Ética e integridade - Sumário GRI
Code of conduct and integrity - GRI Summary
We concluded the process of updating Klabin’s Code of Conduct in 2021, which included support from a specialized consulting firm, and all the Company’s departments, and was approved by the Board of Directors on 05/28/2021. The Code of Conduct applies to all members of the Board of Directors, Fiscal Council, directors and employees of Klabin and its affiliates and subsidiaries, as well as suppliers, customers, shareholders, service providers, competitors, commercial representatives, public entities and agencies, financial institutions, the press, communities, and other stakeholders that have some form of relationship with the Company.
The Code of Conduct expresses our commitment to ethical conduct, respect for people, and the environment, and compliance with the law, strengthening the values of justice, equality, transparency, freedom, and dignity. The update includes and reinforces relevant and current topics such as the Anticorruption Law, Commitment not to retaliate against whistleblowers, Brazilian General Data Protection Law (LGPD), Diversity, compliance with Environmental, Social, and Governance (ESG) frameworks, and Klabin’s Sustainable Development Goals (KODS).
We prepared the Code of Conduct in language accessible to everyone. We made it widely available on the company’s website, in Portuguese, English, and Spanish, as well as on the internal portal. To integrate new employees and those with restricted access to computers, we provide printed copies for awareness and signature of a term of agreement. We also maintained and strengthened the need for Code of Conduct training, available on an e-learning platform. Through general and localized communication, as well as specific actions supported by the G&G area, such as group sessions for employees without access to digital platforms, we achieved significant improvements in our indicators.
We developed and provided the Integrity Portal to all employees, accessible through an internal platform, containing the Code of Conduct, Anti-corruption Manual, the area’s action pillars, and access to the Integrity Channel, among other important data and documents.
A conflict of interest is a situation in which an individual has objectives that conflict with those of Klabin, in such a way as to affect their judgment, objectivity and decision making in the execution of their activities in the service of the Company. The materialization of a conflict of interest is a violation of the Code of Conduct, which also covers the management and treatment of such cases (see the Ethical Conduct and Integrity section). Employees are guided to reflect on situations that may be considered a conflict of interest, discuss any uncertainties with their leaders, the People & Management team or the Integrity Area, and report suspected violations to the Integrity and Ombudsman Channel.
The Code of Conduct training includes aspects related to the management of conflicts of interest.
In 2022, the Company launched its Related Party Transaction Policy to strengthen its governance on the subject. This document has helped improve internal controls and mitigate business risks that could result in conflicts of interest.
Own employees notified and trained on anticorruption policies and procedures (by region)
| Year | 2023 | 2022 | 2021 | 2020 | |||||
|---|---|---|---|---|---|---|---|---|---|
| Type | Notified | Trained | Notified | Trained | Notified | Trained | Notified | Trained | |
| North | Total | 468 | 343 | 447 | 369 | 455 | 116 | 246 | 28 |
| Percentage | 100% | 73% | 100% | 82.55% | 100% | 25.49% | 100% | 11.38% | |
| Northeast | Total | 1,525 | 791 | 1,628 | 716 | 1,566 | 168 | 1,415 | 170 |
| Percentage | 100% | 52% | 100% | 43.98% | 100% | 10.73% | 100% | 12.01% | |
| Midwest | Total | 313 |
259 | 327 | 254 | 4,337 | 1,316 | ND | ND |
| Percentage | 100% | 83% | 100% | 77.68% | 100% | 30.34% | ND | ND | |
| Southeast | Total | 4,082 | 2,963 | 4,558 | 2,844 | 10,842 | 3,956 | 2,788 | 919 |
| Percentage | 100% | 73% | 100% | 62.40% | 100% | 36.49% | 100% | 32.96% | |
| South | Total | 11,137 | 8,645 | 11,433 | 7,736 | 323 | 127 | 10,425 | 4,343 |
| Percentage | 100% | 78% | 100% | 67.66% | 100% | 39.32% | 100% | 41.66% | |
| Total | Total | 17,525 | 13,001 | 18,393 | 11,919 | 17,523 | 5,683 | 14,874 | 5,46 |
| Percentage | 100% | 74% | 100% | 64.80% | 100% | 32.43% | 100% | 36.71% | |
Own employees notified and trained on anti-corruption policies and procedures (by functional category)
| Year | 2023 | 2022 | 2021 | 2020 | |||||
|---|---|---|---|---|---|---|---|---|---|
| Type | Notified | Trained | Notified | Trained | Notified | Trained | Notified | Trained | |
| Senior Executive Board | Checked | 20 | 7 | 20 | 13 | 17 | 15 | 13 | 12 |
| Percentage | 100% | 35% | 100% | 65.00% | 100% | 88.24% | 100% | 92.31% | |
| Management and coordination | Total | 515 | 458 | 516 | 340 | 800 | 619 | 629 | 523 |
| Percentage | 100% | 89% | 100% | 65.89% | 100% | 77.38% | 100% | 83.15% | |
| Technical | Total | 2,655 | 2,344 | 2,568 | 1,957 | 520 | 257 | 955 | 643 |
| Percentage | 100% | 83% | 100% | 76.21% | 100% | 49.42% | 100% | 67.33% | |
| Administrative | Total | 811 | 1,359 | 1,626 | 1,201 | 2,535 | 1,333 | 1,611 | 1,077 |
| Percentage | 100% | 100% | 73.86% | 100% | 52.58% | 100% | 66.85% | ||
| Operational | Total | 12,960 | 8,329 | 13,070 | 7,938 | 13,063 | 3,423 | 11,383 | 3,105 |
| Percentage | 100% | 64% | 100% | 60.73% | 100% | 26.20% | 100% | 27.28% | |
| Apprentices | Total | 308 | 256 | 285 | 202 | 292 | 20 | 107 | 20 |
| Percentage | 100% | 84% | 100% | 70.88% | 100% | 6.85% | 100% | 57.94% | |
| Interns | Total | 256 | 248 | 308 | 267 | 296 | 16 | 176 | 80 |
| Percentage | 100% | 97% | 100% | 86.69% | 100% | 5.41% | 100% | 50.57% | |
| Total | Total | 17,525 | 13,001 | 18,393 | 11,919 | 17,523 | 5,683 | 14,874 | 5,46 |
| Percentage | 100% | 74% | 100% | 64.80% | 100% | 32.43% | 100% | 36.71% | |
Note: In this item, we inform the total number (considering all regions) of service providers and, of this total, the number whose contracts have an Anti-Corruption Clause. The difference between quantities corresponds to price agreements, software contracts, partnership contracts, leases, contracts with real estate agencies and airlines.
Klabin makes anti-corruption policies and procedures available to all its business partners, either contractually by requesting the signature of the "General Conditions of Supply" document, which contains anti-corruption guidelines, or through information present in its transaction channels with third parties (Electronic Market, purchase order templates).
For data referring to communication and training, critical business partners were considered, according to internal parameters, which are evaluated by the contracted platform EcoVadis and take into account criteria of sustainability, ethics, among others.
According to the Klabin Code of Conduct, freedom of union association is guaranteed to employees: “We seek to maintain an open and constant dialogue agenda with professional representation entities, which goes beyond collective bargaining and changes in legislation.”
Since 2013, Klabin has been a signatory to the National Pact for the Eradication of Slave Labor, reflecting its commitment to combating slave and child labor. The Klabin Code of Conduct explicitly states its refusal to associate with companies or individuals linked to this kind of practice.
Klabin’s supplier engagement is underpinned by a series of criteria designed to ensure that legal and sustainability parameters are upheld across its entire value chain. As well as demanding minimum quality standards, timely deliveries and tax compliance, the Company also mandates adherence to labor, environmental and human rights laws as indispensable conditions.
Updated and verified on: 26/06/2023