Conduta ética e integridade
Ethical conduct and integrity
The Integrity Area periodically conducts processes to map the risks of corruption in its operations. In the last biennium 2021-2022, 100% of operations were mapped by means of questionnaires completed by directors, document analysis, interviews, and transactional tests conducted by specialized consultants. The consulting firm's recommendations report was based on the mechanisms for Integrity Programs in Decree 8.420/2015, which regulates anti-corruption law 12.846/2013. Action plans were established for the suggestions for improvement, officially included in Klabin's risk matrix.
In order to reduce the risk of events that could be classified as acts of corruption, or any other violations of the values outlined in its Code of Conduct, the Company provides regular training to its various stakeholders, as well as hosting an Ethics Week and other communication initiatives. In doing so, it seeks to foster reflection on matters of integrity in the corporate environment. Improvements were also made through the elaboration of policies and procedures, which formally established general or specific guidelines and responsibilities, as well as the hiring of resources to improve the assessment of third parties and the Integrity and Ombudsman Channel.
The Integrity Area also evaluated 100% of the donations and sponsorships granted by Klabin, integrating the assessment flow of the recipients in the mitigation of reputational risks that may damage the Company’s image and reputation. In addition, in compliance with the Anti-Corruption Manual and the Federal Law, no cases of donations involving public agents were identified in 2022.
Cases involving violations of the Code of Conduct and bribery and/or corruption
| Category | Checked | Confirmed |
|---|---|---|
| Corruption and/or bribery | 0 | 0 |
| Unlawful Acts | 18 | 0 |
| Behavioral | 542 | 88 |
| Conflicts of Interest | 46 | 0 |
| Information Security | 0 | 0 |
| Violation of Regulatory Laws or Standards | 198 | 38 |
| Sexual harassment | 32 | 17 |
| Discrimination | 9 | 2 |
| Money laundering | 0 | 0 |
| Total | 845 | 145 |
Klabin's Whistleblower Channel is managed by the Integrity area and administered by a specialized and independent company. The governance process prevents the occurrence of conflicts in the receipt and handling of reports. The dissemination of the Channel to the employees reinforces the differentials of the entire process, such as: management by a specialized and independent company, the governance process, personal service by a consultant, the existence of the Integrity Committee for judging and handling complaints, in addition to the confidentiality and non-retaliation of whistleblowers.
The categories reported cover the following situations: Unlawful Acts (Fraud, Theft, Misappropriation of Materials, Improper Payment or Receipt); Behavioral (Abuse of Power, Bullying, Physical Aggression, among others); Conflicts of Interest (Favoritism, Close relationship with direct subordinates); Violation of Laws or Regulatory Standards (Violation of Environmental, Labor or Fair Trade Laws, and other legislation). For cases of sexual harassment and discrimination, check under "Cases of discrimination and measures taken".
There were no cases of corruption or bribery in Klabin’s Integrity and Ombudsman Channel in 2022. The Channel, which receives complaints with guaranteed anonymity, aims to receive reports of violations of the Code of Conduct, standards, and current legislation, which are handled according to the complexity of the reported situations and undergo a process of analysis, investigation, and application of disciplinary measures and/or corrective actions for confirmed cases. Depending on the seriousness of the confirmed situation, the disciplinary measures applied range from formal warnings to termination of employment contracts or service provision. Preventive measures are also established for confirmed cases to mitigate possible recurrences.
The confirmed cases of sexual harassment resulted in 11 terminations, one suspension, four replacements of third-party employees and a written warning. It is important to emphasize that Klabin conducted intense campaigns on sexual harassment during the entire year of 2021 and reinforced the topic, including the active participation of senior management, leadership in general, and other employees.
The confirmed cases of discrimination correspond to reports of racial discrimination. The disciplinary measures applied take into account the severity of each case, and these occurrences resulted in dismissals of the reported employees.
Pending and/or closed lawsuits during the period covered by the report regarding unfair competition and violations of antitrust and antimonopoly laws
| Unit | 2022 | 2021 | 2020 | 2019 | 2018 | |
|---|---|---|---|---|---|---|
| Number of pending or closed lawsuits | Number | 0 | 0 | 0 | 0 | 0 |
No lawsuits were identified regarding unfair competition, violation of antitrust laws, and monopoly.
Fines and non-monetary sanctions associated with environmental issues
| Category | Unit | 2022 | 2021 | 2020** | 2019* | 2018 |
|---|---|---|---|---|---|---|
| Monetary value of significant fines | BRL | 0 | 0 | 45,000.00 | 12,071.15 | 0 |
| Monetary value of significant fines | USD | 0 | 0 | 8,667.68 | 2,994.80 | 0 |
| Total number of non-monetary sanctions | number | 0 | 0 | 0 | 1 | 0 |
| Total number of cases resolved through arbitration mechanisms | number | 0 | 0 | 0 | 0 | 0 |
| Accumulated environmental liabilities at the end of the year | BRL | 0 | 0 | 0 | 0 | 0 |
Note: Fines in excess of USD 10,000 are considered significant.
* BRL/USD exchange rate on 12/31/2019 – BRL 4.0307
** BRL/USD exchange rate on 12/31/2020 – BRL 5.1917
We had no fines or sanctions in 2022.
Klabin's history includes a long-standing commitment to ethical and responsible business practices in all its operations. In order to align its actions with international best practices, it established compliance with the Sustainable Development Goals (SDGs), and set its short, medium and long-term targets, aiming for fairness and transparency in relationships, protecting fundamental freedoms, in accordance with national laws and international agreements. The Integrity Area is responsible for promoting the guidelines of the Klabin Code of Conduct, Anti-Corruption and Competition standards and laws and has established the following targets: (a) strengthen the pillars of the Integrity Program; (b) disseminate them to all its units and strategic partners; and (c) consolidate integrity as an internally and externally perceived value.
In 2022, the Company worked on the communication, awareness and training of employees on the Code of Conduct, updated, revised and approved in May 2021 by the Board of Directors, the highest governance body. The document's preparation involved 14 areas from all of Klabin's directorates and support from a specialized consulting firm. 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 (KSDGs).
Klabin continues to strengthen its base of employees trained on the Code of Conduct through communication and awareness initiatives involving People & Management focal points at several units, achieving a significant improvement in the indices. The areas most sensitive to the topic of competitive practices and positions more subject to the risk of corruption receive specific training using the resources available in the internal corporate education portal or through experts to debate the subject and generate engagement, reflection and discussion.
Regarding the evaluation of third parties, the Integrity area has participated in the project to restructure the registration and approval of suppliers, conducted by the procurement area, contributing to the identification of related risks and ways to mitigate them. In addition, it participates in the construction of sector risk assessment metrics for critical Sustainability suppliers, from the perspective of the EcoVadis system. Reputational assessment of donations and sponsorships, agroforestry partnerships, and law firms was maintained and strengthened through Integrity questionnaires, due diligence, and ongoing monitoring of these partners on the Dow Jones platform.
An Integrity risk mapping process was conducted throughout Klabin's operation by an external consultancy and concluded in 2022, including issues related to corruption. The final recommendations report was based on the mechanisms for Integrity Programs in Decree 8.420/2015, which regulates anti-corruption law 12.846/2013. Suggestions for improvement were made and action plans were established to fulfill them as needed.
Undertaking goals linked to the topic by executives
| 2022 | 2021 | |
|---|---|---|
| Managers | 1.0% | 2.0% |
| Directors | 0.0% | 8.0% |
| Total executives | 11 | 9 |
Updated and verified on: 06/25/2022