• Jose Augusto Ramalho Miranda (officer) — 63,719, $1,145,667.62, +40.5%
• Regina Helena Jorge Nunes (director) — 31,266, $562,162.68, new position
• 9 further officers and directors filed the same day at the same price
Breadth and dollar size both hit their ceilings: 14 distinct filers and $16,278,714.42 in a single day. Conviction is also maxed — 11 of the 14 grew existing stakes by more than 20%. Seniority scored 10 of 15, because the filers are executive officers and directors rather than a named CEO or CFO. No penalties were applied: no same-day selling and no excluded rows.
These Form 4s were filed 2026-09-22; the trades executed 2026-09-18. The purchases by Rubens Aguiar Alvarez and Regina Helena Jorge Nunes were each reported by a second filer (Denise Pauli Pavarina and Paulo Rogerio Caffarelli respectively) and counted once. Nothing was excluded from this cluster and the day's scan was not capped. Reporting only — not investment advice.