During onboarding for both employees and contractor, our Code of Conduct is presented and made available in printed and online versions, accessible via QR code, along with documents such as our Anti-Corruption and Anti-Bribery Policy and the Human Rights Policy, available on Bracell’s website. Our Human Rights Policy, which applies to employees, contractors, and subcontractors, emphasizes our zero-tolerance stance on forced or compulsory labor.

All contracts signed with contractors or subcontractors include standard clauses ensuring zero tolerance for forced or compulsory labor (see more under GRI 3-3 Management of material topics: Supply chain management).

We have identified the following as operations with potential risk of forced or compulsory labor: planting, road construction and maintenance, maintenance of forestry machinery and equipment, and outsourced labor.  These operations are located in the regions where our industrial sites are based, namely in the states of São Paulo and Bahia, including areas operated by third parties.

We have strict preventive measures in place to mitigate any risk related to this issue. For contractor workers, we require documentation and conduct regular visits to forestry operations, carried out by our Internal Audit and Certification teams.

Audits of operations

We conduct both internal and external audits to manage environmental, social, management, and quality requirements. These requirements are assessed against the ISO 9001:2015, ISO 14001:2015 and Programme for the Endorsement of Forest Certification (PEFC) requirements. We also undergo external audits based on the IFC (International Finance Corporation) Performance Standards at our Lençóis Paulista (SP) site, a requirement in connection with the finance secured for Project Star—two newbuild flexible pulp lines, in operation since 2021.

Audits are periodically carried out in contractors’ operations to ensure compliance with internal policies and environmental, safety, and ethics standards.

Bracell’s Internal Audit team has developed a specific plan for forestry areas where outsourced workers are present and risks are higher, ensuring compliance with company policies and protecting workers’ rights. Forced or compulsory labor is classified in Bracell’s compliance matrix as an extreme violation. Identified potential causes include: activities with long shifts and high demand for operational labor; high levels of outsourcing; and lack of monitoring at worksites managed by contractors, especially in rural areas.