Vale (VALE) legal chief holds 55,528 cash-settled RSUs tied to shares

Rhea-AI Filing Summary

Vale S.A. reported initial holdings for Executive VP Legal Officer Sami Arap Sobrinho on a Form 3. He holds Restricted Share Units linked to 55,528 Common Shares. Each RSU represents a contingent right to the economic equivalent of one common share, vesting in equal installments on March 1, 2027 and March 1, 2028, and will be settled in cash.

Insider Trade Summary

1 transaction reported

Mixed 1 txn

Insider Arap Sobrinho Sami

Role Executive VP Legal Officer

Type	Security	Shares	Price	Value
holding	Restricted Share Units	--	--	--

Holdings After Transaction: Restricted Share Units — 55,528 shares (Direct)

Footnotes (1)

1. [object Object]

Key Figures

Underlying shares: 55,528 shares Exercise price: $0.00 per unit Vesting date 1: March 1, 2027 +1 more

4 metrics

Underlying shares 55,528 shares Common Shares underlying Restricted Share Units, direct ownership

Exercise price $0.00 per unit Restricted Share Units exercise/conversion price

Vesting date 1 March 1, 2027 First annual RSU vesting installment

Vesting date 2 March 1, 2028 Second annual RSU vesting installment

Key Terms

Restricted Share Units, contingent right, economic equivalent, settled in cash

4 terms

Restricted Share Units financial

"Each Restricted Share Unit ("RSU") represents a contingent right to receive the economic equivalent of one Common Share"

Restricted share units (RSUs) are a promise from a company to give an employee or service provider actual shares or cash equal to the shares after certain conditions are met, typically staying with the company for a set time or hitting performance targets. Think of them like a time-locked gift card that becomes usable only after you’ve earned it. For investors, RSUs matter because they align employee incentives with company performance and can increase the number of shares outstanding over time, diluting existing ownership and affecting earnings per share.

contingent right financial

"represents a contingent right to receive the economic equivalent of one Common Share"

economic equivalent financial

"to receive the economic equivalent of one Common Share of Vale S.A."

settled in cash financial

"The RSUs vest annually in equal installments ... and will be settled in cash."

Understanding Insider Trading Forms →

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

OMB APPROVAL

OMB Number:			3235-0104
Estimated average burden
hours per response:			0.5

1. Name and Address of Reporting Person^*

Arap Sobrinho Sami

(Last) (First) (Middle)

PRAIA DE BOTAFOGO 186

19TH FLOOR BOTAFOGO

(Street)

RIO DE JANEIRO RIO DE JANEIRO 2225145

(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
Vale S.A. [ VALE ]

3a. Foreign Trading Symbol
[VALE3]

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

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

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

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)

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
Restricted Share Units	(1)	(1)	Common Shares	55,528	(1)	D

Explanation of Responses:

1. Each Restricted Share Unit ("RSU") represents a contingent right to receive the economic equivalent of one Common Share of Vale S.A. The RSUs vest annually in equal installments on March 1, 2027 and 2028 and will be settled in cash.

Remarks:

Exhibit 24 - Power of Attorney

	/s/ Thiago Kiill Lofiego, Attorney-in-fact	03/31/2026
	** 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 Vale (VALE) Form 3 filing for Sami Arap Sobrinho disclose?

The Form 3 discloses that Executive VP Legal Officer Sami Arap Sobrinho holds Restricted Share Units tied to 55,528 Vale common shares. These RSUs are a form of compensation that track share value but are settled in cash rather than stock.

How many Vale (VALE) shares underlie Sami Arap Sobrinho’s Restricted Share Units?

The filing shows RSUs linked to 55,528 underlying common shares of Vale S.A. Each RSU represents the economic equivalent of one share, giving cash-based exposure to the company’s stock performance over time.

When do Sami Arap Sobrinho’s Vale (VALE) Restricted Share Units vest?

The RSUs vest in two equal annual installments on March 1, 2027 and March 1, 2028. Vesting means portions of the award become earned over time, subject to continued service and any plan conditions.

Are the Vale (VALE) Restricted Share Units settled in stock or cash?

According to the filing, the RSUs will be settled in cash. Although each unit tracks the value of one common share, the executive ultimately receives a cash payment instead of additional Vale shares at settlement.

What does “each RSU represents the economic equivalent of one Vale (VALE) common share” mean?

It means each Restricted Share Unit’s value mirrors one Vale common share, but the holder receives cash based on that share’s value at settlement, rather than receiving the actual share itself.