Eletrobras (NYSE: EBR) director details large indirect stakes and RSUs

Rhea-AI Filing Summary

Brazilian Electric Power Co (Eletrobras) director Pedro Batista de Lima Filho filed an initial Form 3 listing indirect holdings in the company’s shares. The filing shows multiple managed accounts advised by Radar Gestora holding Common Shares, Class “B1” Preferred Shares and Class “C” Preferred Shares, for which he may be deemed an indirect beneficial owner, subject to pecuniary-interest disclaimers. It also reports 40,476 restricted stock units that are economically equivalent to Common Shares and reserved for the Board of Directors.

SEC Form 3

FORM 3

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

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1. Name and Address of Reporting Person^*

Batista de Lima Filho Pedro

(Last) (First) (Middle)

AVENIDA GRACA ARANHA, NO. 26

CENTRO

(Street)

RIO DE JANEIRO 20030-000

(City) (State) (Zip)

BRAZIL

(Country)

2. Date of Event Requiring Statement (Month/Day/Year)
03/18/2026

3. Issuer Name and Ticker or Trading Symbol
BRAZILIAN ELECTRIC POWER CO [ AXIA3 ]

3a. Foreign Trading Symbol
[AXIA6 AXIA7]

5. If Amendment, Date of Original Filed (Month/Day/Year)

4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director		10% Owner
	Officer (give title below)		Other (specify below)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1. Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)
Common Shares	5,420,200	I	By managed account(1)(2)
Common Shares	2,426,032	I	By managed account(3)(4)
Common Shares	29,152	I	By managed account(5)(6)
Common Shares	38,502	I	By managed account(7)(8)
Common Shares	1,366,500	I	By managed account(9)(10)
Common Shares	1,260,946	I	By managed account(11)(12)
Class "B1" Preferred Shares	14,813,300	I	By managed account(1)(2)
Class "B1" Preferred Shares	8,045,900	I	By managed account(3)(4)
Class "B1" Preferred Shares	274,450	I	By managed account(5)(6)
Class "B1" Preferred Shares	362,073	I	By managed account(7)(8)
Class "B1" Preferred Shares	3,734,776	I	By managed account(9)(10)
Class "B1" Preferred Shares	3,668,377	I	By managed account(11)(12)
Restricted Stock Units(13)	40,476	D

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
Class "C" Preferred Shares	(14)	(14)	Common Shares	5,318,130	(14)	I	By managed account(1)(2)
Class "C" Preferred Shares	(14)	(14)	Common Shares	2,751,866	(14)	I	By managed account(3)(4)
Class "C" Preferred Shares	(14)	(14)	Common Shares	79,798	(14)	I	By managed account(5)(6)
Class "C" Preferred Shares	(14)	(14)	Common Shares	105,286	(14)	I	By managed account(7)(8)
Class "C" Preferred Shares	(14)	(14)	Common Shares	1,340,808	(14)	I	By managed account(9)(10)
Class "C" Preferred Shares	(14)	(14)	Common Shares	1,295,612	(14)	I	By managed account(11)(12)

Explanation of Responses:

1. Pedro Batista de Lima Filho ("Mr. Filho") is a partner at Radar Gestora de Recursos Ltda. ("Radar Gestora"), which is responsible for the portfolio management of MALIKO INVESTMENTS LLC - BANCO BTG PACTUAL S/A ("Maliko") and receives a performance-based compensation in his capacity as a partner of Radar Gestora , which directly holds 5,420,200 Common Shares, 14,813,300 Preferred "B1" Shares and 5,318,130 Class "C" Shares of Eletrobras - Brazilian Electric Power Co. (the "Company"). Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Maliko.

2. For the purposes of this filing, each of Maliko and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Maliko or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended, or otherwise.

3. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of MANUKA INVESTMENTS LLC - BANCO BTG PACTUAL S/A ("Manuka") and receives a performance-based compensation in his capacity as a partner of Radar Gestora, which directly holds 2,426,032 Common Shares, 8,045,900 Preferred "B1" Shares and 2,751,866 Class "C" Shares of the Company. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Manuka.

4. For the purposes of this filing, each of Manuka and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Manuka or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended, or otherwise.

5. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of TUCURUI MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Tucurui") and receives a performance-based compensation in his capacity as a partner of Radar Gestora, which directly holds 29,152 Common Shares, 274,450 Preferred "B1" Shares and 79,798 Class "C" Shares of the Company. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Tucurui.

6. For the purposes of this filing, each of Tucurui and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Tucurui or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended, or otherwise.

7. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of XINGO MASTER FUNDO DE INVESTIMENTO FINANCEIRO DE ACOES ("Xingo") and receives a performance-based compensation in his capacity as a partner of Radar Gestora, which directly holds 38,502 Common Shares, 362,073 Preferred "B1" Shares and 105,286 Class "C" Shares of the Company. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Xingo.

8. For the purposes of this filing, each of Xingo and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Xingo or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended, or otherwise.

9. Mr. Filho is a partner at Radar Gestora which is responsible for the portfolio management of RADAR MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Radar") and receives a performance-based compensation in his capacity as a partner of Radar Gestora, which directly holds 1,366,500 Common Shares, 3,734,776 Preferred "B1" Shares and 1,340,808 Class "C" Shares of the Company. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Radar.

10. For the purposes of this filing, each of Radar and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Radar or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended, or otherwise.

11. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of INFRAD MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Infrad") and receives a performance-based compensation in his capacity as a partner of Radar Gestora, which directly holds 1,260,946 Common Shares, 3,668,377 Preferred "B1" Shares and 1,295,612 Class "C" Shares of the Company. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Infrad.

12. For the purposes of this filing, each of Infrad and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Infrad or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended, or otherwise.

13. Each restricted stock unit ("RSU") is the economic equivalent of one Common Share, is settled in Common Shares on a 1:1 basis, and was issued pursuant to the Company restricted share based compensation program. These RSUs are reserved for the Board of Directors.

14. Pursuant to Article 11 of the Bylaws of the Company, the Class "C" Preferred Shares shall be automatically converted into Common Shares, assuming such Class "C" Preferred Shares are not earlier mandatorily redeemed by the Company in accordance with its Bylaws, at a ratio of 1:1, as follows: * 4% of the total volume of originally-issued Class "C" Preferred Shares, allocated proportionally among all holders, in each of the fiscal years 2026, 2027, 2028, 2029 and 2030; and * all Class "C" Preferred Shares remaining, in fiscal year 2031.

Remarks:

The Company currently trades on the B3 S.A. - Brasil, Bolsa, Balcao (B3) under the following ticker symbols, "AXIA3" for its Common Shares; "AXIA6" for its Class "B1" Preferred Shares and "AXIA7" for its Class "C" Preferred Shares.

	/s/ Pedro Batista de Lima Filho	03/18/2026
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 5 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 3: SEC 1473 (03-26)

FAQ

What does the EBR Form 3 for Pedro Batista de Lima Filho disclose?

The Form 3 discloses initial insider holdings in Brazilian Electric Power Co by director Pedro Batista de Lima Filho. It details indirect positions through several managed accounts plus 40,476 restricted stock units reserved under the company’s board compensation program.

Are there any insider share purchases or sales in this EBR Form 3?

The Form 3 does not report any insider purchases or sales. Transaction data show zero buy and sell entries, with 19 holding records and a neutral net buy/sell direction, indicating this filing simply establishes existing positions rather than new trades.

How are Maliko and Manuka related to EBR director Pedro Batista de Lima Filho?

Maliko and Manuka are investment vehicles managed by Radar Gestora. As a partner at Radar Gestora, Pedro Batista de Lima Filho may be deemed to indirectly beneficially own shares those entities hold, while both he and the entities disclaim beneficial ownership beyond pecuniary interest.

What does the EBR filing say about Class "C" Preferred Shares conversion?

Class “C” Preferred Shares automatically convert into Common Shares. The bylaws provide a 1:1 conversion, with 4% of the originally issued Class “C” shares converting each fiscal year from 2026 through 2030, and all remaining shares converting in fiscal year 2031.

What are the restricted stock units reported in the EBR Form 3?

The filing reports 40,476 restricted stock units (RSUs). Each RSU is economically equivalent to one Common Share and is settled on a 1:1 basis. These RSUs were issued under the company’s restricted share-based compensation program and are reserved for members of the Board of Directors.

Does the EBR Form 3 show direct or indirect ownership for most holdings?

Most reported holdings are indirect through managed accounts. The Common, Class “B1” Preferred, and Class “C” Preferred share positions are shown as indirectly owned by accounts managed by Radar Gestora, whereas the 40,476 restricted stock units are held as direct ownership.