Ethical conduct and integrity

The Integrity Area is responsible for coordinating the development and updating a series of Klabin's regulatory documents, which establish the guidelines that should guide the conduct and decisions of everyone who interacts with the Company. They include the Code of Conduct, Anti-Corruption Policy, Supplier Code of Conduct, Integrity Program Policy, Integrity and Ombudsman Channel Policy, Competition Policy and Trade Sanctions Policy, the latter in partnership with the Legal and People & Management areas, as well as other departments such as Procurement, Sales and Finance, as applicable. 

In 2024, Klabin approved a new Anti-Corruption Policy, replacing the previous Anti-Corruption Manual, as well as the Trade Sanctions Policy. It also revised the Integrity and Ombudsman Channel Policy. In accordance with the Company’s Regulatory System Policy, all integrity policies are reviewed every five years and approved by the Board of Directors. 

To promote impartiality and equity in decision making and in managing the consequences of any misconduct, the Integrity Area leads cross-functional groups composed of representatives of the Legal, People & Management and Integrity areas. The Integrity Area presents these groups with the results of behavioral investigations, as well as recommended disciplinary measures and action plans, for their evaluation and deliberation. 

Code of Conduct and Integrity Portal 

Klabin’s Code of Conduct reflects the Company’s values, principles and standards, and expresses its commitment to ethical conduct, respect for people and the environment, and compliance with laws that reinforce the values of justice, equality, transparency, freedom and dignity. It guides all the Company’s relationships, including with board members, Fiscal Council members, directors and employees, affiliates, wholly owned subsidiaries, suppliers, clients, shareholders, service providers, competitors, commercial representatives, public entities and agencies, financial institutions, the press, communities and society. 

The present document was reviewed and approved by the Board of Directors on May 28, 2021, including and reinforcing relevant and current topics such as Brazil’s Anti-Corruption Law, a commitment not to retaliate against whistleblowers, the Brazilian General Data Protection Law, diversity, compliance with environmental, social and governance requirements, and Klabin’s Sustainable Development Goals (KODS). The document was written in accessible language and is available for consultation on Klabin’s intranet and website in Portuguese, English and Spanish. 

For employees, Klabin provides an online Integrity Portal, which describes the pillars of the Company’s activities in this area and consolidates access to the Integrity Channel and relevant documents such as the Code of Conduct and Anti-Corruption Policy, in a single location. The new employees undergoing onboarding and those with restricted access to computers receive printed copies of the Code of Conduct for their information and they sign a declaration undertaking to comply with it.  

Klabin’s Code of Conduct guarantees employees freedom of association with labor unions. 

In 2004, Klabin launched its Supplier Code of Conduct, designed for suppliers and their employees, contractors and service providers throughout the production chain, including subcontractors, temporary workers and any other professionals directly or indirectly involved in supplying services or products to Klabin. The document is based on the Company’s Code of Conduct and policies, as well as applicable laws and regulations. 

Integrity Program 

Klabin maintains an Integrity Program aligned with market best practices, which promotes the principles and values of its Code of Conduct and complies with anti-corruption and competition laws. The program is based on pillars focused on prevention, detection, remediation and monitoring of actions that could breach the rules described in internal documents or applicable laws and regulations. 

The program is overseen by the Integrity Committee, which is composed of the legal, integrity, risk, internal controls, communication and institutional relations director; the people and corporate services director; a business director; the integrity manager; and the internal audit manager. Monitoring takes place at quarterly meetings, at which the program’s actions, indicators, results and progress are reported. The Integrity Committee oversees the program, which reports its results to the Executive Board, the Audit and Related Parties Committee and the Board of Directors, annually or when requested. 

Integrity training 

One of the cornerstones of the Integrity Program, in its prevention pillar, is internal staff training. In 2024, nine training courses on various topics were conducted by specialists, distributed over 14 sessions, totaling 25 hours. Training on the Code of Conduct and Anti-Corruption Measures can also be done in e-learning format through the Klabin Business School Platform. 

In 2024, the Company saw a significant improvement in its internal training indicator regarding the Code of Conduct, reaching 78% participation, up from 70% in 2023. This result can be attributed to intensified general and targeted communication on the topic and specific actions supported by the People & Management Area, such as group sessions for employees without access to digital platforms. 

Another highlight of the year was the participation of over 82% of employees in the Commercial and Procurement areas in training courses on competition offered to groups related to the topic. These courses are taught by specialists and provide opportunities for dialogue, reflection and relevant discussions. They are also available on the Escola de Negócios Klabin Portal (Klabin Business School). 

Ethics Week 

The 2024 edition of Ethics Week, launched by Cristiano Teixeira, Klabin’s CEO, was dedicated to combating harassment and discrimination. The event invited employees to reflect on their role in building an environment of integrity, both inside and outside the Company, and on respect and efforts to tackle harassment and discrimination. The initiative featured a diverse program of activities tailored to different employee profiles, encouraging engagement. The content complemented the integrity training available on the Escola de Negócios Klabin Portal (Klabin Business School). 

The event has been held since 2016 for Klabin employees, reinforcing awareness of ethical behavior and providing training with specialists. 

Verification of Compliance System 

In 2024, the Integrity Area, in partnership with the Risk, Internal Controls and Data Protection areas, reviewed its risks, internal controls and mapping of sensitive data in the execution of its activities, to further enhance the Integrity Program. This review of risks and internal controls is conducted annually, as part of the program’s ongoing monitoring, which also includes reports to the Integrity Committee, responsible for its supervision, and to the Executive Board, Audit and Related Parties Committee and Board of Directors. 

Relationship with academia 

Strengthening its relationship with academia, in 2024 Klabin took part in the 12th Communication and Ethics Challenge organized by the Public Relations Program at Faculdade Cásper Líbero, a renowned private higher education institution in São Paulo. The participating third-year university students worked on the theme of “How to incorporate integrity into Klabin’s day-to-day communications in a way that makes the topic accessible and interesting to all audiences.” This initiative helps broaden perspectives on the construction of meaning in everyday integrity communications. 

Third-party reputation assessments 

Klabin conducts integrity assessments, background checks, and reputation analysis of third parties, as well as evaluations of commercial transactions, in compliance with applicable economic sanctions in the conduct of its business. These procedures aim to identify potential risks, support the Company in business decision-making, and ensure alignment with ethical guidelines. Klabin is committed to continuosly improving and deepening its research parameters in third-party integrity assessments, background checks, and reputation analyses.

Political party contributions 

In 2024, in accordance with legislation and internal rules, Klabin did not make any contributions to political parties. During the year, Klabin’s Anti-Corruption Policy was launched, replacing the previous Anti-Corruption Manual, which explicitly prohibits contributions or donations to political parties, political campaigns and/or candidates for public office, in line with applicable legislation. 

Since 2016, Brazilian companies have been prohibited from contributing to political campaigns or organizations, in accordance with Law 13,165 of 2015. Klabin’s managers, employees and suppliers are also prohibited from making contributions on its behalf or engaging in any conduct that could appear to be a political donation or contribution on its behalf.