TTEN3 Board Independence Rules under Novo Mercado
TTEN3 FRE governance disclosure is a useful contrast to mega-cap boards: the policy framework is detailed, but the filing does not list named independents or the current independent count.
This page summarizes a board-independence analysis from the 2025 FRE. apicvm returns the filings.
The research question
> Assess board composition rules, independence criteria, evaluation, and conflicts.
Structural rules
| Rule | Disclosure |
|---|---|
| Board size | 4–9 members; 2-year unified term; re-election allowed |
| Independence floor | At least 2 or 20%, whichever is greater (round up if fractional) |
| Standards | Novo Mercado + CVM Resolution 80 |
| Evaluation | Board as a body each term; individual directors, Audit Committee, other committees, and executive board at least once per term |
| External board review | None hired in the covered year |
Independence disqualifiers include controlling shareholders, shareholder voting agreements, close family ties, and employment/directorship in the last 3 years.
Ownership disclosure (partial)
| Holder group | Shares disclosed |
|---|---|
| Board of Directors | 10,700 |
| Statutory Executive Board | 12,133,173 |
| Combined | 12,143,873 |
The FRE excerpt did not provide total share capital for percentage conversion — so “skin in the game” cannot be computed from this section alone.
Research takeaway
You can score policy quality from the FRE. You cannot score current independence headcount without the nominal roster — a gap that section-level retrieval should surface explicitly rather than hallucinate.
Replicate with apicvm
export APICVM_KEY='apicvm_...'
export APICVM_URL='https://apicvm.dev'
curl -H "Authorization: Bearer $APICVM_KEY" \
"$APICVM_URL/v1/companies/resolve?query=TTEN3&by=ticker"
curl -H "Authorization: Bearer $APICVM_KEY" \
"$APICVM_URL/v1/documents?ticker=TTEN3&type=FRE&year=2025&name=Governan"
curl -X POST -H "Authorization: Bearer $APICVM_KEY" \
-H "Content-Type: application/json" \
-d '{"callback_url":"https://your-server/callback","document":{"id":"<id>"}}' \
"$APICVM_URL/v1/document-text-extractions"Methodology note
Findings above come from a completed Hold analysis of the company's public 2025 FRE. This is a research illustration, not investment, legal, or tax advice. Verify numbers against the original filing before trading, modeling, or publishing reports.
Limitations
- apicvm returns filings and extracted text — it does not classify risks or compute coverage ratios.
- Figures are as of the FRE filing date; later ITRs or facts relevantes can update them.
- Corpus coverage depends on ingestion lag.
Next steps
Ready to integrate?
Get an API key and start querying Brazilian CVM filings programmatically.