39. Sadia periodically provided reports to senior management about potential risks
and actions taken to mitigate them. It is undisputed that Sadia executives monitored and had
access to information about the current state of the Company’s hedging practices. Indeed,
defendants have now admitted that at least defendant Ferreira knew that the Company’s hedging
policy had been violated prior to revealing such information to the public. On October 30, 2008,
the Company conducted an analyst conference call (the “October 30, 2008 Conference Call”),
during which the Company referenced a slide presentation, available on its website, which tried
to explain away what Sadia characterized on the call as a “rupture in information”, and later
acknowledged as a possible “intentional flaw.” The slide referenced during the conference call
showed that on a daily basis, members of the risk management committee received both “Daily
Currency Books”, which detailed Sadia’s hedging exposure, and the results as well of an “Outof-
Policy warning”, which would alert the committee to any deviations from Sadia’s stated “nonspeculative”
hedging policy.