Ethical conduct and integrity
Code of Conduct and Integrity
Klabin Integrity and Ombudsman Channel
Klabin has made consistent progress in strengthening its Integrity Program. The initiatives implemented reflected the program’s growing maturity, delivering significant efficiency gains while reinforcing the Company’s ethical culture and enhancing transparency, employee engagement, and alignment with best practices.
In 2025, the Integrity and Ombudsman Channel received 2,271 reports, reflecting the successful consolidation and repositioning of the hybrid model implemented in 2024. This model is characterized by the following features:
In the first instance within the organization (Integrity Channel): for reporting potential violations of the Code of Conduct, Klabin’s policies, and/or applicable legislation, as well as for submitting questions regarding the principles, guidelines, and requirements established in the relevant regulations.
Second instance (Ombudsman): designed to handle complaints that have previously been processed through the Company's primary service channels but have not been satisfactorily resolved, as well as cases in which the complainant is not satisfied with the outcome presented.
Highlights of the year included the full automation of the Channel’s workflows and the development of its first Power BI dashboard, enhancing management insights and increasing transparency of information. Additionally, an institutional video was developed for the Integrity and Ombudsman Channel to educate stakeholders about its purpose and use, reinforce the hybrid model, and support the submission of higher-quality reports.
The Integrity and Ombudsman Channel is available to all stakeholders, 24/7, in Portuguese, English, and Spanish. Reports can be registered through the website or by phone, identified or anonymously, and whistleblowers are protected against retaliation.
http://www.canalintegridadeeouvidoria.com.br/klabin
TELEPHONES
Brazil: 0800 718 7814
Argentina: 0800 222 0545
Cases involving violations of the code of conduct, including bribery and/or corruption.
Allegations found to be true:
| Nature | 2022 | 2023 | 2024 | 2025 |
| Corruption and bribery¹ | n/d | 4 | 4 | 0 |
| Fraud¹ | n/d | 11 | 12 | 17 |
| Discrimination² | n/d | 13 | 10 | 4 |
| Workplace harassment² | n/d | 65 | 54 | 70 |
| Sexual harassment² | n/d | 24 | 18 | 25 |
| Customer data breach³ | n/d | 0 | 0 | 0 |
| Conflict of interest¹ | n/d | 8 | 12 | 20 |
| Money laundering¹ | n/d | 0 | 0 | 0 |
| Insider trading | n/d | 0 | 0 | 0 |
Note 1: The reported figures include complaints investigated and concluded by Internal Audit to be substantiated or partially substantiated, whether received through Klabin’s Integrity and Ombudsman Channel or submitted directly to the Internal Audit area.
Note 2: The reported figures include complaints received through Klabin’s Integrity and Ombudsman Channel that were investigated and found to be substantiated or partially substantiated.
Nota 3: The reported figures include complaints registered through the Integrity and Ombudsman Channel and complaints received by Klabin's Data Protection area.
The Channel received an additional 1,776 reports related to matters outside the scope of investigations conducted by the Integrity area (workplace harassment, sexual harassment, and discrimination) and Internal Audit (fraud, theft, robbery, sabotage, conflicts of interest, and misuse or destruction of assets). These cases were handled by the Integrity area in partnership with leadership and the People & Management team for evaluation and resolution.
Allegations involving financial or asset-related misconduct are investigated by the Internal Audit area, using internal resources and, when necessary, the support of external specialists or third-party providers.
Since October 2024, investigations into behavioral misconduct allegations, including sexual harassment, workplace harassment, and discrimination, have been conducted by the Integrity Investigations Unit, which may engage specialized experts and request dedicated resources as needed. To ensure impartiality, consistency in decision-making, and appropriate consequence management, a multidisciplinary review committee was also established, comprising representatives from the Legal, People & Management, and Integrity areas. Within this framework, the Integrity area presents the findings of behavioral investigations, along with recommended disciplinary measures and action plans, for the committee’s review and deliberation.
In accordance with Klabin’s Code of Conduct, disciplinary measures are applied to confirmed violations. Depending on the severity of the misconduct, these measures may range from verbal and/or written warnings to suspension or termination of employment of those involved, as well as related reorientations.
Regarding Klabin's suppliers, the Klabin Supplier Code of Conduct establishes that, in case of non-compliance with applicable legislation or regulations, the guidelines of the Code of Conduct, Klabin's policies, or contractual provisions, the Company will take appropriate measures. These may include educational actions to strengthen partners' procedures and controls, suspension or termination of the business relationship, and/or legal action, as applicable.
Legal actions pending and/or concluded during the reporting period involving allegations of unfair competition or non-compliance with antitrust and antimonopoly laws.
| 2022 | 2023 | 2024 | 2025 | |
| Number of pending or concluded legal proceedings | 0 | 0 | 0 | 0 |
On October 9, 2024, the Administrative Council for Economic Defense ("CADE") initiated an administrative proceeding to investigate the alleged exchange of sensitive information among the human resources departments of certain companies. At this stage of the proceedings, Klabin is unable to predict the outcome of the investigation. Pursuant to Law No. 12,529 of November 30, 2011, legal entities found liable for violations of the economic order may be subject to fines ranging from 0.1% to 20% of the gross revenue of the company, group, or conglomerate in the fiscal year preceding the initiation of the administrative proceeding. Additional non-monetary sanctions may also be imposed. This is the most current information available regarding the case.
Fines and non-monetary penalties related to environmental issues.
| Category | 2022 | 2023 | 2024 | 2025 |
| Total value of significant fines (R$) | 0 | 0 | 0 | 0 |
| Total value of significant fines (R$) | 0 | 0 | 0 | 0 |
| Total number of non-monetary sanctions | 0 | 0 | 0 | 0 |
| Total number of cases resolved through arbitration. | 0 | 0 | 0 | 0 |
| Total environmental liabilities at year-end (R$) | 0 | 0 | 0 | 0 |
Note: Fines exceeding $10,000 are considered significant.
In 2025, Klabin was issued a fine that meets the significance criteria outlined above. However, the enforceability of the penalty has been suspended by court order.
The Integrity area is responsible for coordinating the development and periodic review of Klabin’s key normative documents, which establish the principles and guidelines that govern the conduct and decision-making of all individuals and entities interacting with the Company. These documents include the Code of Conduct, Anti-Corruption Policy, Supplier Code of Conduct, Integrity Program Policy, Integrity and Ombudsman Channel Policy, Competition Policy, and Trade Sanctions Policy. They are developed collaboratively with the Legal and Human Resources areas and, when applicable, with other functions such as Procurement, Sales, and Finance. All Integrity-related policies are aligned with the Company’s Regulatory System Policy, reviewed at least every five years, and submitted for approval by the Board of Directors.
To promote impartiality and equitable decision-making in the handling of misconduct cases, the Integrity area leads multidisciplinary committees comprising representatives from the Legal, People & Management, and Integrity areas. These committees are responsible for reviewing the findings of behavioral investigations presented by the Integrity area, as well as evaluating and deliberating on recommended disciplinary measures and corrective action plans.
Code of Conduct and Integrity Portal
The Klabin Code of Conduct encompasses the Company's values, principles, and standards, explicitly stating its commitment to ethical conduct, respect for people and the environment, and compliance with laws that strengthen the values of justice, equality, transparency, freedom, and dignity. It guides the Company's relationships and applies to board members, supervisory board members, directors and employees, affiliates and wholly-owned subsidiaries, suppliers, customers, shareholders, service providers, competitors, sales representatives, public entities and bodies, financial institutions, the press, communities, and society.
The current version of the document was reviewed and approved by the Board of Directors on May 28, 2021. It includes and reinforces key contemporary topics such as the Anti-Corruption Law, the commitment to non-retaliation against whistleblowers acting in good faith, the General Data Protection Law (LGPD), diversity, compliance with environmental, social, and governance (ESG) frameworks, and the Klabin Sustainable Development Goals (KODS). The document also safeguards employees’ freedom of association and was written in accessible language and is available for consultation on Klabin’s intranet and website in Portuguese, English, and Spanish.
Klabin makes available to its employees the Integrity Portal, an online platform that outlines the main pillars of the Integrity Program and provides centralized access to the Integrity Channel and key governance documents, such as the Code of Conduct and the Anti-Corruption Policy. As part of the onboarding process, new employees, as well as employees with restricted access to computers, receive printed copies of the Code of Conduct and are asked to formally acknowledge and commit to its principles by signing a commitment statement.
Klabin also has a Supplier Code of Conduct, intended for suppliers and their employees, third parties, and service providers throughout the production chain, including subcontractors, temporary workers, or any professional directly or indirectly involved in providing services or supplying products to Klabin. The document is based on the Company's Code of Conduct and policies, as well as applicable laws and regulations.
The Integrity Program
Klabin’s Integrity Program is aligned with leading market practices and supports compliance with applicable anti-corruption and competition laws. The Program is built on pillars dedicated to the prevention, detection, remediation, and monitoring of conduct that may violate the rules described in internal documents or applicable laws and regulations.
The Program is overseen by the Integrity Committee, which is composed of the Legal Director, Integrity Director, Risk Director, Internal Controls Director, Communications and Institutional Relations Director, People & Corporate Services Director, one Business Director, one Corporate Director, the Integrity Manager, and the Internal Audit Manager. Oversight is carried out through quarterly meetings, during which reports on the Program’s initiatives, indicators, results, and progress are presented. In addition, the Integrity area regularly reports its results to the Board of Directors, the Audit Committee and Related Parties, the Fiscal Council, and the Board of Directors.
Training and awareness initiatives for internal audiences are a key component of the Prevention pillar. In 2025, the Program expanded its reach by broadening the target audiences for knowledge-building actions. Five training programs covering a range of topics were delivered by subject matter experts and representatives from the Integrity area. These programs were conducted across 11 sessions, totaling more than 20 hours of training. The training sessions provide a forum for dialogue, reflection, and relevant discussions and are also made available through the ENK Portal. Furthermore, e-learning courses on the Code of Conduct and Anti-Corruption are offered through Klabin Business School (ENK).
In 2025, the Company recorded a significant increase in participation in Code of Conduct training, achieving an 81% completion rate, up from 78% in 2024. This improvement was driven by enhanced general and targeted communication on the topic and specific actions, supported by the People & Management area, including group training sessions for employees without access to digital learning platforms.
Ethics Week
The 2025 Ethics Week was designed to revisit and reinforce key ethical principles and highlight how they shape everyday interactions across the organization. The initiative underscored the relevance of adhering to the standards outlined in the Code of Conduct, internal policies, and applicable legislation in every decision-making process. The event also emphasized that organizational culture is built through daily actions and that it is everyone's responsibility to ensure a respectful and safe work environment, both within and beyond Klabin, with zero tolerance for harassment and discrimination.
The program offered a variety of initiatives tailored to different employee audiences, encouraging broad participation and engagement. The topics covered complemented the integrity-related training available on the ENK Platform, strengthening ongoing learning efforts.
Business Directors actively participated in both the opening session and the program’s activities, underscoring Klabin’s commitment to promoting a culture of ethics and integrity throughout the organization.
Since its inception in 2016, Ethics Week has been a recurring initiative on Klabin’s institutional calendar. The event aims to reinforce awareness of ethical conduct and promote learning through sessions led by subject matter experts, supporting the ongoing advancement of an ethical culture within the organization.
Compliance System Verification
In 2025, as part of the continuous evolution of the Integrity Program, the Integrity area, together with the Risk, Internal Controls, and Data Protection areas, reviewed its risks, internal controls, and the mapping of sensitive data related to the execution of its activities. The review is carried out annually as part of the Program’s continuous monitoring and improvement process. The findings are reported to the Integrity Committee, responsible for overseeing the Program, and periodically shared with the Executive Board, the Audit and Related Parties Committee, and the Board of Directors.
Third-party reputational assessment
Klabin performs integrity due diligence, background screening, and reputational assessments of business partners and third parties, in addition to evaluating commercial transactions, with due consideration given to applicable economic sanctions. These processes are intended to identify and assess potential risks, while supporting the Company in making business decisions and ensuring compliance with ethical guidelines.
Klabin is committed to the continuous improvement of its integrity due diligence, background screening, and third-party reputational assessment processes, in line with best market practices.
Political party contributions
Since the enactment of Law No. 13,165/2015 in 2016, Brazilian companies have been prohibited from making contributions to political campaigns or political organizations. Accordingly, Klabin prohibits its directors, officers, employees, and suppliers from making contributions on behalf of the Company or engaging in any activity that could be perceived as a political donation or contribution made in Klabin's name.
In 2025, Klabin made no contributions or donations to political parties, political campaigns, or candidates for public office, in compliance with applicable legislation and the Company's internal policies, including its Anti-Corruption Policy.
Updated and verified on: 31/07/2026