Materiality

The Importance of the Risk, Opportunity, and Sustainability Topic Valuation Agenda 

Klabin recognizes that environmental, social, and governance factors can significantly influence its ability to create long-term value. In this context, identifying, assessing, and managing sustainability-related risks and opportunities are essential to strengthening corporate strategy and business resilience, while supporting decision-making that considers both financial and non-financial factors.

In line with the guidelines of the International Sustainability Standards Board (ISSB), the Company seeks to further integrate sustainability considerations into business planning by assessing how changes in environmental, social, regulatory, technological, and market conditions may affect its results, financial position, and future prospects. This approach enables an understanding not only of potential risks to the business but also of opportunities arising from the transition to a more resilient, low-carbon, and nature-positive economy.

The risk and opportunity agenda is complemented by the valuation of material sustainability topics, which aims to translate potential impacts into financial effects on revenues, costs, investments, assets, liabilities, and cash flows. This approach enhances transparency, supports more effective capital allocation, and strengthens the Company’s ability to anticipate trends, manage uncertainties, and capture strategic opportunities.

By connecting sustainability, risk management, and financial performance, Klabin reinforces its long-term perspective and ability to adapt to an increasingly dynamic business environment. This integration provides investors, lenders, and other stakeholders with a clearer view of how sustainability-related issues may contribute to the creation, preservation, or erosion of corporate value across different time horizons.

Risk Prioritization Methodology for IFRS S1 and S2

For sustainability-related financial reporting, Klabin applies a risk prioritization methodology that integrates sector-specific benchmarks, analysis of nature-related dependencies, corporate materiality, and enterprise risk management. This approach helps identify the risks with the greatest potential to affect the Company’s strategy, operational performance, cash flows, and ability to create value across short-, medium-, and long-term horizons.

The process begins with the universe of corporate risks identified and managed through Klabin’s Risk Matrix. Successive filters are then applied to determine the priority topics for financial analysis and disclosure in accordance with the requirements of IFRS S1 and IFRS S2.

Risks related to SASB topics

The first filter considers risks associated with the sustainability topics identified by SASB for the Pulp and Paper sector. This step ensures alignment with themes recognized internationally as potentially relevant to financial performance and long-term value creation in the industry.

Risks associated with nature dependencies

The second filter incorporates risks arising from Klabin’s dependencies on ecosystem services, as identified in the Nature Transition Plan. The analysis considers factors critical to business continuity and the value chain, including water availability, biomass supply, biological control, habitat maintenance, and the mitigation of extreme weather events.

Dual-Material Themes

Priority is then given to risks associated with topics classified as “double material” in the Company’s materiality assessment—specifically Water, Climate, and Biodiversity. These topics are considered capable of generating significant impacts on people and the environment while also having material implications for the business, reinforcing the connection between sustainability and corporate performance.

High and Critical Risks

Finally, priority is given to risks classified as High or Critical in Klabin’s Corporate Risk Matrix. This criterion focuses the analysis on events with the greatest potential to affect strategy execution, operational continuity, financial performance, or the Company’s future prospects.

Prioritization Result

By combining sector-specific relevance (SASB), nature dependencies, double materiality, and corporate criticality, Klabin identifies a set of priority risks for assessing financial impacts, scenarios, mitigation measures, and adaptation strategies. These risks form the basis for disclosures on governance, strategy, risk management, and metrics in accordance with the requirements of IFRS S1 and IFRS S2.

With the introduction of the EUDR (European Union Deforestation Regulation), Klabin adapted its processes to meet the new requirements, further strengthening transparency and traceability across its supply chain.

The EUDR requires companies exporting wood-based products to the European Union to demonstrate that their raw materials are not associated with deforestation or forest degradation. Klabin already meets these requirements by sourcing wood from pine and eucalyptus plantations specifically cultivated for pulp and paper production and certified by internationally recognized organizations.

To learn more about the Company's approach to EUDR compliance, visit EUDR-Klabin

The topic of human rights encompasses environmental, social, and governance issues, including labor practices, health and safety, diversity and non-discrimination, community relations, environmental protection, and data privacy. Given the cross-cutting nature of these topics, human rights at Klabin are managed through a cross-functional approach, supported by a comprehensive set of policies and standards:

• Code of Conduct
• Supplier Code of Conduct
• Anti-Corruption Manual
• Sustainability Policy
• Diversity and Employability Policy
• Fundamental Rights in Labor Relations Policy
• Socio-environmental Responsibility Policy for Supplier Contracting
• Life Protection Policy
• Cybersecurity Policy.

These commitments are grounded in internationally recognized frameworks, including the UN Guiding Principles on Business and Human Rights; the International Bill of Human Rights, comprising the Universal Declaration of Human Rights and the UN Covenants on Civil and Political Rights and on Economic, Social and Cultural Rights; International Labour Organization (ILO) conventions; and international conventions on biodiversity, the environment, and climate. The principles of the UN Global Compact and the United Nations Sustainable Development Goals (SDGs) also provide guidance.

In 2025, Klabin strengthened its human rights management by appointing its first Human Rights Analyst. Throughout the year, the Company received no reports of human rights violations or related cases.

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TRADITIONAL COMMUNITIES

Total forest area on Indigenous lands (in acres)

Number of traditional communities identified (5 km buffer around Klabin's forest management areas)

Klabin maps, identifies, and characterizes all traditional communities—including quilombola and faxinalense communities, as well as Indigenous peoples—located within its areas of influence. This work has evolved through several stages in recent years:

• 2019: 81 traditional communities located within a 10 km buffer zone of Klabin’s forest management areas in Paraná were identified and characterized;
• 2020: Following the expansion of Klabin’s forest base, a new assessment was conducted in 2020 to identify traditional communities located within a 10 km buffer of the Company’s forest management areas across the states of Paraná, Santa Catarina, Rio Grande do Sul, and São Paulo. This resulted in the identification of 80 additional communities for subsequent characterization.
• 2022: Following a two-year hiatus due to the COVID-19 pandemic, work resumed to characterize the 80 communities previously identified.
• 2023: In light of the continued expansion of Klabin’s forest base, 16 additional communities were identified.
• 2024: The characterization process was completed, covering a total of 177 communities: 19 Indigenous Territories, 55 quilombola communities, and 103 faxinalense communities, including 15 integrated into the Faxinal system.

In 2025, following a methodological review of its territorial analysis process, Klabin adopted a 5 km buffer around its forest management areas to map traditional communities. The change was introduced to improve the precision of impact assessments and strengthen the management of territorial relationships. As a result, the data are no longer directly comparable with the previous historical series, which was based on a 10 km buffer, but provide a more accurate picture of the communities within the operations’ direct area of influence.

The distribution in 2025 was:

• Indigenous Peoples - 14
• Quilombola communities – 41
• Faxinais - 5

In its engagement with all identified and characterized communities, the Company complies with Brazilian legislation and follows the recommendations of International Labour Organization (ILO) Convention 169, ensuring the right to free, prior, and informed consent (FPIC). In 2025, no cases of rights violations involving Indigenous peoples or traditional communities were reported.

* Studies based on official data and primary surveys enabled a detailed analysis of “faxinais” within Klabin’s operating areas in Paraná. Of the 104 “faxinais” initially identified, 16 remain active “faxinal” communities, of which only 5 are located within the 5 km buffer zone of the Company’s forest management areas. Over the years, the remaining communities have lost their traditional characteristics due to various external factors. Across the broader operational territory, 89 traditional communities were identified within a 10 km radius of the Company’s forest management areas. However, following the adoption of a refined methodology and a more precise 5 km buffer, 60 traditional communities are now identified within the area of analysis. All historical data remain duly recorded and available in the Company’s mapping databases.

GRI-412-1 SASB-RR-FM-210a.2

Stakeholder engagement on human rights, Indigenous rights, and local communities.

Klabin’s Social Responsibility and Community Relations area operates at the corporate level, supporting all of the Company’s units to strengthen relationships with stakeholders and potentially affected parties, prevent and mitigate impacts associated with its operations, provide remediation where necessary, and promote initiatives that contribute to local development in the regions where it operates.

In this context, its main areas of activity are:

• Proactive identification and management of potential social impacts associated with Klabin’s forestry and industrial operations
• Identification of opportunities to engage with local communities and contribute to territorial development;
• Fostering and strengthening dialogue among Klabin, public authorities, local and traditional communities, and other stakeholders.

Human rights due diligence at Klabin

Klabin conducts human rights due diligence through a structured and continuous process aligned with the UN Guiding Principles on Business and Human Rights. The process covers 100% of the company’s operations and is integrated into its governance and risk management practices, extending across the entire value chain and encompassing potentially impacted communities and new business relationships, including acquisitions and joint ventures.

In 2021, Klabin launched the first stage of its human rights due diligence process, supported by an independent consultancy. Since then, the process has been continuously enhanced and further implemented, and is structured around six main stages:

In 2025, a comprehensive and ongoing review of the controls and actions related to Human Rights Due Diligence was conducted based on the new maturity and adequacy assessment framework. The controls and action plans were also updated, and the process of updating the human rights due diligence framework was initiated, supported by interviews, document analysis, and an external consultancy.

Each stage of the due diligence process is described below:

1. Political Commitment

Although Klabin does not yet have a standalone Human Rights Policy, human rights are addressed across various corporate guidelines, including:

• Code of Conduct
• Supplier Code of Conduct
• Anti-Corruption Manual
• Sustainability Policy
• Diversity and Employability Policy
• Fundamental Rights in Labor Relations Policy
• Socio-environmental Responsibility Policy for Supplier Contracting
• Life Protection Policy
• Cybersecurity Policy

All these commitments are grounded in internationally recognized frameworks, including the UN Guiding Principles on Business and Human Rights; the International Bill of Human Rights, comprising the Universal Declaration of Human Rights and the UN Covenants on Civil and Political Rights and on Economic, Social and Cultural Rights; International Labour Organization conventions; and international conventions on biodiversity, the environment, and climate. The principles of the UN Global Compact and the United Nations Sustainable Development Goals (SDGs) also guide these commitments.

2. Risk and impact assessment

1. Human rights risk mapping

A human rights risk mapping exercise was conducted to identify the key inherent human rights risks associated with Klabin’s business, considering both its own activities and operations and its business relationships. The assessment focused on identifying the rights-holders who could be affected by these risks.

The assessment considered the risks previously identified for each of the relevant supply chains: wood, wood chips, logistics, and other goods and services. Local communities were defined as all those potentially affected by Klabin’s value chain activities, including forestry producers, industrial partners, logistics providers, and forestry suppliers.

As a result of this risk mapping, the following table was developed, identifying the risks associated with different stakeholder groups.

Note 1: Includes sharecroppers, caretakers, and squatters.
Note 2: Includes environmental and human rights defenders.

2.Management capacity assessment

This phase was further strengthened in 2025 through a comparative assessment of Klabin’s practices against international standards and requirements. As a result, a continuous process was established to periodically review and update identified risks, further strengthening governance.

The assessment was integrated into the company’s risk management system, expanding the impact matrix to include human rights issues alongside health and safety. Risks were classified according to a framework based on the UNGPs’ severity criteria, taking into account:

• Scale: severity of impact
• Degree of remediability: the extent to which the situation can be restored to its pre-impact state.
• Scope: number of individuals potentially affected

As a follow-up, the company’s inherent risk was assessed against its management capacity, resulting in short-, medium-, and long-term recommendations and action plans based on identified gaps and action priorities.

*Topics involving employees and contractors.

In 2025, Klabin prioritized updating the maturity status of recommendations and controls, assessing progress in their implementation and adherence to action plans. Risks were also reviewed with the respective sponsors, and action plans for critical risks were updated accordingly.

3. Implementation of prevention and mitigation measures – integration into internal processes

Based on the identified risks and the assessment of management capacity, measures are recommended to prevent and mitigate potential human rights violations, with these actions integrated into the company’s internal processes:

Are the actions taken considered adequate? Yes.

Klabin maintains an Occupational Health and Safety Management System (OHSMS) covering all its operations, including employees and contractors. In addition, six industrial units are ISO 45001 certified, while the company’s own forestry plantations are FSC® Forest Management certified, which includes the assessment of occupational health and safety aspects for workers involved in these activities. Compliance with OHSMS procedures and ISO 45001 and FSC requirements is periodically assessed through audits.

There are also procedures for:

• Continuous hazard identification, risk assessment, and determination of necessary controls;
• Provision of OHS training based on job role and legal requirements;
• Recording, investigation, and analysis of accidents and incidents;
• Identification of potential emergencies and response procedures.

Are the actions taken considered adequate? Yes.

All employees are covered by collective bargaining agreements. In addition, the Code of Conduct guarantees all employees the right to freedom of association and to join trade unions.

Are the actions taken considered adequate? Yes.

Since 2019, Klabin has conducted campaigns, training sessions, workshops, lectures, and discussion circles addressing topics such as racism, gender equity, unconscious bias, inclusive language, and harassment. Most of these initiatives are aimed at both employees and contractors, ensuring that these topics are addressed across different hierarchical levels.

The Company also provides training to support groups and People & Management teams, who are directly involved in handling these cases, with guidance from the Integrity department and an anthropology professor and consultant.

At the same time, procedures are in place for handling reports of harassment and discrimination submitted through the Ombudsman Channel.

Are the actions taken considered adequate? Yes.

The Code of Conduct and the Socio-environmental Responsibility Guidelines for Supplier Contracting establish minimum human rights standards for suppliers. In addition, Klabin uses the Handbook of Minimum Safety, Environmental, and Occupational Health Requirements for Contractors as part of its contracting processes.

In 2025, Klabin launched the Human Rights Risk Assessment by Procurement Category project, a joint initiative led by the Sustainability Governance and Procurement departments, with support from external consultants.

Are the actions taken considered adequate? Yes.

As a signatory to the National Pact for the Eradication of Slave Labor, Klabin commits to cross-referencing its database of active and inactive suppliers multiple times a year against the names listed in the Registry of Employers Found to Have Subjected Workers to Conditions Analogous to Slavery, commonly known as the “Slave Labor Dirty List.” If a match is identified, the Company takes the following actions:

• Identification of the supplier and the service provided, including date, location, and other relevant details
• Formal notification of the supplier, requesting clarification and a statement on the corrective measures implemented, as well as any proposed improvements, where applicable;

From this point onward, an assessment is conducted to determine whether the supplier should be subject to monitoring or whether the business relationship should be discontinued.

In 2025, no suppliers in Klabin’s supply chain were identified on the “Slave Labor Dirty List.”

Are the actions taken considered adequate? Yes.

Klabin has a procedure for managing conflicts with communities, which establishes an internal committee to address substantiated complaints. In addition, the Company maintains “Fale com a Klabin” (Talk to Klabin), a dedicated channel for receiving and addressing community inquiries, grievances, and complaints.

Are the actions taken considered adequate? Yes.

Klabin maps all traditional communities within its areas of influence in accordance with the procedures described under the indicator “Number of traditional communities identified (5 km buffer from Klabin’s forest management areas).”

In alignment with IFC and IDB guidelines and FSC and PEFC requirements, the Company identifies and characterizes the customary rights of traditional communities located within a 5 km radius of its operational areas and establishes measures to safeguard them. Beyond these areas of influence, the Company also considers routes used for timber transportation to identify communities that may be affected by traffic, dust, noise, and safety risks. Preliminary assessments are conducted using official secondary sources, including FUNAI, INCRA, IBGE, and the Palmares Cultural Foundation, among others. This information supports the planning of field assessments and helps ensure compliance with Brazilian environmental licensing requirements.

As a standard practice, Klabin reviews its forest base every two years to identify traditional communities within the defined buffer zone. When necessary, the Company conducts a detailed assessment and characterization of newly identified communities, ensuring that its databases remain up to date.

With more reliable data and a deeper understanding of the presence of traditional peoples in the territory, Klabin can build closer relationships and engage in more meaningful and sensitive dialogue with these communities when necessary. In cases where roads are shared, the Company engages with communities to provide information about its operations.

Klabin operates on the principle of avoiding management and operational activities within the territories of Indigenous peoples and traditional communities. Accordingly, the application of Free, Prior and Informed Consent (FPIC) has not been necessary to date. Should the need arise, the Company has plans and procedures in place based on the fundamental principle of identifying and respecting each community’s consultation protocols. Where no formal protocols exist, the consultation process is defined in consultation with community leaders.

The Social Responsibility and Community Relations team also assesses forest areas under consideration for negotiation, with the aim of ensuring the Company’s adherence to good practices regarding traditional communities. This includes declining to pursue negotiations for areas that are adjacent to or could adversely affect these communities’ ways of life.

The information is made available annually on the Company's website: Klabin – Public Summary (https://klabin.com.br/sustentabilidade/estrategia/resumo-publico ).

Are the actions taken considered adequate? Yes.

Klabin’s activities related to Social Responsibility and Community Relations are described in greater detail under the indicator “Relationship with stakeholders regarding human rights, indigenous rights, and the local community.”

Are the actions taken considered adequate? Yes.

All of Klabin’s operational units operate under an Environmental Management System that includes:

• Mechanisms for recording environmental incidents and anomalies within the units;
• Recording of incidents and complaints from interested parties, along with appropriate incident analysis and monitoring of applicable legal requirements;
• Identification of the environmental aspects and impacts associated with all operations;
• Mitigation measures, such as hydro-solidary and mosaic forest management;
• Environmental monitoring programs in the surrounding regions.

Are the actions taken considered adequate? Yes.

Klabin maintains a data protection governance structure supported by continuous and systematic monitoring, as well as cybersecurity policies and procedures aligned with ISO standards, Brazil’s General Data Protection Law (LGPD), and the Brazilian Internet Civil Rights Framework (Marco Civil da Internet). This information is made available to all employees through a Cybersecurity Handbook and related training sessions.

Suppliers with access to Klabin’s data and employee information are informed of their responsibilities through contractual provisions and are also required to complete an LGPD compliance form.

Risks related to the sexual exploitation of children and adolescents were identified as part of the Human Rights Due Diligence process through interviews with Klabin teams, analysis of internal and publicly available documents, and open-source research on the sector.

In its Supplier Code of Conduct, Klabin establishes a zero-tolerance policy toward the sexual exploitation of children and adolescents, which applies to employees, contractors, suppliers, and other parties across the value chain. The Code is incorporated into contracts and reinforced through specific training sessions.

Since 2016, the Company has been a signatory to the Business Pact Against the Sexual Exploitation of Children and Adolescents on Brazilian Highways, as part of Childhood Brasil’s Na Mão Certa Program (In the Right Hands). It is also a member of the Paranaguá Coalition, a partnership with the municipality that brings together companies to address this issue.

Activities include strengthening awareness campaigns through internal communications and in-person initiatives involving employees, as well as direct and indirect drivers. In 2025, two awareness-raising events were held in the Port of Paranaguá region, with approximately 60 employees participating in each event.

Are the actions taken considered adequate? Partially.

Currently, Klabin carries out targeted initiatives in the regions where it operates through its Social Responsibility and Community Relations department.

As a result of the human rights due diligence process, the area is developing a structured and comprehensive prevention and mitigation program, integrated into its annual impact-based planning.

A critical risk assessment is also underway across 20 raw material procurement categories, taking into account the risk of child sexual exploitation associated with the Company’s activities and business relationships.

4. Monitoring effectiveness

The next phase involves defining and implementing key performance indicators (KPIs) to monitor the effectiveness of measures taken to prevent and mitigate human rights-related risks. These KPIs are integrated into the Company’s KODs, strengthening the alignment between strategic commitments and operational outcomes.

5. Reporting

Reporting on human rights-related topics is disclosed in the Sustainability Report and the ESG Dashboard.

6. Complaint and reporting mechanisms

The Company also provides accessible and secure channels for reporting concerns and submitting complaints, available to internal and external stakeholders as well as impacted communities. Further information is available in the Ethical Conduct and Integrity section of the ESG Dashboard.