GRI 2-19 Remuneration policies

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.

GRI 2-20 Process for determining remuneration

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).

GRI 3-3 Management of material topics: Occupational health, well-being, and safety

The topic of health, well-being, and occupational safety is strategic to Bracell’s sustainability efforts and the long-term resilience of the business. This topic directly affect people’s experience, team performance, and Bracell’s ability to innovate and grow sustainably.

Employee health and safety—which is crucial to well-being and quality of life—is supported by an Integrated Occupational Health and Safety Management System. This system is aligned with Brazilian legislation, especially the Regulatory Standards (NRs) issued by the Ministry of Labor and Employment (learn more under GRI 403-1 Occupational health and safety management system).

The system is managed by Bracell employees who are part of the Specialized Occupational Safety and Health Engineering Service (SESMT) and the Specialized Rural Occupational Safety and Health Service (SESTR), as required by NR-4 and NR-31.

Our occupational health and safety management practices also include a Risk Management Program (PGR), Rural Occupational Risk Management Program (PGRTR), and Occupational Health Surveillance Program (PCMSO). These programs outline safety standards and procedures applicable to all activities conducted by employees and contractors, in line with our integrated management system policy.

These initiatives align with our Integrated Management System Manual, and international standards ISO 9001, ISO 14001, and the Programme for the Endorsement of Forest Certification (PEFC).

At Bracell, safety is a core value, and cultivating a culture of prevention is key to fostering health and well-being in the workplace. See below the initiatives as part of our health and safety management practices.

**Programs, processes, and practices for risk assessment and accident investigation**
Hazard Reports	Hazard Reports are issued for all employee roles and tasks. Risk assessments are carried out by a specialized firm using appropriate methods that are compliant with current legislation.
Workplace Environment Condition Reports (LTCAT)	These reports identify areas eligible for hazard bonuses and that require enhanced risk control measures. They also inform action plans that guide prevention efforts.
Risk Management Program (PGR)	The purpose of this program is to identify risks and design measures to control and prevent them (collective protection equipment, administrative measures, training and personal protective equipment).
Rural Occupational Risk Management Program (PGRTR)	Through this program, we identify, assess, and manage occupational risks in our forestry operations.
Worker protection policies and processes	To shield workers from retaliation, Bracell has policies and processes in place to prevent intimidation, threats, or actions that could negatively impact employment or the workplace environment, such as termination, demotion, loss of income, punishment, and any other unfavorable treatment.
Right of refusal	All employees have a right to refuse to perform a given task if they feel unsafe, by completing the right-of-refusal field in the Work Clearance form.
*Sempre Alerta* and Safe Behavior Program	We have two behavioral programs supporting our goal of achieving zero incidents: Sempre Alerta (“Always Alert,” with a focus on our forestry and mill operations) and our Safe Behavior Program (with a focus on mill operations), both designed to preventively achieve continuous improvement in our safety culture.
Prevention cards	All employees are issued a prevention card containing a list of ten self-assessment criteria, which they must carry with their badge. This card includes a reminder of their right to stop their task, immediately notify their supervisor, and only continue the task when the risk has been neutralized or eliminated. The right of refusal is also included in each employee category’s collective bargaining agreement.
Internal Accident Prevention Committee (CIPA)	Bracell has a continuous improvement subcommittee within CIPA that documents safety actions implemented and their practical outcomes.
Accident Prevention Week	A week dedicated to improving employees’ understanding of operational and occupational safety procedures, as well as safe behavior.
Accident and Incident Investigation	When accidents or incidents occur, the root causes are investigated and analyzed with the participation of managers, department heads, the Occupational Safety team, the Internal Accident Prevention Committee (CIPA), and those directly involved. These investigations, conducted in accordance with internal safety procedures, aim to identify the root causes, implement actions to address them, and document lessons learned to prevent recurrence.
Root Cause Analysis	All accidents and incidents are logged and investigated using Root Cause Analysis (see Occupational Safety Inspection Reports (RIST).
Occupational Safety Inspection Reports (RIST)	Occupational Safety Inspection Reports (RIST) serve as an internal audit tool covering safety, health, and environmental issues. These reports cover 199 compliance items (including NR-1, NR-31, NR-12, required training, among others). Reports are prepared on a regular basis by Occupational Safety employees, supporting compliance with applicable regulations and for continuous improvement in our forestry operations. As an additional preventive measure, department-specific and general performance review meetings are held to develop action plans addressing safety inspection items raised by the Occupational Safety team.
Occupational Health Surveillance Program	This program maps out workers’ tasks and workplaces, the occupational hazards to which they are exposed, and the medical exams required for the prevention of occupational diseases and health protection. It also establishes the frequency at which health checkups are to be conducted. All Bracell employees and contractors are covered by our Occupational Health and Safety Management System.
RADAR – Administrative Disciplinary Rules and Restorative Actions	These rules are designed to embed operational discipline and safe behaviors in Bracell’s mill and forestry operations. In addition to strengthening the safety behaviors of everyone who interacts with our operations, RADAR also establishes a more transparent and fair approach to recognizing good safety practices, as well as a no tolerance stance on unsafe conduct that is liable to cause accidents in our operations.

As part of our employee well-being practices, Bracell carries out a range of initiatives to support diversity and uphold human rights. In 2024, we updated our employee climate survey and conducted a Diversity and Inclusion Census (learn more under GRI 405-1 Diversity of governance bodies and employees).

Another key initiative in 2024 was our anti-workplace harassment campaign. This internal communication campaign included educational materials and visual content shared with employees under the slogan “It’s Not Whining” (see GRI 405-1 Diversity of governance bodies and employees).

In addition, we produced a Practical Guide to Preventing and Combating Harassment and Other Forms of Violence. The guide presents key concepts, guidelines, and rules for all our employees.

Impacts and risks

In managing the material topic of Occupational health, safety and well-being, Bracell has identified actual and potential impacts and risks, both negative and positive. Based on these findings, we work to prevent or mitigate negative impacts and enhance positive ones.

Potential negative impact	Actual negative impacts	Actual positive impacts
Infectious diseases affecting employees and contractors due to exposure to pathogens. This impact is limited in scope and low in intensity, as we have effective internal controls, formalized policies and procedures, and performance indicators in place.	Ensuring fair working conditions and protecting workers’ rights through collective bargaining agreements.	Ergonomic issues caused by repetitive tasks and inadequate posture during the maintenance and operation of equipment. This impact is limited in scope and low in intensity, as we have effective internal controls in place.
		Health impacts on employees, with leave taken due to work-related physical and psychological illnesses. This impact is broad in scope and of medium intensity.
	Preventing employee illnesses through campaigns and educational initiatives.	Respiratory and skin issues in employees and contractors caused by exposure to hazardous chemical substances. This impact is limited in scope and of medium intensity, with internal control mechanisms in place.
		Serious workplace injuries caused, for example, by operating heavy machinery, working at heights, or in confined spaces. This impact is limited in scope and of medium intensity.

GRI 3-3 Management of material topics: Talent acquisition, development and retention

Talent acquisition, development and retention—alongside Employee health, well-being, and safety—are strategic for the sustainability and long-term success of the business. These topics directly affect people’s experience, team performance, and Bracell’s ability to innovate and grow sustainably. For this reason, they are considered material to our approach to sustainability management (learn more about our double materiality assessment in GRI 3-2 List of material topics).

As a growing company, we view human capital as essential for achieving our Bracell 2030 targets and building a safe, healthy, and inclusive workplace.

In 2024, we continued to invest in talent acquisition, development, and retention, with a focus on occupational health and well-being practices and fostering a culture of diversity, equity, and inclusion (read more about our training and development journey in GRI 404 Training and Education).

Details on our talent acquisition, development and retention practices can be found in the disclosures below, which cover women’s representation in leadership, diversity and inclusion, and employee training and development.

Bracell has significantly expanded its operations in Brazil. Since 2021, with the start-up of our Lençóis Paulista (SP) facility—our highest-capacity plant—we have seen a 151% increase in our direct workforce, totaling 10,235 employees in 2024, including 1,688 at Bracell Papéis.

Internally, we have policies, processes, and standard operating procedures that guide our people management practices. In addition, our Bracell 2030 roadmap includes a commitment to promote equal opportunity for women, with a target to reach 30% of leadership roles held by women.

Women in Leadership

Promoting gender equality is one of the top priorities in the Bracell 2030 roadmap, which sets a target of having 30% of leadership positions held by women by 2030. In 2024, we made significant progress on this front, surpassing our interim target of 27% set for the year. We closed the year with 29.4% of leadership roles held by women, totaling 117 female leaders.

These include six senior managers, 37 managers, and 74 coordinators—a strong female presence across different levels of leadership.

Affinity groups

As part of our Diversity & Inclusion (D&I) targets, we also aim to foster a more inclusive work environment for our affinity groups, with a target of achieving 90% positive feedback from these employees on respect and equity in the workplace by 2030.

In 2024, the first year of implementing the Bracell 2030 roadmap, we established a satisfaction baseline for affinity groups and defined the key performance indicators that will guide future progress. This was done through a Diversity & Inclusion Census carried out during the year, which surveyed employees from affinity groups across all business units at the time of the survey. When asked about their overall satisfaction with Bracell, 27% of respondents expressed satisfaction (learn more about our Bracell 2030 targets and commitments).

Bracell’s diversity and inclusion practices (read more in GRI 405-1 Diversity of governance bodies and employees) include measurable targets, a Diversity & Inclusion Committee, and affinity groups focused on gender, race, people with disabilities, LGBTQIAPN+, and generations—the latter launched in 2024 in our Bahia operations. We are a signatory to the Women’s Empowerment Principles (WEPs), a UN Global Compact and UN Women initiative providing guidance on promoting gender equality and women’s empowerment in the workplace, marketplace, and community. Bracell is also actively involved in industry organizations aligned with this agenda.

Diversity within Bracell 2030

In 2024, we defined key performance indicators to measure “respect” and “equity” and structured a management system to track progress on an action plan to create an inclusive work environment for affinity groups—one of our Bracell 2030 targets. That same year, we also reached 29.4% women in leadership positions, bringing us closer to our 2030 target of 30%.

Training and Development

Bracell offers employees a corporate learning program with a structured training matrix that builds both soft and hard skills. Through our knowledge hub—the Bracell Learning Institute—we offer development tracks tailored to our forestry, mill, logistics, and supporting operations.

Our training programs are a key differentiator in attracting and retaining talent. Training initiatives are directly aligned with Bracell’s business challenges and support employees’ personal and professional growth, while also reflecting our T.O.P.I.C.C values (read more in GRI 2-6 About Bracell).

Training is offered both in person and online. Learn more about each training program under GRI 404-2 Programs for upgrading employee skills and transition assistance programs).

Impacts and risks

Bracell conducts comprehensive assessments of the potential and actual impacts related to the material topics in our materiality matrix. These assessments address both positive and negative aspects across the economy, environment, and people—including impacts on human rights.

For the topic Talent acquisition, development and retention, the aspects shown in the table below were identified. For each aspect, we work to prevent impacts from occurring and also have measures in place to reduce or mitigate impacts should they occur.

Potential impacts	Actual impacts
No negative potential impacts were identified.	Work-life imbalance: caused by excessive overtime or the lack of a flexible work system.
	Lower employee engagement.
	Higher turnover: due to the rising appeal of other roles in the market offering better benefits, flexibility, and pay.

GRI 201-3 Defined benefit plan obligations and other retirement plans

Bracell offers employees a defined contribution benefit plan, which is based on monthly contributions made equally by both employee and employer. This is a voluntary plan with nationwide coverage. The purpose of the benefit is to encourage employees to build financial reserves throughout their careers, providing greater financial security in retirement and supplementing the public pension system.

Under the current model, no liabilities are generated, as monthly contributions are immediately allocated to a dedicated fund for each enrolled participant. Our strategy fully ensures coverage of the plan through monthly deposits matching employee contributions. Because it is a defined contribution structure, the organization does not require or set a vesting period, as coverage is already guaranteed under the current model.

For confidentiality reasons, Bracell does not disclose financial information.

GRI 202-1 Ratio of standard entry level wage by gender compared to local minimum wage

Bracell’s Compensation Policy applies to all employees. This policy establishes a minimum wage that is higher than the local minimum wage. The Policy is guided by inclusive principles that promote equal opportunity and diversity across dimensions such as gender, ethnicity, age, religion, sexual orientation, geographic origin, social class, and personal values, while recognizing individual strengths and talents.

Salaries are determined based on several factors, including current labor laws and collective bargaining agreements, the role’s weight and importance within the organizational structure, market practices, internal pay equity, external competitiveness, the expertise and skills required for each position, organizational strategies, available budget, and the company’s financial position.

The salary table is updated annually based on compensation surveys conducted by specialized consulting firms, taking into account factors such as competition, region, labor availability, unemployment rates, and market turnover. The total compensation package offered by the company includes basic salary, bonuses, variable compensation, and benefits, and is designed to be competitive within the market.

A significant portion of workers who are not employees but are engaged in our activities are paid according to the rules established for the local minimum wage.

GRI 401-1 New employee hires and employee turnover

Total workforce and new hires in the period, by age group

**Bahia**
Age group	Total workforce	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Under 30	421	168	39.9	95	31.24
30 to 50	1,304	115	8.82	140	9.78
Over 50	244	7	2.87	18	5.12
Total	1,969	290	14.73	253	13.79

**São Paulo**
Age group	Total workforce	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Under 30	1,564	794	50.77	350	36.57
30 to 50	3,430	1,523	35.44	1,057	37.61
Over 50	1584	234	14.77	169	12.72
Total	6,578	2,551	38.78	1,576	31.37

**Southeast Paper Operations**
Age group	Total workforce	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Under 30	196	71	36.22	14	21.68
30 to 50	273	136	49.82	23	29.12
Over 50	150	7	4.67	8	5
Total	619	214	34.57	45	20.92

Note: Bracell Papéis started operations in 2023 and is reporting its sustainability performance indicators for the first time, for year 2024.

**Northeast Paper Operations**
Age group	Total workforce	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Under 30	320	109	34.06	81	29.69
30 to 50	627	201	32.06	139	27.11
Over 50	45	6	13.33	5	12.22
Total	992	316	31.85	225	27.27

Note: Bracell Papéis started operations in 2023 and is reporting its sustainability performance indicators for the first time, for year 2024.

Total workforce and new hires in the period, by gender

**Bahia**
Gender	Total employees	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Men	1,479	189	12.78	168	12.07
Women	490	101	20.61	85	18.98
Total	1,969	290	14.73	253	13.79

**São Paulo**
Gender	Total employees	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Men	5,635	1,961	34.8	1,199	28.04
Women	1,357	656	48.34	409	39.24
Total	6,992	2,617	37.43	1,608	30.21

**Southeast Paper Operations**
Gender	Total employees	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Men	476	150	31.51	38	19.75
Women	143	64	44.76	7	24.83
Total	619	214	34.57	45	20.92
Note: Bracell Papéis started operations in 2023 and is reporting its sustainability performance indicators for the first time, for year 2024.

**Northeast Paper Operations**
Gender	Total employees	New hires	New hire rate (%)	Terminations	Turnover rate (%)
Men	781	177	22.66	177	22.66
Women	211	238	112.8	48	67.77
Total	992	415	41.83	225	32.26
Note: Bracell Papéis started operations in 2023 and is reporting its sustainability performance indicators for the first time, for year 2024.

GRI 401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees

Pay packages for direct employees are developed based on benchmarking assessments and internal performance reviews, which are conducted twice a year, while also complying with relevant labor legislation. 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).

Employee compensation also includes a benefits package aligned with our corporate policies to promote health and well-being. We are a responsible corporate citizen. We offer extended maternity and paternity leave of 180 and 20 days, respectively. Benefits include health insurance, dental insurance, meal and food allowance cards, pharmacy benefit, health and wellness services (nutrition, psychological counseling, gym access, other sports activities, and health and wellness programs), private pension plans, payroll-deductible loans, Profit-Sharing Program (PPR), dependent allowance for children with disabilities, life insurance, daycare assistance, and year-end benefits (read more in GRI 401-3).

GRI 401-3 Parental leave

We are a responsible corporate citizen. We offer extended maternity and paternity leave of 180 and 20 days, respectively.

	BAHIA	SÃO PAULO	SOUTHEAST PAPER OPERATIONS	NORTHEAST PAPER OPERATIONS
Total number of employees that were entitled to parental leave
Men	1,479	5,635	476	822
Women	490	1,357	143	232
Total employees who took parental leave during the current year
Men	44	32	2	64
Women	8	39	1	15
Total employees who returned to work during the reporting period after parental leave ended
Men	46	33	2	0
Women	10	31	1	0
Total number of employees that returned to work after parental leave ended that were still employed 12 months after their return to work
Men	17	36	2	0
Women	18	9	0	0
Return rate
Men	100	100	100	0
Women	100	100	100	0
Retention rate
Men	89.47	76.60	100	0
Women	81.82	60.00	0	0

GRI 403-1 Occupational health and safety management system

Bracell has an Integrated Occupational Health and Safety Management System that is compliant with Brazilian legal requirements, including the Regulatory Standards (NRs) of the Ministry of Labor and Employment (MTE), labor laws, ILO conventions, Brazil’s Civil and Criminal Codes, collective bargaining agreements, licensing and inspection requirements, and guidelines issued by the Public Labor Prosecutor’s Office (MPT). The system covers all workers, activities, and work locations within the company.

OHS management is carried out by Bracell employees who are members of the Specialized Occupational Health and Safety Service (SESMT), as required by NR-4. The team includes occupational safety engineers and technicians, occupational physicians, occupational nurses, and nursing technicians. Bracell’s Risk Management Program (PGR) and Occupational Health Surveillance Programs (PCMSO) outline safety standards and procedures applicable to all activities conducted by employees and contractors, in line with our Integrated Management System Policy.

The System’s procedures establish day-to-day safety requirements and specific control measures for different risk scenarios. The management model follows guidelines set out in our Integrated Management System Manual and in ISO 9001 and ISO 14001. In addition, Bracell has an Integrated Occupational Health and Safety Management System that is compliant with Brazilian legislation and regulatory standards, ensuring a safe work environment aligned with best practices in occupational health.

GRI 403-2 Hazard identification, risk assessment, and incident investigation

Bracell has an Occupational Health and Safety Management System (OHSMS) in place to identify potential hazards, assess risks, and implement proactive safety measures across both routine and non-routine activities.

Risk and hazard assessments, aimed at protecting people, the environment, assets, and business continuity, are conducted by the Process Safety, Emergency, and Business Risk Management teams, which are part of the Occupational Health and Safety Department.

Health and safety performance indicators are monitored by the Health & Safety team, which presents performance metrics to all departments in monthly meetings, and to the Board and Management in bi-weekly occupational health and safety meetings.

Programs, processes, and practices for risk assessment and accident investigation

We employ specific tools and programs to identify and assess risks, as outlined in the table below.

Hazard Reports	Hazard Reports are issued for all employee roles and tasks. Risk assessments are carried out by a specialized firm using appropriate methods that are compliant with current legislation.
Workplace Environment Condition Reports (LTCAT)	These reports identify areas eligible for hazard bonuses and that require enhanced risk control measures. They also inform action plans that guide prevention efforts.
Risk Management Program (PGR)	The purpose of this program is to identify risks and design measures to control and prevent them (collective protection equipment, administrative measures, training and personal protective equipment).
Rural Occupational Risk Management Program (PGRTR)	Through this program, we identify, assess, and manage occupational risks in our forestry operations.
Worker protection policies and processes	To shield workers from retaliation, Bracell has policies and processes in place to prevent intimidation, threats, or actions that could negatively impact employment or the workplace environment, such as termination, demotion, loss of income, punishment, and any other unfavorable treatment.
Right of refusal	All employees have a right to refuse to perform a given task if they feel unsafe, by completing the right-of-refusal field in the Work Clearance form.
*Sempre Alerta* and Safe Behavior Program	We have two behavioral programs supporting our goal of achieving zero incidents: Sempre Alerta (“Always Alert,” with a focus on our forestry and mill operations) and our Safe Behavior Program (with a focus on mill operations), both designed to preventively achieve continuous improvement in our safety culture.
Prevention cards	All employees are issued a prevention card containing a list of ten self-assessment criteria, which they must carry with their badge. This card reminds employees of their right to refuse unsafe work, allowing them to stop the task in the event of any unsafe condition, immediately notify their supervisor, and only resume work once the risk has been neutralized or eliminated. The right of refusal is also included in each employee category’s collective bargaining agreement.
Internal Accident Prevention Committee (CIPA)	Bracell has a continuous improvement subcommittee within CIPA that documents safety actions implemented and their practical outcomes.
Accident Prevention Week	A week dedicated to improving employees’ understanding of operational and occupational safety procedures, as well as safe behavior.
Accident and Incident Investigation	When accidents or incidents occur, the root causes are investigated and analyzed with the participation of managers, department heads, the Occupational Safety team, the Internal Accident Prevention Committee (CIPA), and those directly involved. These investigations, conducted in accordance with internal safety procedures, aim to identify the root causes, implement actions to address them, and document lessons learned to prevent recurrence.
Root Cause Analysis	All accidents and incidents are logged and investigated using Root Cause Analysis (see Occupational Safety Inspection Reports (RIST).
Occupational Safety Inspection Reports (RIST)	Occupational Safety Inspection Reports (RIST) serve as an internal audit tool covering Safety, Health, and Environmental issues. These reports cover 199 compliance items, including NR-1, NR-31, NR-12, and required training, and are prepared on a regular basis by Occupational Safety employees to ensure compliance and operational improvement in forestry operations. As a preventive measure, performance meetings are held both by department and company-wide, where inspection results are presented and action plans are developed to address the findings identified by the Occupational Safety team.
Occupational Health Surveillance Program	Bracell identifies and maps all workers according to their roles and work locations, as well as the occupational risks to which they are exposed. We also keep records of preventive medical examinations conducted to protect employee health, including their frequency. Our Occupational Health and Safety Management System covers all workers, including contractors.
RADAR – Administrative Disciplinary Rules and Restorative Actions	These rules are designed to embed operational discipline and safe behaviors in Bracell’s mill and forestry operations. In addition to strengthening the safety behaviors of everyone who interacts with our operations, RADAR also establishes a more transparent and fair approach to recognizing good safety practices, as well as a no tolerance stance on unsafe conduct that is liable to cause accidents in our operations.

Process Quality Assurance and Training

We provide employee training to ensure occupational health, well-being, and safety processes and tools are effective (learn more under GRI 403-5 Worker training on occupational health and safety). In this context, we carried out the following:

Training on regulatory standards and operational procedures (read more under GRI 3-3 Talent Acquisition, Development and Retention)
Oversight of the onboarding process for new employees and ongoing training
Regular safety audits conducted by the Occupational Safety team to identify areas needing to be addressed and to improve management practices and processes
Safety certification for specific tasks, such as working at heights and in confined spaces.

Monitoring and continuous improvement

Process outcomes are reviewed and presented in monthly meetings of departmental safety committees and the Master Occupational Safety Committee, ensuring the system is continuously reviewed and improved.

Accidents and incidents are investigated using Bracell’s internal Root Cause Analysis procedure (PS023-05), which was updated in 2024 to include improved methodology and behavioral analysis.

A Safety Performance Index (IDS) tracks safety indicators by department and supports safety management.

Communication channels and worker protection

We provide formal channels for employees to report hazards and unsafe situations, ensuring protection from retaliation:

IDS – a tool whereby employees can report risk situations, which are addressed by the safety team
Whistleblower Hotline (Contato Seguro) – ensures confidentiality and protection against intimidation or penalties (read more under GRI 2-25: Processes to remediate negative impacts)
Sempre Alerta program (PST033-05) – enables workers to exercise their right to refuse unsafe tasks, without fear of retaliation
Internal policies and processes to ensure that safety-related reports do not result in negative impacts on employment or the employee’s professional standing.

In our Bahia operations, we have implemented a program, called OPA (Observe, Plan, Act), to encourage employees to report risk conditions and adopt a “see and act” approach. Reports are managed by the relevant departments and discussed in daily management meetings, ensuring effective corrective action is taken and fostering a continuous safety culture.

GRI 403-3 Occupational health services

We offer occupational health services to ensure a safe environment and promote employee well-being. These include disease prevention initiatives, wellness campaigns, and wellness programs designed to provide safe working conditions and a high quality of life for all team members.

All services are provided by qualified professionals, including an occupational physician, occupational nurse, and nursing technician. To ensure quality of service, we conduct annual satisfaction surveys with employees. In addition, we engage external audits to ensure compliance and service effectiveness.

Workers have unrestricted access to on-site medical clinics, which provide 24-hour in-person care and remote support via corporate phone, email, and internal extension. Health promotion and occupational disease prevention information is shared through official channels, including the intranet, weekly Comunica newsletters and Comunica TV, digital and physical bulletin boards, emails, and Rádio Bracell.

Main services provided

Occupational Health & Safety Program (PCMSO): occupational health checkups tailored to the risks of each position, aiming to preserve employee health. If any abnormal results are detected during checkups, the relevant individuals are temporarily relieved of their duties, provided with appropriate treatment based on the recommendations of our medical team, and monitored until their health status normalizes.
Hearing Conservation Program (PCA): a set of measures to mitigate noise-related risks, thereby preventing or minimizing work-related hearing impairment. This includes a hearing management system integrated into the environmental management system.
Health and quality-of-life campaigns: initiatives based on Brazil’s national health calendar.
Health and Ergonomics Committees: strengthening prevention and promoting well-being in the workplace.
Occupational health checkup management: continuous monitoring of employees’ health.
Medical and nursing care: access to clinical support and first aid.
Acolher program: management of workstations for pregnant employees.
Occupational disease control and prevention: risk and absenteeism management.

We also regularly provide both individual and group counseling on topics such as maintaining a healthy diet and the importance of exercising regularly.

GRI 403-4 Worker participation, consultation, and communication on occupational health and safety

We actively involve our employees in the development, implementation, and evaluation of the Occupational Health and Safety Management System. Employee participation is encouraged through training, educational campaigns, toolbox talks, and monitoring tools, ensuring an inclusive and effective approach.

Employees contribute directly to training programs, campaigns, and educational initiatives, and also participate in our Safety Performance Index (IDS) and continuous improvement activities.

Communication channels

Health and safety information is shared through leadership and internal communication tools such as Comunica TV and bulletin boards, ensuring that all employees have access to up-to-date guidelines.

Formal health and safety committees

Bracell maintains formal committees composed of both employees and contractors, who are tasked with continuously monitoring, analyzing, and improving safety conditions. Their key roles include:

Identifying and mitigating risks, and implementing preventive measures
Assessing working conditions, conducting inspections, and improving operational environments
Designing and implementing occupational health and safety programs
Investigating and responding to serious, imminent risks, with the authority to recommend halting operations until the issues are resolved.

These committees meet monthly and have the autonomy to recommend actions and monitor implementation, influencing the design and implementation of safety policies.

All Bracell workers are represented on health and safety committees.

Active employee participation

Employees are encouraged to actively engage around health, well-being, and safety through:

Toolbox talks, which foster open communication to raise concerns and offer suggestions
Support for the Internal Accident Prevention Committee (CIPAA), ensuring that reported issues are addressed
Safety walks, which allow managers to hear employees’ perspectives on risks and best practices
Recognition campaigns, which highlight good safety practices and promote a culture of prevention.

Both in-house and third-party workers are encouraged to identify, report, and document any events related to health, well-being, and safety occurring in our operations. Following investigation, action plans are developed for each reported case. All of this information is evaluated as part of the incident investigation process.

Our 100% Safe Journey Program encourages active employee participation. Through this program, we recognize best practices and high safety standards demonstrated by employees. Following assessments of compliance with safety standards, winners are announced and awarded bronze, silver, or gold badges.

GRI 403-5 Worker training on occupational health and safety

We believe that both hard and soft skills are essential to the success of our employees. That’s why we continue to scale up initiatives in professional training, organizational culture, and health and safety practices—aligned at all times with our values of diversity, equity, and inclusion.

We provide health and safety training to ensure a safe work environment and compliance with regulatory standards. These training programs, developed in plain language, aim to prevent occupational risks, promote employee well-being, and minimize accidents, covering topics from machine safety to preventive measures in risk situations.

All training materials are reviewed periodically to reflect legislative updates. In addition, we assess training effectiveness through internal audits and safety indicators. To ensure the continuous improvement of our health, well-being, and safety training efforts, we also conduct satisfaction surveys and performance evaluations.

This supports ongoing employee training, reduced operational risks, and a strong safety culture in the workplace.

General health and safety training

Training covers both theoretical and practical content, such as emergency drills and instructions on proper use of Personal Protective Equipment (PPE). This includes training on:

Accident Prevention (NR 01 – Employee Induction, NR 05 – CIPA)
First Aid and Emergency Response (NR 07 – First Aid, Fire Response Team)
Machine and Equipment Safety (NR 12 – Machinery Protection, NR 31.12 – Machine Operation Safety)
Safe Handling of Chemicals (NR 20 – Occupational Safety and Health with Flammables and Fuels)
Working at Heights and in Confined Spaces (NR 35 – Work at Heights, NR 33 – Confined Space Work)
Vehicle Operation and Cargo Transport (Defensive Driving, Cargo and Emergency Vehicle Drivers).

Job-specific training by area

Mills

Training programs on industrial operations and safety at production facilities, including:

NR 10 – Safety in Electrical Installations and Maintenance (Low and High Voltage – SEP)
NR 11 – Safe Operation of Forklifts
NR 13 – Boiler and Process Unit Safety
NR 18 – Safety in Welding and Aerial Platform Operations
NR 20 – Handling of Flammables and Fuels
Lockout-Tagout
Among other training topics.

Forestry

Training focused on field safety, including:

NR 31 – Safe Operation of Agricultural and Forestry Machinery
NR 31.7 – Prevention of Accidents Involving Pesticides
Safe Operation of Forestry Equipment (Chainsaws, Forwarders, Harvesters, Chippers, etc.)
Forest Fire Prevention and Control
Among other training topics.

Fire prevention and response

We run an annual training program for the fire teams responsible for responding to fires in our forestry and mill operations, in compliance with the regulations of the São Paulo and Bahia fire departments. These training sessions cover:

Implementation of strategic actions
Use of equipment
Defensive driving techniques for firefighting vehicles
Use of helicopters for support in fire response
Best practices in local community engagement

Methodology and application:

Regulatory training (NRs) is tailored to employees’ roles and tasks, in compliance with legal requirements.
Internal safety programs, such as RADAR and Sempre Alerta, address best practices and safe behavior.
Hands-on training and drills ensure readiness for emergency situations.
New employee onboarding includes general instructions on occupational health and safety.

GRI 403-6 Promotion of worker health

Bracell provides health and dental plans for all employees and their dependents, with national coverage. We also offer discounts in drugstore chains, gyms, educational institutions, and partnerships with organizations such as the Industrial Social Service (SESI), providing access to sports and leisure activities.

Bracell’s health management practices help to enhance well-being and health, and prevent diseases both inside and outside the workplace. Employees receive individual and group guidance on topics such as routine checkups, healthy nutrition, and the importance of exercising regularly. Key initiatives include:

Health benefits and wellness programs

Wellness programs

Mental health: Levemente program, focused on emotional well-being
Physical activities: Bracell Runners and Corrida do Eucalipto (running and brisk walking programs), and the Bracell Challenge, which supports better quality of life by encouraging healthy eating habits and regular exercise. These initiatives are available to both employees and their eligible dependents.
Maternal health: Pessoinhas program: multidisciplinary support for pregnant employees and spouses, providing assistance throughout pregnancy up to six months after childbirth.
Empresa Cidadã: extends maternity leave by 60 days (for a total of 180 days) and paternity leave by 15 days (for a total of 20 days). Employees also receive baby first aid training and attend sessions as part of the Pessoinhas

Annual health campaigns:

coordinated awareness initiatives on topics including sexually transmitted infections, respiratory diseases, flu vaccination, breast (Pink October) and prostate cancer prevention (Blue November), dehydration prevention, and two annual blood donation drives.

Bracell ensures workers’ health information is kept strictly confidential, in compliance with Brazil’s General Data Protection Regulation (BR GDPR). All data is handled exclusively by healthcare professionals, ensuring confidentiality and impartiality.

GRI 403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

Both employees and contractors have access to outpatient services, including checkups by nurses and physicians. When necessary, workers are referred for additional exams and specialized medical care.

Beyond providing health services, we actively identify hazards and risks associated with the activities of both employees and contractors over whom we do not have direct control. To prevent and mitigate these risks, we have a robust risk management system based on continuous risk identification and monitoring using tools such as our Risk Management Program (PGR), Occupational and Safety Procedures, Job Safety Analysis, Permits to Work, Occupational Safety Inspection Reports (RIST), Safety Committees, Gemba Safety Walks, Preliminary Risk Analysis (APR), and Work Clearance (LT).

Contractors are required to follow internal procedure PR.SEG.005, ensuring that their risk management programs align with Bracell’s safety guidelines for proper task execution.

The main risks identified include mechanical, electrical, thermal, chemical, ergonomic, and physical hazards, as well as risks related to fire and explosion. Occupational risks are also mapped, such as noise, vibration, non-ionizing radiation, poor posture, manual lifting, falls, poisonous bites, and road accidents. In addition, hazards like working at heights, handling chemicals, and electricity may result in falls, burns, or electric shocks.

Safety is further enhanced by our Specialized Occupational Health and Safety Engineering Service (SESMT) and a 24-hour Emergency Prevention and Response Team, organized across three shifts.

In our mill operations, a dedicated full-time emergency team operates around the clock, including an emergency response crew available for all work shifts, as well as trained fire wardens prepared to respond to emergencies with water and chemical fire trucks, ambulances, portable water cannons, and automated external defibrillators. In Bahia, the emergency team is also a participant in the Camaçari Industrial Park’s Mutual Emergency Response Plan (PAM).

Occupational health and safety management practices

Safe behavior	The safe behaviors outlined in our Code of Conduct are reinforced through clear guidelines for employees.
Occupational health & safety programs	Comportamento Seguro (“Safe Behavior”) and Sempre Alerta (“Always Alert”)—two programs covering all employees, including contractors.
Inspections	Safety inspections to identify unsafe working conditions and behavior, inform continuous improvement, and strengthen our safety culture.
Contractor audits	Six-monthly audits on compliance with applicable legal requirements (read more in Responsible Production, GRI 408-1).
Integrated Management System	Procedures, instructions, and incident investigation forms are incorporated in Bracell’s Integrated Management System (IMS).

GRI 403-8 Workers covered by an occupational health and safety management system

All employees and contractors are covered by our Occupational Health and Safety System, including all mill and forestry operations personnel.

We have implemented an Occupational Health and Safety Management System based on legal requirements and/or recognized standards/guidelines.

We follow Brazilian regulatory standards and ABNT 14280, including NR 01, which addresses risk management and the Risk Management Program (PGR), and NR 07, on Occupational Health & Safety Programs (PCMSO). These guidelines are addressed in our Integrated Management Policy.

Region	2022			2023			2024
Region	Men	Women	Total	Men	Women	Total	Men	Women	Total
Bahia	1,342	436	1,778	1,434	470	1,904	1,479	490	1,969
São Paulo	3,412	715	4,127	4,501	986	5,487	5,265	1,313	6,578
Southeast Paper Operations	0	0	0	0	0	0	476	143	619
Northeast Paper Operations	0	0	0	0	0	0	834	235	1,069
Total	4,754	1,151	5,905	5,935	1,456	7,391	8,054	2,181	10,235

Note: Bracell Papéis, our paper business, started operations in 2023 and is reporting its sustainability performance indicators for the first time, for year 2024.

The data disclosed under GRI 403-2 Hazard identification, risk assessment, and incident investigation was audited internally (referencing the content under GRI 3-3 Management of material topics: Health, well-being, and occupational safety or 403-2), while the data disclosed under GRI 403-3 Occupational health services was audited externally.

Region	2022		2023		2024
Region	Men	Women	Men	Women	Men	Women
Bahia	75%	25%	75%	25%	75%	25%
São Paulo	83%	17%	82%	18%	80%	20%
Southeast Paper Operations					77%	23%
Northeast Paper Operations					78%	22%
Total	81%	19%	75%	18%	79%	21%

Note: Bracell Papéis, our paper business, started operations in 2023 and is reporting its sustainability performance indicators for the first time, for year 2024.

GRI 403-9 Work-related injuries

Hazards and risks with the potential to cause serious accidents are identified and addressed through detailed analyses, planning, qualitative and quantitative assessments, a risk matrix, and consequence assessments. Tools such as Sempre Alerta and PSIF (Potential Critical or Fatal Incident Assessments) support risk identification and assessment.

Workplace safety is reinforced through internal procedures like Job Safety Analysis and Permits to Work. All employees, whether direct or outsourced, must be certified and trained before requesting any permit to work. No maintenance work can begin without a permit to work, in accordance with our “Commitment to Life – Stay Alert” safety policy. Routine operations are also governed by Standard Operating Procedures and safety pointers.

No worker has been excluded from work-related injury data.

Established safety targets include maintaining an overall frequency rate (TRIR and LTIR) lower than 3.0, a total recordable injury rate (TRIR) below 1.0, a lost time injury rate (LTIR) below 2.5, and a severity rate below 50.