Drummond Maria Rita de Carvalho 4

What Happened

• Maria Rita de Carvalho Drummond, Chief Legal Officer of Cosan S.A., reported multiple transactions: three open‑market/private sales on April 15–17, 2026 totaling 109,400 shares (codes S) and a same‑day “other acquisition/disposition” on May 19, 2026 (code J) involving 280,954 shares that were both acquired and disposed on that date.
• Sales: 35,800 shares @ 5.57 (BRL) = BRL 199,406 (4/15); 36,200 shares @ 5.48 = BRL 198,488 (4/16); 37,400 shares @ 5.48 = BRL 204,915 (4/17). Total reported sale proceeds = BRL 602,809.
• May 19 transactions: acquisition of 280,954 shares @ 5.14 = BRL 1,444,104 and a simultaneous disposition of 280,954 shares @ 5.14 = BRL 1,444,104 (both reported with transaction code J).

Key Details

• Transaction dates and prices:
  • 2026-04-15: Sold 35,800 @ 5.57 (BRL) — BRL 199,406 (S)
  • 2026-04-16: Sold 36,200 @ 5.48 (BRL) — BRL 198,488 (S)
  • 2026-04-17: Sold 37,400 @ 5.48 (BRL) — BRL 204,915 (S)
  • 2026-05-19: Acquired 280,954 @ 5.14 (BRL) — BRL 1,444,104 (J)
  • 2026-05-19: Disposed 280,954 @ 5.14 (BRL) — BRL 1,444,104 (J)
• Currency: Filing notes amounts are reported in Brazilian reais (BRL) (footnote F1).
• Shares owned after the transactions are not specified in the provided data. The filer notes that a Form 3 filed March 18, 2026 inadvertently omitted 559,785 common shares (footnote F2).
• Footnotes of note:
  • F3: Some reported amounts relate to long‑term incentive program awards (rights to receive shares subject to vesting and performance); final delivered amounts may change and are shown gross.
  • F4: Each American Depositary Share (ADS) represents four common shares (useful if comparing ADS vs common‑share counts).
• Timeliness: The Form 4 was filed May 21, 2026. The April 15–17 sales were reported late (outside the typical two‑business‑day window); the May 19 trades were reported on May 21 (within two business days).

Context

• The April transactions were outright sales (routine insider selling). The May 19 J‑code entries show an acquisition and a disposition of the same number of shares on the same day; the filing does not explain the mechanics (e.g., transfer, settlement, tax withholding, or other corporate/internal processing), so avoid inferring motivation.
• For retail investors: purchases can be more informative as a potential bullish signal; here the sales were material in amount but the simultaneous May 19 acquire/dispose largely net to zero on the face of the filing.