Ethical conduct and integrity - GRI Summary

A conflict of interest arises when an individual’s personal interests conflict with those of Klabin, potentially compromising their judgment, impartiality, or decision-making in the performance of their duties. Conflicts of interest constitute a violation of the Company’s Code of Conduct (for more information, see Ethical Conduct and Integrity ). Employees are encouraged to identify and disclose potential conflicts of interest, seek guidance from their leaders or the People & Management or Integrity teams whenever needed, and report suspected violations through the Integrity and Ombudsman Channel. 

Code of Conduct training covers aspects related to the management of conflicts of interest. 

In 2022, the Company established the Related-Party Transactions Policy to strengthen governance in this area. The document helps improve internal controls and mitigate business risks that could lead to conflicts of interest. 

Employees Informed of and Trained on Anti-Corruption Policies and Procedures, by Region

Employees informed of and trained on anti-corruption policies and procedures, by job category

*In 2023, apprentices and interns were reported as a single category.

Business partners informed of and trained on anti-corruption policies and procedures

Klabin communicates its anti-corruption policies and procedures to business partners through contractual provisions requiring compliance with the Company’s Integrity standards, which set out its anti-corruption requirements, as well as through the Integrity section of its external website, which is publicly accessible.

As of November 2024, Klabin strengthened its framework by progressively incorporating a contractual clause requiring suppliers to acknowledge and comply with the Company’s Supplier Code of Conduct. This requirement is being implemented on an ongoing basis and applies to both new contracts and contract renewals. Publicly available, the Supplier Code of Conduct sets out the ethical principles governing the Company’s relationships with its suppliers, ensuring they understand Klabin’s expectations regarding integrity, anti-corruption, ethical business conduct, and compliance with applicable laws and regulations.

In accordance with the Klabin Code of Conduct, employees are guaranteed the right to freedom of association and trade union membership. As stated in the Code: “We seek to maintain an agenda of open and ongoing dialogue with employee representative bodies that extends beyond collective bargaining and legislative changes.”

Since 2013, Klabin has been a signatory to the National Pact for the Eradication of Slave Labor and has committed to cross-referencing its database of active and inactive suppliers—multiple times a year—against the names listed in the Registry of Employers who have subjected workers to conditions analogous to slavery (commonly known as the “Slave Labor Dirty List”). Accordingly, should any match be found, the Company takes the following actions: 

• Identification of the supplier and the service provided, including the date, location, among other relevant details; 

• Formal notification to the party requesting clarification and a statement describing the corrective measures implemented and, where applicable, Recommendations for improvement. 

At this stage, a decision is made on whether the supplier will remain under monitoring or whether the business relationship will be terminated. In 2024, no suppliers in Klabin’s supply chain were identified as appearing on any such list. 

Klabin’s supplier contracting process follows rigorous criteria to ensure that legal and sustainability standards are upheld throughout its value chain. This process may include an Integrity Due Diligence (IDD) assessment, which, in addition to screening against the Brazilian Government’s “Dirty List,” includes media searches and background checks, in accordance with the Company’s Code of Conduct and Supplier Code of Conduct. 

In addition to meeting requirements related to quality, on-time delivery, and tax compliance, suppliers are expected to comply with labor laws and uphold environmental and human rights standards as a non-negotiable condition.