Ethical conduct and integrity

Righteousness and transparency in the Company’s relationships, protecting fundamental freedoms and in compliance with national legislation and international agreements.

The Integrity Area periodically conducts processes to map the risks of corruption in its operations. In the last biennium 2021-2022, 100% of operations were mapped by means of questionnaires completed by directors, document analysis, interviews, and transactional tests conducted by specialized consultants. The consulting firm's recommendations report was based on the mechanisms for Integrity Programs in Decree 8.420/2015, which regulates anti-corruption law 12.846/2013. Based on this report, action plans were established.

In order to reduce the risk of events that could be classified as acts of corruption, or any other violations of the values outlined in its Code of Conduct, the Company provides regular training to its various stakeholders, as well as hosting an Ethics Week and other communication initiatives. In doing so, it seeks to foster reflection on matters of integrity in the corporate environment. Improvements are also made through the elaboration of policies and procedures, which formally established guidelines and responsibilities, general or specific, in addition to the Integrity and Ombudsman Channel available to internal and external assessment.

The Integrity Area also conducts a reputational assessment of third parties with the aim of mitigating reputational risks that could harm the Company's image and reputation. Furthermore, in compliance with the Anti-Corruption Manual and Federal Law, in 2022 no cases of donation involving public agents were identified.


GRI-205-3

Cases involving violations of the Code of Conduct and bribery and/or corruption

Category Checked Confirmed
Corruption and/or bribery 0 0
Unlawful Acts 18 0
Behavioral 501 69
Conflicts of Interest 46 0
Customer Privacy data and Cybersecurity 0 0
Violation of Regulatory Laws or Standards 198 38
Sexual harassment 32 17
Discrimination 9 2
Money laundering 0 0
Total 804 126

 

Klabin's whistleblowing channel is managed by the Integrity area and administered by a specialized and independent company. The integrity channel governance process aims to prevent the occurrence of conflicts in the reception and handling of reports. In disclosing the Channel to employees, the differentials of the entire process are reinforced, such as: management by a specialized and independent company, the governance process, personal service by a consultant, the existence of the Integrity Commission to follow up on complaints, in addition to confidentiality and non-retaliation of whistleblowers.

The categories reported cover the following situations: Corruption; Bribery; Unlawful Acts (Fraud, Theft, Misappropriation of Materials, Improper Payment or Receipt); Behavioral (Abuse of Power, Bullying, Physical Aggression, among others); Conflicts of Interest (Favoritism, Close relationship with direct subordinates); Violation of Laws or Regulatory Standards (Violation of Environmental, Labor or Fair Trade Laws, Customer Privacy Data, Cybersecurity, Sexual Harassment, Discrimination, Money Laundering and other legislation). 

There were no cases of corruption or bribery in Klabin’s Integrity and Ombudsman Channel in 2022. The Channel, which receives complaints with appropriate measures to protect anonymity, aims to receive reports of violations of the Code of Conduct, standards, and current legislation, which are handled according to the complexity of the reported situations and undergo a process of analysis, investigation, and application of disciplinary measures and/or corrective actions for confirmed cases. Depending on the seriousness of the confirmed situation, the disciplinary measures applied range from formal warnings to termination of employment contracts or service provision. Preventive measures are also established for confirmed cases to mitigate possible recurrences.

The confirmed cases of sexual harassment resulted in 11 terminations, one suspension, four replacements of third-party employees and a written warning. It is important to emphasize that Klabin conducted intense campaigns on sexual harassment during the entire year of 2021 and reinforced the topic, including the active participation of senior management, leadership in general, and other employees.

The confirmed cases of discrimination correspond to reports of racial discrimination. The disciplinary measures applied take into account the severity of each case, and these occurrences resulted in dismissals of the reported employees.


GRI-206-1

Pending and/or closed lawsuits during the period covered by the report regarding unfair competition and violations of antitrust and antimonopoly laws

  Unit 2022 2021 2020 2019 2018
Number of pending or closed lawsuits Number 0 0 0 0 0

 

No lawsuits were identified regarding unfair competition, violation of antitrust laws, and monopoly.

 

GRI-307-1

Fines and non-monetary sanctions associated with environmental issues

Category Unit 2022 2021 2020** 2019* 2018
Monetary value of significant fines BRL 0 0 45,000.00 12,071.15 0
Monetary value of significant fines USD 0 0 8,667.68 2,994.80 0
Total number of non-monetary sanctions number 0 0 0 1 0
Total number of cases resolved through arbitration mechanisms number 0 0 0 0 0
Accumulated environmental liabilities at the end of the year BRL 0 0 0 0 0
Total actual and opportunity costs  from water-related incidents BRL 0 0 0 0 0

Note: Fines in excess of USD 10,000 are considered significant.
* BRL/USD exchange rate on 12/31/2019 – BRL 4.0307
** BRL/USD exchange rate on 12/31/2020 – BRL 5.1917

We had no fines or sanctions in 2022.
 

Klabin's history includes a long-standing commitment to ethical and responsible business practices in all its operations. In order to align its actions with international best practices, it established compliance with the Sustainable Development Goals (SDGs), and set its short, medium and long-term targets, seeking rectitude and transparency in relationships and the protection of fundamental freedoms, in accordance with applicable laws and regulations.

The Integrity Area is responsible for promoting the guidelines of the Klabin Code of Conduct, Anti-Corruption and Competition laws and regulations, and has the following objectives: (a) strengthen the pillars of the Integrity Program; (b) disseminate them to all its units and strategic partners; and (c) consolidate integrity as a value perceived internally and externally.

In 2022, the Company worked on communicating and training employees so that they are properly aware of the Code of Conduct, which was updated, revised and approved in May 2021 by the Board of Directors. The revision of the document involved 14 areas from all Klabin's boards and the support of a specialized consultancy. The update included and reinforced relevant and current topics such as the Anti-Corruption Law, Commitment not to retaliate against whistleblowers, General Data Protection Law (LGPD), Diversity, compliance with Environmental, Social and Governance (ASG) milestones and Klabin Sustainable Development Goals (KODS).

Klabin continues to strengthen its base of employees trained on the Code of Conduct through communication and awareness initiatives involving People & Management focal points at several units, achieving a significant improvement in the indices. The areas most sensitive to the topic of competitive practices and positions potentially more exposed to the risk of corruption receive specific training using the resources available in the internal corporate education portal or through experts to debate the subject and generate engagement, reflection and discussion.

Regarding the evaluation of third parties, the Integrity area has participated in the project to restructure the registration and approval of suppliers, conducted by the procurement area, contributing to the identification of related risks and ways to mitigate them. In addition, it participates in the construction of sector risk assessment metrics for critical suppliers associated with Sustainability issues, from the perspective of the EcoVadis system. Third-party reputation rating maintained was maintained and strengthened through Integrity questionnaires, due diligence, and ongoing monitoring of these partners on the Dow Jones platform.

An Integrity risk mapping process was conducted throughout Klabin's operation by an external consultancy and concluded in 2022, including issues related to corruption. The final recommendations report was based on the mechanisms for Integrity Programs in Decree 8.420/2015, which regulates anti-corruption law 12.846/2013. Based on the results of this mapping, action plans were established.

Since 2016, Brazilian companies are not allowed to contribute to political campaigns or organizations (Law 13165/2015). It is important to emphasize that since 2014 Klabin's Anticorruption Manual also presents impediments to donations to politicians and political parties.  Therefore, the company has made no contributions of this kind in 2022.

In addition to communication and awareness campaigns, the company has provided trainings on harassment and discrimination on the Klabin’s Educational Platform, such as: "Discrimination and Harassment at Work", "Lecture on Harassment with Professor Alexandre Cerveira and the Integrity Committee", "Sexual Harassment - Cultural Aspects”, "Code of Conduct Course", among others related to moral and sexual harassment.
 

Compliance system verification

In 2021, the company hired the consultancy company BDO who has been assessing our Integrity Program for improvements and recommendations, which will progressively complement the Deloitte’s 2019 verification. Work was finished in 2022 and covered Klabin's Code of Conduct and Compliance channel. It is worth mentioning that, more importantly, the company keep focusing on accomplishing last assessment’s as well as seeking to review and continuously maintaining the Integrity Program. 

Undertaking goals linked to the topic by executives
 

  2022 2021
Managers 1.0% 2.0%
Directors 0.0% 8.0%
Total executives 11 9

Updated and verified on: 06/26/2023