The Complaint alleges that throughout the Class Period, Defendants issued false and misleading statements to investors and / or failed to disclose that:

1. The accident at Samarco Mineracao S.A. (“Samarco”) of the bursting of the Fundao Dam resulted in the spillage of toxic waste;
2. Vale had a contract with Samarco that allowed Vale to deposit iron ore waste from its treatment plants from Vale’s Alegria mine into the Fundao Dam;
3. Vale’s programs and procedures to mitigate environmental, health, and safety incidents were inadequate; and
4. As a result, Defendants’ statements about the Company’s business and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times

When the true details entered the market, the lawsuit claims that investors suffered damages.

On behalf of all persons and entities who purchased or otherwise acquired Vale S.A.’s (“Vale” or the “Company”) common or preferred stock American Depository Receipts during the Class Period