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Trading Policy


Updated in 2007-10-15T12:22:04
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SADIA S. A.

        CNPJ/MF nº 20.730.099/0001-94

           A PUBLICLY-HELD COMPANY

POLICY FOR TRADING STOCK,  NOTES,  MARKETABLE
SECURITIES  AND  DERIVATIVES  ISSUED  BY  THE
COMPANY AND BY THIRD PARTIES, IF ANY

1 - PURPOSE
This  Policy  for   Trading   Stock,   Notes,
Marketable Securities and Derivatives  issued
by the Company  ("Trading  Policy")  aims  to
establish the criteria and procedures  to  be
observed by the  persons  listed  below  when
trading   ("Trading")   stock,   notes    and
marketable   securities,   including    their
Derivatives  (ADRs  -   American   Depositary
Receipts,  as  an  example),  issued  by  the
Company and  occasionally  by  third  parties
and, in this latter  case  particularly  when
the Company is involved  in  the  acquisition
of a shareholding control,  or  in  combining
an operational  partnership,  joint  venture,
merger and a takeover  of  another  publicly-
held company which is  not  part  of  Sadia's
economic group.

2 - SCOPE
This Trading Policy applies to the  following
persons ("Restricted  Persons")  and  to  the
very Company who are obliged to  comply  with
it faithfully:
-      controlling   shareholders   who   are
   signatories to the Company's Shareholders'
   Agreement    ("Assenting     Shareholders"
   [either direct or indirect]);
-     Company administrators (members of  the
   Executive  Board  and  of  the  Board   of
   Directors);
-      members   of   the   Audit   Committee
   (incumbents and deputies);
-     members of the Advisory Council;
-      members  of  any  other  bodies   with