Net debt / EBITDA

Formulas: - Gross debt = 2.01.04 + 2.02.01 (loans and financing, current and non-current, including debentures and — since 2019/IFRS 16 — leases) - Net debt = Gross debt − Cash (1.01.01) − Financial investments (1.01.02) - EBITDA = EBIT (3.05) + D&A - ND/EBITDA = Net debt / EBITDA

Where D&A comes from (the honest part)

Depreciation/amortization has no fixed account in CVM's standardized chart of accounts. We extract it from the indirect-method DFC (block 6.01): we add up the lines whose description contains "deprecia", "amortiza" or "exaust", taking only the deepest lines (parent and child never count twice). The exact accounts used are recorded in fato.origem, company by company, year by year.

Amortization of DEBT issuance cost is excluded (since 2026-08-30). Lines such as "amortização do custo de captação", "custo de transação de empréstimos", "comissão sobre debêntures" or "gastos com emissão de debêntures" all contain the word amortização and are financing expense, not depreciation of an asset. Adding them to EBITDA inflates an operating measure with a financial item.

The finding came from an external audit: a reviewer checked SUZB3 2023 against the company's audited financial statements and noticed our D&A included 6.01.01.11 Amortização do custo de transação, ágio e deságio (R$ 67 million, +0.34% on EBITDA). He did not declare a discrepancy — he recorded the caveat, because he could not open the CVM file to show the account. Starting from that one case we measured the whole class: 279 company-years, 226 inflated EBITDA figures, 107 of them above 1% and 35 above 5%; the worst was SERENA ENERGIA 2023 at +38.9% (R$ 908 million on a R$ 2.3 billion EBITDA). The fix changed 232 EBITDA and 223 Net debt/EBITDA values.

What still counts, and this is half the rule: amortization of mais-valia (the fair-value step-up from a business combination), of goodwill, of intangibles and of right-of-use assets. All of these are amortization of an ASSET and belong in EBITDA by definition. The first exclusion pattern we wrote would have removed them from 89 lines — over-correcting is the same defect as under-correcting.

This is a correction, not a mark. The house rule is to mark when the source is ambiguous; a label that says "cost of raising debt" is not ambiguous.

Declared safeguards (each one becomes a flag): - Company with no indirect-method DFC in the year → D&A null → EBITDA and ND/EBITDA null, flag sem_da_na_dfc. We do not estimate. - EBITDA ≤ 0 → ND/EBITDA is not published (flag ebitda_nao_positivo).

Declared limitation: this "EBITDA" is the reconstructed accounting one (EBIT + D&A from the DFC), not the "adjusted EBITDA" of the companies' releases — which each company defines its own way and which is therefore not comparable.

Source, treatment and general limitations: see fontes_e_padronizacao.md.