Ethical conduct and integrity

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Klabin's Integrity Channel and Ombudsman's Office are managed by the Integrity area and administered by a specialized and independent company, which provides greater security for the users. 

Suspected violations of the Code of Conduct should be reported to the Channel, which is available to all stakeholders 24 hours a day, seven days a week, in Portuguese, English and Spanish. 

Klabin Integrity and Ombudsman Channel 

www.canalintegridadeeouvidoria.com.br/klabin (select your preferred language) 

0800 718 7814 – Brazil 

0800 222 0545 – Argentina 

Reports can be made anonymously or with contact details. Confidentiality is assured, as well as non-retaliation against whistleblowers or anyone who cooperates with investigations. 

Reports of a financial or asset nature are forwarded to Internal Audit for investigation and behavioral allegations are investigated in partnership with the People & Management area. 

The table below shows the total number of substantiated complaints in 2023 for each type of complaint: 

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

*The figures include all complaints investigated by the Internal Audit, received by Klabin's Integrity Channel and Ombudsman or directly by the area. In the event of a conflict of interest, different reporting Channels are taken into consideration: Favoritism and Conflict of Interest. 

** The figures include complaints received by Klabin's Integrity Channel and Ombudsman's Office, investigated in partnership with the People & Management area. 

***It includes complaints received by the Integrity and Ombudsman Channel and by Klabin's Data Protection area. 

Disciplinary measures in accordance with current legislation are applied to confirmed cases and can range from verbal and written warnings to suspension and dismissal of those involved, as well as related reorientation. 

In addition, 1,289 reports* were received in the Behavioral and People categories, and such cases were assessed by managers, in partnership with leaders and the People & Management team. 

*This figure excludes the types of harassment, sexual harassment and discrimination, as confirmed cases of such incidents are reported in the table above. 

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

In 2023, no lawsuits were identified regarding unfair competition, violation of antitrust laws, and monopoly. 

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Fines and non-monetary sanctions associated with environmental issues

Note: Fines of more than $10,000 are considered significant. 
In 2023, Klabin received no significant fines or sanctions.

The Integrity area at Klabin is responsible for the Integrity Program, which is structured on the pillars of prevention, detection, and remediation, with the support and commitment of senior management. Additionally, it conducts mapping of ethics and compliance risks with the support of internal teams and specialized consultancies, along with continuous diagnosis and monitoring of its processes.

The business support areas such as risks, internal controls, environment, sustainability and others have a primary duty to follow all applicable and current legislation, in compliance with requirements and standards, and it is a direct part of their remuneration to ensure and enforce all legal obligations applicable to the company's business. 

Klabin Code of Conduct

The Code of Conduct is intended for all board members, fiscal council members, directors, and employees of Klabin and its affiliates and wholly-owned subsidiaries. The document also applies to suppliers, customers, shareholders, service providers, competitors, commercial representatives, public entities and bodies, financial institutions, the press, communities, and other stakeholders who have any form of relationship with the company.

The Code of Conduct was reviewed and approved by the Board of Directors in May 2021. The document review involved 14 areas from all of Klabin's departments and the support of a specialized consultancy. The update included and reinforced relevant topics such as the Anti-Corruption Law, a commitment not to retaliate against whistleblowers, the Brazilian General Data Protection Law (LGPD), Diversity, compliance with Environmental, Social, and Governance (ESG) frameworks, and Klabin's Sustainable Development Goals (KODS). Since then, the Integrity area has been reinforcing the principles and guidelines set out in the document through communication campaigns, such as Klabin Ethics Week, training, and workshops.

Klabin Confidentiality Channel

Klabin's Integrity and Ombudsman Channel is managed by the Integrity area and operated by a specialized and independent company, which provides greater security for users. Suspected violations of the Code of Conduct should be reported to the Channel, which is available to all stakeholders 24 hours a day, seven days a week, in Portuguese, English, and Spanish. Reports can be submitted anonymously or identified. Confidentiality is guaranteed, as is non-retaliation against whistleblowers or those who cooperate with investigative processes.

In 2023, there was a 47% increase in the total volume of reports received compared to 2022, demonstrating the reach of employees and third parties in operations. Internal mechanisms have been reviewed—typology and impact matrix—and specific parameters have been implemented in the reporting management system, enabling the extraction of new indicators and supporting leaders in the implementation of preventive and corrective actions in a more timely manner.

Code of Conduct Training

One of the Program's foundations is internal staff training. In 2023, considering the Integrity training schedule, there was a campaign to adhere to the Code of Conduct across all Klabin's operations, competitive training sessions for the Commercial and Procurement teams, as well as anti-corruption workshops for the entire company leadership.

By 2023, the company achieved over 70% compliance among employees with Code of Conduct Training, surpassing the 64.1% achieved in 2022. The Integrity area has been working with the People & Management team to boost engagement. In addition to communication and awareness campaigns, Klabin has provided trainings on harassment and discrimination on 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 training", among others related to moral and sexual harassment.

Another highlight of the year was the participation of over 90% of employees in the Commercial and Procurement areas in Competition Training, a focus of the Company for audiences with greater interaction with the topic. The trainings are conducted by specialists, with ample space for dialogue, reflection, and relevant discussions, and the content is available on the internal corporate education portal.

Compliance System Verification

Annually, Integrity risks are reviewed by Klabin's internal team as part of the continuous monitoring of the Integrity Program.

The consultancy BDO evaluated Klabin's Integrity Program in 2021 and, in continuation of this work, in 2022 applied a survey to assess the Program. The Integrity area is committed to the constant evolution of the Program, incorporating the improvement opportunities identified in internal and external evaluations and surveys.

Third-Party Reputational Assessment

In 2022, the process of third-party reputational assessment was enhanced through the implementation of the Integrity Questionnaire and, in 2023, by expanding the research parameters applied to the assessments.

Political Contributions

Since 2016, Brazilian companies have been prohibited from contributing to political campaigns or organizations — Law 13165/2015. Klabin's Anti-Corruption Manual, prepared in 2014, prohibits donations to politicians and political parties. In line with legislation and internal rules, the company did not make such contributions in 2023.