be achieved. As made very clear in the Risk Factors section of the Company’s Reference Form, the recovery of hydrocarbon volumes, in an economically viable manner, from the Company’s fields depends on several factors beyond its control and often does not reflect the productive capacity or the oil and natural gas accumulations of a given asset.
It is, therefore, an operational estimate of capacity, and not a projection of results (production volume, profit, EBITDA, cash generation, dividends, or others).
Any references to potential increases in production capacity and to investment capacity derive from concrete operational information and the progress of projects already disclosed, and it is certain that the Company does not disclose any expectations in defined amounts or timeframes, nor does it make any performance commitments.
Finally, Brava reaffirms its commitment to keep its investors and the market in general duly informed, in line with best corporate governance practices and in strict compliance with applicable legislation.
Brazil Energy Insight 
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