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.
Conflict of Interest management is addressed in the Code of Conduct, a document approved by the Board of Directors, where employees are encouraged to reflect on behaviors that may represent a conflict, seek clarification from leadership, HR, or the Integrity team, and report suspicions of violations to Klabin's Integrity Channel and Ombudsman.
Conflict of Interest occurs when there is a clash between collective and individual interests or between the company's interests and those of an employee or group of employees, potentially compromising the company's interest or improperly influencing the performance of those employees' duties.
Aspects related to Conflict of Interest management are included in Klabin's Code of Conduct training and the flow of reputational assessments conducted by the Integrity department. Since 2022, the Company has instituted the Related Party Transaction Policy aimed at strengthening governance on this matter. This document contributes to improving the internal control environment and mitigating risks in transactions that may lead to conflicts of interest.
Own employees notified and trained on anticorruption policies and procedures (by region)
| Year | 2022 | 2022 | 2021 | 2021 | 2020 | 2020 | |
|---|---|---|---|---|---|---|---|
| Type | Notified | Trained | Notified | Trained | Notified | Trained | |
| North | Total | 447 | 369 | 455 | 116 | 246 | 28 |
| Percentage | 100% | 82.55% | 100% | 25.49% | 100% | 11.38% | |
| Northeast | Total | 1,628 | 716 | 1,566 | 168 | 1,415 | 170 |
| Percentage | 100% | 43.98% | 100% | 10.73% | 100% | 12.01% | |
| Midwest | Total | 327 | 254 | 4,337 | 1,316 | ND | ND |
| Percentage | 100% | 77.68% | 100% | 30.34% | ND | ND | |
| Southeast | Total | 4,558 | 2,844 | 10,842 | 3,956 | 2,788 | 919 |
| Percentage | 100% | 62.40% | 100% | 36.49% | 100% | 32.96% | |
| South | Total | 11,433 | 7,736 | 323 | 127 | 10,425 | 4,343 |
| Percentage | 100% | 67.66% | 100% | 39.32% | 100% | 41.66% | |
| Total | Total | 18,393 | 11,919 | 17,523 | 5,683 | 14,874 | 5,46 |
| Percentage | 100% | 64.80% | 100% | 32.43% | 100% | 36.71% |
Own employees notified and trained on anti-corruption policies and procedures (by functional category)
| Year | 2022 | 2022 | 2021 | 2021 | 2020 | 2020 | |
|---|---|---|---|---|---|---|---|
| Type | Notified | Trained | Notified | Trained | Notified | Trained | |
| Senior Executive Board | Checked | 20 | 13 | 17 | 15 | 13 | 12 |
| Percentage | 100% | 65.00% | 100% | 88.24% | 100% | 92.31% | |
| Management and coordination | Total | 516 | 340 | 800 | 619 | 629 | 523 |
| Percentage | 100% | 65.89% | 100% | 77.38% | 100% | 83.15% | |
| Technical | Total | 2,568 | 1,957 | 520 | 257 | 955 | 643 |
| Percentage | 100% | 76.21% | 100% | 49.42% | 100% | 67.33% | |
| Administrative | Total | 1,626 | 1,201 | 2,535 | 1,333 | 1,611 | 1,077 |
| Percentage | 100% | 73.86% | 100% | 52.58% | 100% | 66.85% | |
| Operational | Total | 13,070 | 7,938 | 13,063 | 3,423 | 11,383 | 3,105 |
| Percentage | 100% | 60.73% | 100% | 26.20% | 100% | 27.28% | |
| Apprentices | Total | 285 | 202 | 292 | 20 | 107 | 20 |
| Percentage | 100% | 70.88% | 100% | 6.85% | 100% | 57.94% | |
| Interns | Total | 308 | 267 | 296 | 16 | 176 | 80 |
| Percentage | 100% | 86.69% | 100% | 5.41% | 100% | 50.57% | |
| Total | Total | 18,393 | 11,919 | 17,523 | 5,683 | 14,874 | 5,46 |
| Percentage | 100% | 64.80% | 100% | 32.43% | 100% | 36.71% |
Business partners notified and trained on anticorruption policies and procedures
| 2022 | 2021 | 2020 | ||||
|---|---|---|---|---|---|---|
| Type | Notified | Trained | Notified | Trained | Notified | Trained |
| Total | 473 | 37 | 40 | 8 | 158 | 1,381 |
| Percentage | 100% | 7.82% | 100% | 22% | ||
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.”
The hiring of suppliers at Klabin follows a number of criteria to ensure that legal and sustainability aspects are extended to the Company’s value chain.
In addition to requiring minimum levels of quality and timely delivery, tax compliance, compliance with applicable labor, environmental and human rights legislations are non-negotiable conditions.
Klabin has been a signatory to the National Pact for the Eradication of Slave Labor since 2013, which reinforces its commitment to combat slave and child labor.
Klabin’s Code of Conduct expresses our repudiation of the association with companies or people who have links to this practice: ”We do not have and do not allow hiring of suppliers and service providers or associations with companies or entities that have any link with the exploitation of child and/or slave labor, even if in their value chain."
Updated and verified on: 06/26/2023