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.