Business Context and Reporting Period
Company: AMBEV S.A.
Filing Type: Form 6-K (Report of Foreign Private Issuer)
Reporting Period: October 2025 (Filing Date: October 29, 2025)
Subject: Submission of the updated "Manual on Disclosure and Use of Information and Securities Trading Policy."
This filing does not contain financial results or operational updates. It serves to disclose the Company's internal governance framework regarding the handling of Material Acts or Facts and securities trading by insiders, in compliance with Brazilian Securities and Exchange Commission (CVM) Ruling No. 44/21.
Financial Metrics
The filing text does not provide a clear value for revenue, profit, cash flow, margins, debt, or liquidity. This document is a policy disclosure and contains no financial statements or performance data.
Material Changes
The primary material change disclosed is the amendment and consolidation of the Company's internal policies:
- Policy Update: The Board of Directors approved amendments to the Manual on October 29, 2025.
- Regulatory Alignment: The Manual was updated to align with CVM Ruling No. 44/21, establishing a scheme of responsibility for the use, communication, and disclosure of Material Acts or Facts.
- Scope Expansion: The policy defines "Bound Persons" (Directors, executives, employees with access to material information, and controlling shareholders) and mandates their adherence to strict disclosure and trading protocols.
Guidance, Outlook, and Risks
Management Commentary: Management emphasizes that the Company's conduct is guided by the principle of full disclosure and transparency to ensure equitable treatment of investors. The Investor Relations Officer is designated as the primary responsible party for communicating Material Acts or Facts.
Risks and Contingencies:
- Insider Trading Restrictions: Strict prohibitions on trading securities during "Blackout Periods" and within 15 days preceding the disclosure of quarterly (ITR) or annual (DFP) financial statements.
- Confidentiality Breaches: Bound Persons are jointly and severally responsible for maintaining the confidentiality of privileged information until public disclosure.
- Penalties: Failure to comply with the Manual may result in disciplinary sanctions, including dismissal with cause, and the Company may seek full indemnification for losses sustained.
Key Facts for Investor Verification
- Verify the effective date of the policy amendments (October 29, 2025) to ensure compliance with the latest CVM regulations.
- Confirm the definition of "Bound Persons" to understand which employees and directors are subject to trading restrictions.
- Note the specific blackout period of 15 days prior to the release of quarterly and annual financial statements.
- Review the procedures for "Individual Investment Plans," which allow limited trading during restricted periods under strict conditions.
- Identify the Investor Relations Officer as the central point of contact for all material disclosures and policy monitoring.