Total remuneration at Bracell is based on the employee’s role as well as their skills and competencies. We also apply variable compensation criteria linked to results, alignment with, and dissemination of our T.O.P.I.C.C. organizational values.

Our compensation structure is compliant with current labor laws and all collective bargaining agreements. We also benchmark our compensation practices so we remain competitive in attracting and retaining talent to support Bracell’s strategies and goals.

Internally, compensation is determined based on a role’s grading and/or its relative importance in the organizational structure, internal pay equity, the knowledge and competencies required for each role, the defined organizational structure, available budget, and both individual and company performance.

The salary table is updated annually based on market benchmarks. Benchmarking assessments cover variables such as competitor compensation, regional benchmarks, labor availability, unemployment rates, and turnover.

For executive-level positions, Bracell’s Compensation Policy includes fixed and variable pay, signing bonuses and hiring incentives, retirement benefits, and severance-related policies.

For leadership positions, variable compensation includes bonuses linked to achieving organizational goals, including commitments outlined in Bracell 2030 (read more under Bracell 2030).

Variable compensation consists of two components:

Performance Contract (PC): individual contracts outlining employee-specific performance targets, as part of a corporate bonus program. This model aligns individual with organizational objectives and drives high performance and talent retention.

Core Values Evaluation Form: in this component, payment is tied to performance assessed through our Profit-Sharing Program (PPR), which is agreed annually by the company, an employee committee, and the labor union to match compensation with overall business performance.

Contract terminations follow the guidelines established by Brazilian labor legislation.

At Bracell, the term “senior management” refers to individuals serving as President, Vice President, Chief Operations Officer, or Head of Operations. As of the reporting year, Bracell’s senior management team comprises seven members—4 based in São Paulo and 2 in Bahia. One executive was hired locally in São Paulo.

Bracell Papéis currently has two senior management executives, both of whom are internal hires from Bracell Papéis Sudeste. Their leadership responsibilities include oversight of our Northeast paper operations. No local hires were made for senior-level positions within Bracell Papéis during the reporting period (for more details, see GRI 405-1).

Bracell is a member of Royal Golden Eagle (RGE), a conglomerate of biological resource-based manufacturing and energy companies with global operations. As a closely held company, we are not listed on any stock exchange.

RGE has an Executive Management Board comprised of strategic executives, while each business unit has its own leadership structure, with CEOs, management teams and boards of directors.

Executives on the RGE Executive Management Board are appointed to monitor and oversee specific roles in business units, ensuring strategic alignment and management support. In addition, executives from different business units report quarterly to the RGE Executive Management Board to present results and discuss corporate matters.

The highest governance body for sustainability is the Sustainability Steering Committee, which is responsible for:

• Monitoring sustainability performance
• Overseeing environmental, social and governance practices (learn more under GRI 2-18)

Members are selected on the basis of technical expertise, skills and strategic competences, guaranteeing high-quality decision-making in line with the company’s sustainability principles.

The Sustainability Steering Committee receives advisory support from Bracell’s senior operational management, composed of the heads of forestry operations, mill operations, logistics, legal affairs, internal audit, corporate relations and human resources, as well as the Sustainability VP. This structure enables a comprehensive analysis of environmental, social and governance risks and impacts. (See more in GRI 2-17)

In addition, Bracell has a Crisis Committee that is convened to manage unexpected events and emergencies, ensuring rapid, coordinated responses to mitigate impacts on operations and stakeholders. (See more in GRI 2-16)

Oversight and transparency

Bracell’s CEO and senior management regularly report to the RGE Executive Board, ensuring continuous oversight of our strategic planning and sustainability strategy and full transparency and alignment with corporate goals. (See more in GRI 2-18)

Composition of the Sustainability Steering Committee

President

Praveen Singhavi (Read more under GRI 2-11)

Industrial Operations Officer – São Paulo

Guilherme Araújo

Head of Forestry Operations

Mauro Quirino

Managing Director – Bahia

Rudine Antes

Executive Vice President

Luiz Carlos Cavalcanti Dutra Junior

Managing Director – Bracell Papéis

Eduardo Aron

The Committee comprises six members, all male and all holding executive positions. There are no independent or advisory members on our governance bodies or committees.

Bracell’s senior executives have permanent roles, although the composition of the board may change with business strategy.

Find out more about the responsibilities, competencies and expertise of the members of the Sustainability Steering Committee under GRI 2-17.

The selection of the members of Bracell’s Sustainability Steering Committee and heads of operations, which comprise the company’s senior management, is based on an analysis of candidates’ expertise, skills, seniority and dedication, competencies and technical know-how. That analysis aims to select people who are able to contribute to creating positive value for the business, for Bracell’s sustainability strategy and for the areas where we operate (see more under GRI 2-17 and 2-18).

Bracell’s Vice President of Sustainability reports directly to the Sustainability Steering Committee, to which, on a quarterly basis, he communicates progress made towards the Bracell 2030 sustainability targets and commitments.

The Sustainability Steering Committee deliberates on the execution of the company’s strategic plan, sustainability targets and commitments, and risks and impacts relating to environmental, social and governance issues.

Bracell’s president, Praveen Singhavi, was appointed in January 2023 and is responsible for the execution of strategic plans, approval of Bracell 2030 targets and commitments, and approval and oversight of strategic operational projects. For more than 15 years (April 2007 January 2023), he previously served as president of April, an RGE Group company and one of the world’s largest and most advanced producers of fiber, pulp and paper, with operations in the province of Riau, Sumatra, Indonesia (learn more under GRI 2-9 and 2-17).

The Sustainability Steering Committee, led by Bracell’s president, Praveen Singhavi, is responsible for strategic decision-making concerning key sustainability matters. The committee oversees and validates the management of environmental, social and governance risks and impacts, ensuring that sustainability is aligned with long-term business planning.

Among its responsibilities, the committee is also in charge of validating Bracell’s materiality matrix, ensuring that priority is given to the most important issues for stakeholders and company strategy. (See more in GRI 3-2)

Sustainability steering committee oversight of internal and external audits

The Sustainability Steering Committee monitors the results of internal and external audits, assessments on compliance with Forestry Certification Endorsement Program (PEFC), ISO 9001 and ISO 14001 certification standards, carried out annually, and audits on the International Finance Corporation (IFC) Performance Standards and Equator Principles, which take place twice yearly (see more in ESG certifications and badges).

It also monitors and oversees continuous improvement processes as part of the Bracell Integrated Management System (see more in GRI 2-13), for compliance with the requirements of certification standards, legislation and international sustainability protocols.

All applicable policies, protocols, regulations and standards are  incorporated in internal procedures outlining processes and guidelines on managing social, environmental and governance issues. These documents are part of Bracell’s Integrated Management System, accessible to all Bracell employees.

Sustainability Steering Committee oversight of priority topics for internal and external stakeholders

Bracell’s Managing Director of Institutional Relations, who is a member of the Sustainability Steering Committee, is responsible for overseeing activities designed to cultivate relationships with external stakeholders, including local communities, traditional communities and peoples, trade associations, and government organizations and representatives.

Other strategic stakeholders (employees, contractors, suppliers, customers and financial institutions) also have their interests represented by the executives of each department responsible for relations with and engagement of those stakeholders: heads of forestry and industrial operations, logistics, sales, finance, human resources, as well as the Vice President of Sustainability.

Position	Executive	Scope of work
President	Praveen Singhavi	Chief operations officer for Bracell in Brazil
Industrial Operations Officer – São Paulo	Guilherme Araújo	Head of mill operations, São Paulo
Head of Forestry Operations	Mauro Quirino	Head of forestry operations, São Paulo
Managing Director – Bahia	Rudine Antes	Head of industrial and forestry operations, Bahia
Executive Vice President	Luiz Carlos Cavalcanti Dutra Junior	Stakeholder engagement strategic planning lead
Managing Director – Bracell Papéis	Eduardo Aron	Head of operations for Bracell Papéis in Brazil

Bracell’s strategic priorities, which cover business and sustainability goals, targets and commitments, are aligned with our Mission, Vision and Values, as well as our Sustainability Vision (see more in GRI 2-6 and GRI 2-22).

Operational management is carried out in accordance with corporate policies, operational procedures, risk matrices and environmental, social and governance impacts comprising Bracell’s Integrated Management System. These policies and procedures comply with the requirements of ISO 14001, ISO 9001, Forestry Certification Endorsement Program (PEFC) certification requirements, applicable legislation, regulatory standards, and international sustainability and anti-corruption management protocols.

The Environment and Certification departments of Bracell’s forestry and industrial operations are responsible for the Integrated Management System, and report to their respective Operations Managing Director.

Social issues, like labor law, human rights, and occupational health and safety, are managed by the Human Resources, Contractor Management, Occupational Health, Forestry Occupational Safety and Industrial Occupational Safety departments.

In addition, Bracell has supporting departments that also manage social, environmental and governance issues, in line with national law and international protocols concerning sustainability and compliance, such as our Sustainability, Customer Service, Compliance, Internal Audit, Legal, Institutional Relations, Community Relations and Corporate Social Responsibility (CSR) departments, as follows:

• the Sustainability, Institutional Relations, Community Relations and Corporate Social Responsibility and Corporate Communication departments, which report to the CEO.
• the Customer Service Department, which reports to the Chief Industrial Operations Officer, São Paulo
• the Compliance and Legal departments, reporting to the Chief Legal Officer
• the Internal Audit Department, reporting to the Head of Internal Audit

Find out more about the governance structure responsible for impact management under GRI 2-9 and GRI 2-10.

Bracell’s corporate policies containing guidelines on environmental, social and governance issues include the following:

– Sustainability Policy;

– Human Rights Policy;

– Anti-Corruption and Anti-Bribery Policy;

– Code of Procurement Ethics;

– Bracell Code of Conduct;

– Pulpwood and Fiber Sourcing Policy;

– Whistleblowing Policy;

– Third-Party Due Diligence Policy (internal procedure)

Bracell’s Sustainability Steering Committee actively participates in the preparation and approval of our Sustainability Reports. The members of this governance body review the reported information and data concerning the company’s sustainability performance.

Disclosures are audited externally by a third party for consistency, transparency, and alignment with the principles applicable to the disclosure of sustainability results in international frameworks like the Global Reporting Initiative (GRI) Standards and the Global Compact Communication on Progress (CoP), to which Bracell committed voluntarily as a signatory of the UN Global Compact.

Bracell’s Bracell Code of Conduct and RGE’s Global Code of Conduct provide guidelines on conflicts of interest. Their contents are disseminated to employees, who complete a Conflict of Interest Declaration where they identify any such situations.

The Code of Procurement Ethics highlights the importance of an ethical business environment and preventing conflicts between financial and personal interests within RGE Group. All business with suppliers must be conducted fairly, without personal gain, promoting a mutually beneficial business relationship. The Code establishes that all suppliers must submit a declaration to the company stating whether or not they have any personal affiliations with staff or representatives of the organization, in order to identify potential conflicts of interest.

Bracell has adopted a comprehensive set of processes to prevent and mitigate conflicts of interest, including:

• Corporate policies;
• Operational procedures
• Training and development concerning conflicts of interest
• Ethics or review committee
• Formal channels for submitting concerns and complaints (Fale Conosco and Bracell Escuta – see more in GRI 2-25);
• All members of the Sustainability Steering Committee hold executive positions. There are no independent members on the Sustainability Steering Committee.

Where conflicts are identified, they are managed ethically and responsibly, ensuring an integrity-driven organizational culture.

For reasons of confidentiality and to protect the individual rights of those involved, cases of conflict of interest are not revealed to stakeholders. Bracell remains committed to an approach that strikes a balance between transparency and protection of sensitive information.

Bracell’s Sustainability Steering Committee is formed by executives with strategic competencies to manage Bracell’s business interests, such as management of sustainability issues. In carrying out its work, the committee is also supported by the company’s senior management, who have knowledge and experience of environmental, social and governance issues.

Together, this group is responsible for setting and overseeing targets and commitments, like Bracell 2030, and managing social and environmental risks and opportunities in Bracell’s operations.

Committee members undergo continuous training and development, ensuring their competencies are aligned with business needs and sustainability demands impacting the organization (see more in GRI 404-2).

Expertise of Sustainability Steering Committee executives

Position	Executive	Credentials
President	Praveen Singhavi	Responsible for overseeing general business operations. Leads all Bracell staff. More than 25 years of management experience. Formerly president of the APRIL Group and a member of the RGE Group, he has previously held several senior management positions, including national and regional financial management roles, at other global companies in the commodities and manufacturing sectors.
Industrial Operations Officer	Guilherme Araújo	Head of Industrial Operations, São Paulo. Guilherme led the company’s forestry, industrial, and logistics operations (both inbound and outbound) in Bahia until 2024. He has previously: headed the commissioning of power generation plants, industrial plants, and greenfield projects, as well as the pulp production process; participated in implementing Lean methodology; implemented a sustainability agenda focusing on long-term social programs; and actively participated in external stakeholder engagement and relationship activities. Guilherme holds a bachelor’s degree in chemical engineering and has 26 years of experience in the forestry and pulp sector.
Head of Forestry Operations	Mauro Quirino	Mauro has over 20 years of experience working for Brazilian and multinational companies in the forestry sector. He has an MBA in Business Administration and Controllership (Getúlio Vargas Foundation) and a master’s in Accounting Science (PUC-SP). His expertise includes the areas of Controllership and Finances, Supply Chain and Forestry Operations.
Managing Director – Bahia	Rudine Antes	Rudine has 28 years of management experience in the pulp and paper industry, on four continents and in 17 industrial complexes in South America, North America, Europe and Asia. He holds a bachelor’s degree in Industrial Chemistry from the Federal University of Santa Maria (Brazil), a postgraduate certificate in Strategic Innovation from the Massachusetts Institute of Technology (USA), a master’s in Pulp Technology from the Helsinki University of Technology and a doctorate in Chemical Engineering from Aalto University (Finland).
Executive Vice President	Luiz Carlos Cavalcanti Dutra Junior	With over 37 years of market experience, Luiz has served as vice president of Public Relations, Advertising, and Communication for companies in the energy, consumer goods, chemicals, retail, infrastructure, and education sectors. He has served as a member of the Board of Directors and non-executive director in the education, infrastructure, and investment holding sectors. He has expertise in corporate brand management, communications, marketing, media relations, public and governmental affairs, and sustainability.
Managing Director – Bracell Papéis	Eduardo Aron	Eduardo has led competitive and complex consumer-centered businesses across pharmaceutical/OTC products, pet food and personal care. He has over 20 years of executive experience in marketing, trade marketing, sales and administration, and R&D. With a passion for customers, he works to advance innovation as a way of driving profitable, sustainable growth. Eduardo is a certified Blue Ocean Strategy Instructor. He has experience of creating and applying digital transformation strategies geared to positive business results, and has worked for organizations in the sector.

Expertise of senior leadership supporting the Sustainability Steering Committee

Position	Executive	Credentials
Vice President, Sustainability	Marcio Nappo	Marcio Nappo brings over 20 years of experience in sustainability and corporate affairs, having held senior executive roles at global firms in the food industry, agricultural commodity trading, and leading agribusiness associations in Brazil. His work focuses on the design and implementation of corporate sustainability and ESG strategies. Marcio holds a Bachelor’s degree in Economics from the University of São Paulo (USP) and a master’s degree in Economics from Fundação Getulio Vargas (FGV-SP).
Senior Manager, Operational Support	Alexandre Figueiredo	Alexandre has over 25 years’ experience in the Pulp and Paper industry, having led both greenfield and brownfield projects as well as managing environmental and ESG matters related to mill operations. He oversees the mill’s environmental management and licensing processes, leads Bracell’s sustainability strategy for mill operations, and manages special projects. He reports directly to the COO. Alexandre holds a chemical engineering degree from the Federal University of Santa Catarina and an MBA in Finance from Fundação Dom Cabral.
Senior Manager, Human Resources – Bahia	Carolina Linhares Fialho Gomes	With 20 years of experience in Human Resources Management, Carolina holds a degree in psychology and has received training in Coaching and Leadership from the University of West of England, UK, with a graduate degree in people management and organizational behavior. She works in HR planning to align it with the current and future needs of client departments and the business, focusing on talent acquisition, change management, and team building. Carolina leads projects focused on recruitment & selection, development, performance, diversity & inclusion, organizational climate, and culture.
Senior Manager, Human Resources – São Paulo	Mauro Peixoto	Mauro has 18 years of experience in HR in the pulp, energy, and oil and gas sectors. He has led teams in the sphere of people and projects to support business growth with national operations. He has led transformation and development programs implementing global and corporate HR guidelines. His expertise includes: talent acquisition, training and development, organizational design, succession planning, compensation, engagement, and performance management. Mauro holds a bachelor’s degree in Business Administration from Fundação Getúlio Vargas (FGV), an MBA in business management from FGV, and a graduate degree in project management from the University of São Paulo (USP).
Head of Talent Management and Learning and Development	Fernanda Kruse	With degrees in business administration and advertising, and 18 years working in the field, Fernanda has experience of the main subsystems in HR. Her background includes internal consultancy (Business Partner) supporting leadership and employees in the following processes: career management, recruiting and selection, training and development, performance review, youth training, succession planning, induction, and strengthening corporate culture and processes. With a degree in Advertising from AESO and Business Administration from the Federal University of Pernambuco, she holds graduate degrees in Online Education and Learning Techniques from the Pontifical Catholic University of Rio Grande do Sul and in Career Consulting from Fundação Instituto de Administração.
External Relations Officer	Manoel Browne	Manoel is an executive with experience in managing ESG matters and public affairs. He has worked for large corporations, at the head of multidisciplinary teams and in crisis management. He holds degrees in corporate, business, and environmental law. With a Master’s in Law, Manoel also has an MBA from the Alberto Luiz Coimbra Institute of Postgraduate Studies and Research in Engineering (COPPE/UFRJ) and a PMD from ISE/IESE.

 

The performance of each member of the Sustainability Steering Committee is evaluated annually according to Bracell and RGE Group guidelines. Those guidelines include organizational values (T.O.P.I.C.C.) (see more in GRI 2-6) and fulfillment of the year’s strategic planning targets, covering business (operational) and sustainability targets (Bracell 2030).

The evaluation process is carried out independently, ensuring transparency and objectivity. The process includes self-evaluation, peer evaluation, individual interviews and analysis of leadership performance in strategic meetings. All executives receive feedback focused on continuous improvement. An individual development plan is also drawn up annually for each executive and monitored by the Human Resources department, with actions including on-the-job development, learning from others, and leadership development programs (see more in GRI 404-2).

Bracell does not have an independent compensation committee responsible for overseeing the process for determining remuneration. Employee compensation comprises a base salary commensurate with the role, supplemented by various benefits. Each year, the terms of collective bargaining agreements are incorporated into compensation packages following negotiations with unions representing employee categories within the workforce.

The salary structure for our direct employees is based on legal requirements, market benchmarking, and biannual internal performance evaluations. Our compensation and variable compensation policies (which are tied to performance reviews) align with the compensation and evaluation policies of the RGE Group (read more in GRI 2-20).

For employees in leadership positions (specialist and above), performance evaluations are conducted by a committee comprising Bracell leaders from relevant departments (learn more in disclosure GRI 2-19).

Bracell does not disclose information on executive compensation, as this is considered strategic and confidential.

Bracell’s policy commitments are overseen by the Sustainability Steering Committee, which plays a central role in implementing our ESG strategy. Responsibilities are delegated through clear targets and commitments, defined hierarchies, effective communication, tracking systems, collaboration, and periodic evaluations to ensure ownership, accountability, and performance recognition.

These commitments are embedded in our strategy through goal-setting, policy development, standard operating procedures, training, impact assessments, internal communication, due diligence, feedback loops, and transparent reporting. In business relationships, policy commitments are implemented via contract clauses, audits, capacity building, issue resolution, sustainability reporting, open communication, and partner assessments.

Our commitments (see Bracell 2030), governance practices, risk management, KPIs, and continuous improvement efforts are aligned with applicable laws, regulations, and corporate policies. Our leadership monitors progress on Bracell 2030 targets, ensuring best practices and governance are applied across operations.

All Bracell protocols, standards, and policies are detailed in internal procedures that guide the management of environmental, social, and governance matters. These documents are managed through an Integrated Management System (IMS), accessible to all employees.

They are also regularly shared with employees, contractors, and suppliers. To ensure compliance, Bracell provides regular training and development. Stakeholder compliance with internal standards is also monitored and evaluated.

Training is provided annually on anti-corruption guidelines as part of Bracell’s Code of Conduct (see GRI 2-13 Delegation of responsibility for managing impacts).

Additional actions taken to implement policy commitments include:

• All senior leaders receive regular ethics and integrity training, including training on our Code of Conduct.
• All employees are trained and informed on Bracell’s values, commitments, and policies. They also receive technical and operational training outlined in role-specific training matrices as part of our Integrated Management System.
• Employees in senior roles or responsible for supplier due diligence receive specialized training from RGE business partners.
• Bracell’s internal standards and commitments also extend to suppliers and contractors. Compliance is assessed during supplier selection and screening, where suppliers are required to submit documentation and certifications appropriate to the scope of work. Document control is kept during both supplier onboarding and subsequent contract management.
• All suppliers receive Bracell’s Procurement Code of Conduct and undergo documentation checks to confirm compliance with applicable local, national, and international laws, certification requirements, technical standards, and regulatory frameworks.

Learn more about training and development at Bracell under GRI 404 Training and Education.

In 2024, Bracell reported a total of ten monetary fines and five non-monetary sanctions related to non-compliance with laws and regulations applicable to our forestry operations in São Paulo. The total amount of fines was R$ 3,919,277.14, including R$ 24,716.64 associated with violations allegedly committed in prior reporting periods.

We consider a case of non-compliance significant where it exceeds R$ 1 million or involves non-compliance with requirements or legislation that could impact the continuity of our activities, cause damage to our reputation or compromise consumer loyalty or customer and employee trust.

In our industrial operations in São Paulo, there were no fines or non-monetary sanctions for non-compliance with laws and regulations in 2024.

Despite having been party to violation notices and labor proceedings, Bracell presented defenses, appeals or judicial proceedings to annul the violation notices, as well as holding a Conduct Adjustment Agreement (TAC) with the public authorities concerning the non-fulfillment of working hours requirements.

In 2024, Bracell received no significant fines relating to non-compliance with laws or regulations.

To ensure compliance, Bracell fulfills federal, state and municipal legislation application to operations and has specialized internal departments addressing these matters, such as Legal, Environment and Certifications, Tax, Workplace Health & Safety, Social, Governance and Compliance. Legal requirements are managed by means of the Verde Ghaia SOGI system, which monitors and ensures compliance with standards applicable to Bracell Bahia.

In the reporting period, no fines or non-monetary sanctions concerning non-compliance with laws or regulations were reported for Bracell Papéis, either in São Paulo or in the Northeast. There were no significant cases of non-compliance during the reporting period.

All of our operations are assessed on corruption risk in accordance with the RGE Group Anti-Corruption Policy (internal document) and the Bracell Anti-Bribery and Anti-Corruption Policy (read more about Bracell’s operations structure under GRI 2-6).

The Internal Audit, Compliance and Risk Management teams lead assessments of risks related to ethics and corruption. Identified risks are described in internal procedures forming part of Bracell’s Integrated Management System (see more in GRI 2-13), which formalize procedures relating to corruption, prevention measures and impact mitigation.

Corruption risks, identified in the compliance risk matrix, are defined as corruption, bribery, fraud or similar acts committed by employees or third parties in Bracell’s name, by granting an unfair advantage or other acts defined as corruption in applicable legislation. The process of identifying and evaluating these risks was based on an assessment prepared by the Compliance department, following meetings with different departments and senior management. Interviews were carried out with the Audit, Human Resources, Enterprise Risk Management (ERM), Procurement and Communication teams, among others. The Compliance department also joined the process and risk design workshops led by the ERM together with technical departments, assessing integrity risks.

The main causes identified include relationships with licensing, regulatory and oversight bodies, the absence of policies setting out procedures for contacting government officials, relationships with political actors and interaction with public officials by third parties acting on behalf of Bracell. Risks were also highlighted relating to the hiring of employees historically linked to the public sector or to government-owned companies, inadequate controls for the award of funding, presents, hospitality, donations and sponsorship, as well as the engagement of suppliers with a negative compliance recommendation in due diligence, but whose engagement was approved by senior management. Other issues identified include the lack of moral effect from monitoring and sanctions measures for non-compliance and the bad faith of employees or third parties who attempt to commit unlawful acts. The process of evaluating and managing corruption risk is continually being improved to strengthen Bracell’s culture of integrity and compliance.

Bracell also has a Whistleblowing Policy for Financial Reporting Inaccuracies, aimed at all employees. This document sets out fundamental principles and procedures for reporting and investigating concerns. The policy presents the means whereby:

1. Employees raise concerns about possible inaccuracies in financial reports, internal controls or any other related matters.
2. A fair and independent investigation is carried out, with adequate follow-up to address each concern raised by employees.

Whistleblowers are advised to report possible inaccuracies to the Internal Audit departments in all operations. Reports can be made by telephone, email, snail mail, face-to-face meetings, and other means of communication.

Bracell has formal channels for submitting concerns and complaints (Fale Conosco and Bracell Escuta—see more in GRI 2-25). Bracell formalizes its commitment to ethics and sustainability by means of a Code of Conduct and corporate policies that are public and disclosed to all stakeholders. Our policies are available on our website at https://www.bracell.com/en/institutional/governance/ and https://www.bracell.com/en/sustainability/our-commitment/.

Bracell’s Compliance team, which is part of the Legal department, is responsible for the direct management of corruption-related matters, although this issue is evaluated in relation to risks across all Bracell operations, in real time (see more in GRI 205-1).

In 2024, the Compliance department launched an Integrity Program comprising a series of initiatives to reinforce related risk-management policies and procedures. These initiatives ensure that Bracell’s operations are carried out ethically and transparently, in accordance with the law and company values.

Integrity Program

Through our Integrity Program, we assess risks according to their likelihood and magnitude of impact, and:

– We create and/or update corporate policies and procedures to enhance control of operational processes in relation to these risks

– We carry out training and workshops with a focus on risk-management practices and control mechanisms

– We carry out communication initiatives and events that reinforce best practices in integrity, such as the disclosure of information bites on the subject and the launch of a guide with questions and answers about the Integrity Program and Code of Conduct.

All Bracell employees are informed and trained on anti-corruption policies and the Code of Conduct. The same applies to the six members of the Sustainability Steering Committee—83% of whom are based in São Paulo and 17% in Bahia (learn more about each member under GRI 2-9).

All newly hired employees receive a copy of the Code of Conduct during induction. They also receive training on integrity, anti-bribery and anti-corruption. Other practices include the following:

• All members of the senior leadership team attend regular training on ethics and integrity, including training on the Code of Conduct
• Employees in senior positions or who are responsible for conducting supplier due diligence receive additional, personalized training on RGE’s business partner due diligence process
• All Bracell suppliers receive copies of our Procurement Code of Conduct and undergo due diligence and a review of documentation and evidence demonstrating compliance with local, national and international laws and regulations, certification requirements, technical standards and regulatory standards

Anti-corruption training is mandatory for all employees and delivered via our online training platform. We communicate mandatory training for contractors working on site in our operations.

As of 2024, Bracell Papéis Nordeste is in the process of being fully integrated into Bracell’s corporate systems and procedures. Employees at this site did not attend the 2024 anti-corruption training, which is scheduled for 2025.

The percentage of employees trained is 37% for pulp operations in São Paulo, 55% for Bracell Papéis in the Southeast and 40% for pulp operations in Bahia.

Most untrained staff work in the field in forestry operations, without routine access to our training system. To cater for this work setting, we are developing specific training for this audience.

Total number and percentage of governance body members who have received communications and training on anti-corruption policies and procedures, by region

Bracell	Informed	Trained
Total number of members in the year	5	5
Total number of members who have received communications/training	5	5
Percentage of members who have received communications/training (%)	100	100

Total number and percentage of employees who were informed and trained in anti-corruption policies and procedures, by region

	Bahia		São Paulo		Papéis Sudeste		Total Bracell
	Informed	Trained	Informed	Trained	Informed	Trained	Informed	Trained
Total workforce	11,115		6,865		654		19,288
Total number of employees who have received communications/training	11,115	4,517	6,865	2,541	654	357	19,288	7,772
Percentage of employees who have received communications/training (%)	100	40.64	100	37.01	100	54.59	100	40.29

Number and percentage of employees who were informed and trained in anti-corruption policies and procedures, by employee category

	Informed	Trained
Executive Board
Total workforce	16	–
Total number of employees who have received communications/training	16	–
Percentage of employees who have received communications/training (%)	100%	–
Senior Manager
Total workforce	43	–
Total number of employees who have received communications/training	43	–
Percentage of employees who have received communications/training (%)	100%	–
Middle Management
Total workforce	161	–
Total number of employees who have received communications/training	161	–
Percentage of employees who have received communications/training (%)	100%	–
Coordinator
Total workforce	258	–
Total number of employees who have received communications/training	258	–
Percentage of employees who have received communications/training (%)	100%	–
Specialist
Total workforce	213	–
Total number of employees who have received communications/training	213	–
Percentage of employees who have received communications/training (%)	100	–
Technical/Supervisor
Total workforce	1,150	–
Total number of employees who have received communications/training	1,150	–
Percentage of employees who have received communications/training (%)	100%	–
Administrative
Total workforce	1,541	–
Total number of employees who have received communications/training	1,541	–
Percentage of employees who have received communications/training (%)	100%	–
Operational
Total workforce	6,815	–
Total number of employees who have received communications/training	6,815	–
Percentage of employees who have received communications/training (%)	100%	–
Trainee
Total workforce	23	–
Total number of employees who have received communications/training	23	–
Percentage of employees who have received communications/training (%)	100%	–
Total
Total workforce	10,220	–
Total number of employees who have received communications/training	10,220	–
Percentage of employees who have received communications/training (%)	100%	–

Note: the percentage of employees trained is 37% for pulp operations in São Paulo, 55% for Bracell Papéis in the Southeast and 40% for pulp operations in Bahia. Most untrained staff work in the field in forestry operations, without routine access to our training system. To cater for this work setting, we are developing specific training for this audience.

Number and percentage of business partners who have received communications and training on anti-corruption policies and procedures:

	Informed	Trained
Total number of business partners	1,914	1,914
Total number of business partners that have received communication/training	1,914	1,914
Percentage of business partners who received communication/training (%)	100	100

Note: Bracell Papéis Nordeste is currently undergoing integration into Bracell’s corporate compliance framework. As a result, its employees did not attend the company-wide anti-corruption training program in 2024. Training for this operation is scheduled for 2025.

Confirmed incidents of corruption and actions taken

	2022	20231	20242
Total number of confirmed incidents of corruption	0	2	4
Nature of reported incidents	0	Fraud	Bribery and kickbacks; fraud
Total number of confirmed incidents in which employees were dismissed or disciplined for corruption	0	1	4
Total number of confirmed incidents where contracts with business partners were terminated or not renewed due to violations related to corruption	0	1	0

¹ In 2022, a case of fraud was reported relating to a forestry module, which resulted in an internal audit. That audit culminated in the dismissal of the employees concerned. Although the incident took place in 2022, it was reported for 2023, the year in which there was also another case of fraud, this time relating to travel reimbursements, which led to the dismissal of one employee. In 2023, we recorded no cases of public corruption.

² For the four confirmed cases of corruption in 2024, the employees involved were duly disciplined or dismissed. The employee categories affected include supervision, coordination and operational. Altogether, 29 employees were either disciplined or dismissed. In one case concerning reimbursement of moving expenses, 26 employees were dismissed. In the other cases, there was only one dismissal per case.

Bracell does not have any pending or concluded legal actions in 2024 related to anti-competitive behavior, anti-trust, and monopoly practices.