Current Report by Foreign Issuer (Form 6-K)

2.3 To set guidelines for disclosing information on the trading in securities.

2.4 To set guidelines for disclosing Notices to the Market.

3.1.1 The rules provided for in this Policy must be complied with by all Sabesp Employees, even by those who have not sign the Statement of Adherence yet (Exhibit 2), as applicable.

3.1.2 This Policy sets forth specific rules that to the following people:

(i) controlling shareholder;

(ii) members of the statutory bodies;

(iii) employees with access to Material Acts or Facts;

(iv) Subsidiaries and Affiliates;

(v) trusted third parties; and

(v) the Company, when holding its own Securities.

3.1.3 The Controlling Shareholder, through the State Capital Defense Council (CODEC), the Subsidiaries and Affiliates must be informed on the provisions and updates of this Policy.

3.1.4 People indicated on 3.1.2 (i) a (iii) must sign the Statement of Consent to this Policy (Appendix 2), to be filed at the Company's headquarters as long as the person maintains a relationship with Sabesp, and for at least five years after the relationship is terminated.

3.1.5 The contract signed by the people indicated on 3.1.2 (iv) and (iv) must contain a clause providing for compliance with the guidelines established in this Policy, as applicable.

3.1.6 People indicated on 3.1.2 must ensure that their subordinates and trusted third parties observe the secrecy of undisclosed Material Acts or Facts, and are jointly responsible in the event of non-compliance, pursuant to CVM Resolution 44/2021, Article 8.

3.1.7 Any failure to comply with this Policy may be subject to penalties by the CVM, without prejudice to civil, criminal and administrative liability by Sabesp or other bodies.

3.2.1 For the purposes of this Policy, Material Acts or Facts are considered (i) any decision by the controlling shareholder; (ii) any resolutions of a shareholders' meeting or of the Company's management bodies; or (iii) any other act or fact of a political or administrative, technical, business, economic or financial nature related to Company business, that could have a measurable influence on:

a)the quoted price of Company securities or securities backed by them;

b)investors' decisions to buy, sell or hold these securities; or

c)investors' decisions to exercise any rights inherent to their condition as shareholders.

3.2.1.1 Some examples of potential Material Acts or Facts, in addition to those given in the sole paragraph of Article 2 of CVM Resolution 44/2021 are:

a)performance and financial results, and forecasts and expectations affecting them;

b)publication of an Investment Plan;

c)the election of a Chief Executive Officer or a Chief Financial Officer and Investor Relations Officer;

d)the resignation or dismissal of a member of the management;

e)decisions of the regulatory agency that have a significant impact on the Company, such as a tariff adjustment and/or tariff restructuring;

f) legal or arbitration proceedings with significant impact on the business;

g)a significant reduction in water production due to restrictions on the main inputs used, such as water resources, electricity and chemical products;

h)a change in the news channel used to disclose Material Acts or Facts; and

i)the engagement or discharge of a market maker.

Duties and Responsibilities

3.2.2 The disclosure of Material Acts or Facts and Notice to the Market, as well as the filing at CVM/B3 of the communications listed in items 3.3.9 and 3.3.11 of this Policy, are primarily the responsibility of the Chief Financial Officer and Investor Relations Officer.

3.2.5 The Chief Financial Officer and Investor Relations Officer must inquire people indicated on 3.1.2 whether they are aware of Material Acts or Facts that should be disclosed to the market pursuant to CVM Resolution 44/2021, Article 4, sole paragraph:

(i) if the CVM or the stock exchange on which Sabesp's securities are traded demands additional clarification of the Material Act or Fact;

(ii) if there are unusual fluctuations in the quotation, price or volume of Sabesp securities traded, or securities backed by them; or

(iii) If there is a leak to the media of a potential Material Act or Fact.

3.2.5.1 People indicated on 3.1.2 must respond immediately to requests for clarification from the Chief Financial Officer and Investor Relations Officer about the occurrence of Material Acts or Facts.

Method and channels of communication of Material Acts or Facts

3.2.6 Disclosure of Material Acts or Facts must be:

a)immediate, comprehensive, equitable and simultaneous in all the markets where Company securities are traded;

b)issued in writing, using simple, clear, objective and concise language, and the information given must be useful, true, complete and consistent, so as not to mislead the investor;

c)made at least one (1) hour before the opening or, preferably, immediately after the close of business on B3 and the NYSE, using the CVM/B3 electronic system and the following channels of communication:

i.the SEC electronic system;

ii.the news website indicated in the Company's records filed with the CVM;

iii.domestic and international news agencies;

iv.emails to registered addressees;

v.the "investors" page of Sabesp's website, at "https://ri.sabesp.com.br/en/";

vi.the Sabesp Corporate Portal;

d)issued in English simultaneously with the disclosure in Portuguese.

3.2.11 Exceptionally, a Material Act or Fact may not be disclosed if its disclosure might put the legitimate interests of the Company at risk, and always by the discretion of the controlling shareholder or themanagement.

3.2.11.1 In the event that a Material Act or Fact is involuntarily released, or if there is an atypical movement in the price of securities issued by the Company or backed by them, it must be immediately disclosed as provided for in items 3.2.2 and 3.2.6, even if the information refers to transactions in progress (not concluded), preliminary negotiations, feasibility studies or mere intentions.

3.2.12 People indicated on 3.1.2 who have knowledge of any Material Act or Fact not yet disclosed as provided for in item 3.2.6:

(i) must keep it confidential, pursuant to Article 8 of CVM Resolution 44/2021;

(ii) if they hold documents, files or any record of the material act or fact, they must ensure, through access restriction resources, that such documents will not be unauthorizedly accessed;

(iii) may discuss it or comment on it only with the people directly involved in the matter in question;

(iv) must ensure that their subordinates and trusted third parties keep it confidential, and are answerable jointly with them in case of non-compliance, pursuant to Article 8 of CVM Resolution 44/2021;

(v) must not discuss or comment on it with family members or others;

(vi) must not discuss or comment on it in public places; and

(vii) must not supply it to the press or reproduce it on social networks.

3.2.14 If applicable, before publication of minutes, statutory bodies must assess whether or not the content is a Material Act or Fact; if it is, the Material Act or Fact must be immediately communicated to the Chief Financial Officer and Investor Relations Officer as provided for in items 3.2.3 and 3.2.4., for disclosure pursuant to item 3.2.6. The minutes may only be published after the Material Act or Fact has been disclosed.

Notice to the Market

3.2.15 Other information that may be useful for shareholders and the market in general, but which does not represent a Material Act or Fact, must be disclosed in a Notice to the Market, at least on the CVM/B3 electronic system.

3.2.15.1 Some examples of Notice to the Market:

a) Information, including press releases, which supplement but do not represent Material Acts or Facts (Article 3 paragraph 3 of CVM Resolution 44/2021);

b) information on live streaming with Company executives and/or representatives of the Controlling Shareholder that directly or indirectly address matters related to Sabesp, via digital platforms open to the public in general. For the purpose of this Policy, the term "executives" means Members of Statutory Bodies and representatives of Sabesp speaking on its behalf;

c) material presented in meetings with analysts and market agents (Article 30-XIV of ICVM 480/2009) and in the live streaming described in item b) above;

d) changes in the membership of the Audit Committee (Article 30-XXX of ICVM 480/2009);

e) transactions with related parties (Article 30-XXXIIII and Appendix 30-XXXIIII of ICVM 480/2009);

f) Information on a change in auditors (Article 28, CVM Resolution 23/2021);

g) other occasional information listed in Article 30 of ICVM 480/2009 or in CVM ordinances, as applicable;

h) acquisition/disposal of a shareholding interest (Article 12 CVM Resolution 44/2021); and

i) clarifications to queries or questionings from CVM/B3, in terms of the corresponding request.

3.3.1 Pursuant to article 13 of CVM Resolution 44/2021, it is prohibited to use Material Information not yet disclosed, by any person who has had access to it, in order to obtain benefits, for themselves or others, by trading Securities.

3.3.1.1 For the purposes of defining the illicit act referred to in the caput, it is presumed that:

I - the individual who traded Securities with Material Information not yet disclosed made use of such information in said trading;

II - the individuals or legal entities mentioned in items 3.1.2 (i), (ii) and (vi), regarding business with Securities of their own issue, have access to all Material Information not yet disclosed;

III - the individuals listed in item II, as well as those who have a business, professional, or trust relationship with the Company, by having access to Material Information not yet disclosed, are aware that it is Privileged Information;

IV - the manager who resigns from the Company disposing of Material Information not yet disclosed, benefits from such information if he trades Securities issued by the Company within 3 (three) months as of his resignation;

V - are relevant, from the moment that studies or analysis related to the matter are initiated, the information about the operations of incorporation, total or partial spin-off, merger, restructuring, or any form of corporate reorganization or business combination, change in the Company's control, including by means of execution, amendment or termination of shareholders' agreement, decision to promote the cancellation of the registration of the publicly held company or change in the environment or trading segment of the shares issued by it; and

VI - information about judicial or extrajudicial reorganization and bankruptcy requests made by the Company itself are relevant, as from the moment studies or analysis related to such request are started.

3.3.1.2 The assumptions foreseen in 3.3.1.1:

I - are relative and must be analyzed in conjunction with other elements indicating whether or not the illicit act mentioned in 3.3.1 was, in fact, committed; and

II - may, if appropriate, be used jointly.

3.3.1.3 The assumptions provided for in item 3.3.1.1 do not apply to the stock option plan or to the granting of shares as a component of compensation, approved at a shareholders' meeting, or negotiations regarding fixed-income Securities, pursuant to article 13, paragraph 3 of CVM Resolution 44/2021.

3.3.1.4 The restriction of item 3.3.1.1 does not apply to subscriptions of new Securities issued by the Company, pursuant to article 13, paragraph 4 of CVM Resolution 44/2021.

3.3.2 Neither the Company nor the people indicated on 3.1.2, including anyone who by virtue of their title, function or position with Sabesp, its subsidiaries or affiliates, becomes aware of Material Acts or Facts, may trade in securities issued by Sabesp, or backed by them, including ADSs, in the following circumstances:

a) when Material Acts or Facts are pending disclosure;

b) if they are aware of information on another entity which might affect the quotation, prices or traded volume of securities issued by Sabesp; and

c) during the 15-day period preceding an official announcement of quarterly accounting information or annual financial statements, according to the Corporate Events Calendar.

3.3.2.1 The restriction period referred to in item 3.3.2 c) will only end after the filing of the information in the CVM/B3 electronic system.

3.3.2.2 The Chief Financial Officer and Investor Relations Officer may determine other blackout periods, even after the disclosure of the act or fact, if share trading could interfere with the terms of a deal to which the Material Act or Fact relates, to the detriment of the shareholders of the Company or of the Company itself.

3.3.3 The assumptions, restrictions, and disclosure requirements set forth in this Policy apply:

(i) to negotiations executed inside or outside regulated market environments, including private negotiations, of Securities;

(ii) to negotiations executed directly or indirectly, either through controlled companies or third parties contracted as fiduciary or portfolio managers;

(iii) to negotiations executed for his own behalf or for third parties; and

(iv) to Loan operations (rental) of Securities issued by Sabesp.

3.3.5 Material information is any information about a potential material act or fact, not limited to the examples listed in item 3.2.1.1.

3.3.6 Privileged information is any relevant information not yet disclosed to the market, to which the people mentioned in item 3.1.2 have had access due to their position, role or title in the Company.

3.3.7 People indicated on 3.1.2 who wish to trade in ADSs of Sabesp must:

a)register with the Depositary Bank of the Company's ADSs;

b)trade in accordance with the US rules for capital markets, including, without limitation, the Securities Act of 1933, the Securities Exchange Act of 1934, and this Policy;

c)trade in accordance with the Deposit Agreement in force between Sabesp, the Depositary Bank and the owners and holders of ADSs.

Individual Investment Plan

3.3.8 Pursuant to Article 15 in conjunction with Article 16 of Resolution CVM 44/2021, is not authorized the execution of Individual Investment or Divestment Plan, and they are expressly forbidden to trade in securities issued by Sabesp during the periods and under the terms of prohibitions defined in this Policy.

Communication of ownership

3.3.9 Ownership of and trading in securities issued by the Company must be communicated to the Company, through the Economic, Financial and Investor Relations Office, with copies to the Division of Capital Markets and Investor Relations and to the Investor Relations Department:

(i) by the controlling shareholder, within five (5) days of each trade executed by the controlling shareholder or linked people, as provided for in the Novo Mercado Listing Regulations;

(ii) by members of the statutory bodies, who must also give details of their Related People, at the time and in the form indicated in Articles 11 and 21 of CVM Resolution 44/2021.

(iii) by the Company itself and its subsidiaries and affiliates, pursuant to Articles 11 and 21 of CVM Resolution 44/2021.

3.3.10 Members of the statutory bodies must inform the Company of any change in the list of Related People within fifteen (15) days of the date of the change.

Communication of Trading in a Significant Shareholding Interest.

3.3.11 If the controlling shareholder or shareholders that elect members of the Board of Directors or the Fiscal Council, or any individual or legal entity, or group of people acting jointly or representing the same interests, execute a trade, as defined in paragraph 1 to 3 of Article 12 of CVM Resolution 44/2021, they must inform the Company, through the Division of Capital Markets and Investor Relations, with a copy to the Investor Relations Department, in the manner and at the time indicated in Article 12 of CVM Resolution 44/2021.

3.3.11.1 If an acquisition or sale affects the control or administrative structure of the Company, or gives rise to an obligation to make a public offering, the acquirer or seller must make a public announcement pursuant to Article 12 of CVM Resolution 44/2021.

PI0022v5 - Appendix 1 - Definitions.pdf

PI0022v5 - Appendix 2 - Statement of Consent.docx

Controlling Shareholder

According to Federal Law 6,404/76 and ICVM 361/2002, a controlling shareholder is an individual or legal entity, fund or universality of rights, or a group of people linked by a voting arrangement, or under direct or indirect common control, that:

a) is the owner of partner rights assuring a permanent voting majority on resolutions at shareholders' meetings and the power to appoint a majority of the members of the board of directors; and

b) effectively uses its power to guide the corporate activities of the Company and influence the operation of its statutory bodies.

Sabesp shares

Shares representing the capital stock of Sabesp

Members of Management

Officers and members of the Company's Board of Directors

ADS

American Depositary Share, a security traded in the United States representing Sabesp shares. ADSs can be attested by ADRs, or American Depositary Receipts.

B3

B3 S.A - Brasil Bolsa Balcão

Stock Exchange

B3, NYSE and any other stock exchanges or organized over-the counter markets where the Company's securities are traded.

Corporate Events Calendar

A calendar published on the CVM/B3 website and on the Investor Relations website (https://ri.sabesp.com.br/en/) with the official dates of publication of annual financial statements (DFPs), quarterly information (ITRs), Annual Shareholders' Meetings (AGMs), and other scheduled corporate events.

Affiliates

Companies over which Sabesp has significant influence, as defined in paragraphs 1, 4 and 5 of Art. 243 of Federal Law 6,404/1976.

Company or Sabesp

Companhia de Saneamento Básico do Estado de São Paulo - Sabesp

Subsidiaries

Companies controlled directly or indirectly by Sabesp, as defined in paragraph 2 of Art. 243 of Federal Law 6,404/1976.

CVM

Brazilian Securities Commission (https://www.gov.br/cvm).

Derivative

A financial instrument backed by or relating to underlying financial assets, indices, indicators, rates, goods, currencies, energy assets, transport, commodities or any other variables.

Employee

Person who renders paid services to an employer on a non-sporadic basis, and to whom he/she must be subordinated, whatever their title, function or position in the Company.

Employee with access to Material Acts or Facts

Any employee who, by virtue of their title, function or position in Sabesp, its parent company, subsidiaries or affiliates, has access to any Material Acts or Facts.

An initial listing indicates that the following employees have potential access, permanently or on a one-off basis, to Material Acts or Facts, and so must sign the Statement of Consent (Appendix 2):

·Executive Assistants;

· Heads, Chief of Staff and the Ombudsman;

·Advisors to the Executive Board;

·Executive secretaries and permanent participants of statutory bodies meetings;

·Department managers of the superintendencies responsible for the following matters: Accounting, Capital Markets and Investor Relations, Economic and Financial Controllership, Finance, Regulatory Affairs, New Businesses and Market Expansion, Legal Affairs, Risk Management and Compliance, and Auditing, Communication and Integrated Planning;

·Department Managers of Metropolitan Water Resources Department, Technological Prospection and Intellectual Property Department.

The Executive Officers and the persons described above may designate other employees with potential access to material acts and facts, either in a permanent or eventual manner.

Employees holding the positions described above, as well as those designated by them, must sign the Statement of Consent to this Policy (Appendix 2)

Securities lending (lease)

A transaction whereby one investor (the lender) lends a fixed amount of securities to another (the borrower), for a fixed period, whether or not a rate is agreed between them. In general, the lender is a long-term investor, who is not planning to sell the assets, at least during the period of the agreement. The borrower, on the other hand, is an investor who needs the assets only for a short period of time, usually to execute a strategy or meet an existing investment commitment.

ICVM 361/2002

Brazilian Securities Commission Instruction No. 361, of March 5, 2002, as amended. Provides for the procedures for public offerings for the acquisition of shares of a publicly-held company, the registration of such offerings for cancelling the registration as a publicly-held company, through an increase in the holding of the controlling shareholder, disposal of control of a publicly-held company, for the acquisition of control of a publicly-held company involving an exchange of securities, or for an exchange of securities.

ICVM 480/2009

Brazilian Securities Commission Instruction No. 480, of December 7, 2009, as amended. Provides for the registration of issuers of securities admitted for trading on regulated markets.

Federal Law 6,385/1976

Law No. 6,385, of December 7, 1976, as amended. Provides for the securities market and creates the Securities Commission.

Federal Law 6,404/1976

Law No. 6,404, of December 15, 1976, as amended. provides for joint-stock companies (Brazilian Corporate Law).

Federal Law 13,303/2016

Law No. 13,303, of June 30, 2016. Provides for the legal regulations of government-owned and government-controlled companies and their subsidiaries, at the federal, state and municipal level.

Members of the Statutory Bodies

Members of the Board of Directors, Officers, members of the Fiscal Council (members and alternates), members of the Audit Committee, the Eligibility and Advisory Committee and any other bodies with technical or advisory functions, existing or to be created in the future by statutory ordinance of Sabesp.

Direct trades

Trades executed directly by the owner of a security.

Indirect trades or through third parties

Trades executed through:

Related People; or

Third parties under a trust agreement or a portfolio or share management agreement.

Trades by investment funds in which Covered People hold shares are not considered to be indirect trades, and are not subject to the prohibitions of this Policy, provided that:

i.the fund manager's investment decisions cannot be influenced by the shareholders; and

ii.the investment funds are not exclusive.

NYSE

The New York Stock Exchange.

Statutory Body

The Board of Directors, Officers, Fiscal Council, Audit Committee, Eligibility and Advisory Committee and any other bodies with technical or consultative functions, existing or to be created in the future by statutory ordinance of Sabesp.

Related Person

With regards to the natural persons stated in item 3.1.2 (ii) and, pursuant to CVM Resolution 44/2021, these are:

(i) spouse not separated judicially or extrajudicially;

(ii) cohabitant;

(iii) any dependent included in the annual tax return; and

(iv) direct or indirect subsidiarires.

Tied Person

An individual or legal entity, fund or universality of rights which acts representing the same interests of another individual or legal entity, fund or universality of rights as defined in ICVM 361/2002.

Novo Mercado Listing Regulations

Regulations applicable to companies with shares traded in the special listing segment of B3 referred to as the Novo Mercado. Sabesp has been listed in this segment since 2002.

CVM Resolution 44/2021

Provides for the disclosure of information on material act or fact, the trading of Securities pending undisclosed material act or fact, and the disclosure of information on the trading of Securities, and revokes CVM Instructions 358, of January 3, 2002, 369, of June 11, 2002, and 449, of March 15, 2007.

SEC

U.S. Securities and Exchange Commission

Securities Act of 1933

The Securities Act of 1933, as amended. A US law of 1933 setting rules for the disclosure of complete and fair information on securities, in order to protect investors against fraud.

http://legcounsel.house.gov/Comps/Securities%20Act%20Of%201933.pdf

Securities Exchange Act of 1934

The Securities Exchange Act of 1934, as amended. A US law on regulation of securities exchanges, enacted in 1934.

http://legcounsel.house.gov/Comps/Securities%20Exchange%20Act%20Of%201934.pdf

Trusted third parties

Any individual or legal entity that may have access to Material Acts or Facts as a result of a commercial or professional relationship, or a relationship of trust, with Sabesp, such as independent auditors, securities analysts, consultants and members of the securities distribution system.

Statement of Consent

Statement of consent to the Institutional Policy for Disclosure of Material Acts or Facts and Trading in Securities Issued by Sabesp, to be signed by the Covered People. A model is contained in Appendix 2 to the Policy.

Securities

Shares, debentures, promissory notes, subscription warrants, receipts and rights of subscription, and any other security listed in Article 2 of Federal Law 6.385/1976; and also ADSs, bonds and other securities traded in international markets equivalent to the items mentioned in Article 2 of Federal Law 6,385/1976.

STATEMENT OF CONSENT

to the Institutional Policy for Disclosure of Material Acts or Facts and Trading in Securities Issued by Sabesp

I, [name], TAX ID CPF No. [...],address at [Street, No., unit, City, State, CEP], as [function or title], hereby confirm that I have received a copy and am aware of the terms and conditions of the Policy on Disclosure of Material Acts or Facts and Trading in Securities Issued by Sabesp - PI0022v.5, approved at the 952^nd Meeting of the Board of Directors of Companhia de Saneamento Básico do Estado de São Paulo - SABESP, as required by CVM Resolution 44/2021.

I hereby give my consent to the Policy and undertake to comply with all its terms and conditions. I also confirm that I am aware that failure to comply with the provisions of the Policy and of CVM Resolution 44/2021 is a serious violation, for the purposes of paragraph 3 of Article 11 of Federal Law No. 6,385/76.

[city], [date]

___________________________

[name]