Code of conduct and integrity - GRI Summary

The topic of conflict of interests is dealt with in the Code of Conduct, a document approved by the Board of Directors. The document defines the topic as follows: "Conflict of interests occurs when there is a conflict between collective and individual interests or between the interests of the Company and the interests of an employee or group of employees, in such a way as to compromise the Company's interest or influence, in a way improperly, the performance of the duties of that employee or group of employees."

Conduct such as carrying out parallel activities that compromise work or performance, using Company resources for one's own benefit or that of third parties, requesting undue sponsorship from suppliers are prohibited and may lead to termination of the employment or service contract. or rely on position and internal information. In the Code of Conduct, employees are encouraged to reflect on conduct that may represent a conflict of interest, as well as to report concerns related to the subject through the Integrity and Ombudsman Channel, which will be analyzed with the support of higher bodies, as necessary .

In 2022, the Company approved and internally published the Policy for Transactions with Related Parties, aiming to strengthen its governance on the subject and reinforcing transparency in its financial and accounting disclosures. This document contributes to the improvement of the internal control environment and to the mitigation of business risks that may result in a conflict of interest.

Regarding the management of third parties, Klabin has contracted and operational specialized research and analysis solutions that offer the possibility of identifying negative media, registration on sanctioning lists, PEP's (politically exposed persons), among other points of reputational attention . These tools strengthen the structure for evaluating donations, sponsorships and contracting suppliers, allowing continuous monitoring of the reputational status of these relationships. In addition, a project is underway to restructure the supplier registration and approval process, which will allow for greater harmony between the supply areas and various control areas, such as Integrity, Internal Controls and Legal, resulting in a more mature and robust system from the point of view of mitigating risks related to contracting third parties.

Own employees notified and trained on anticorruption policies and procedures (by region)

In 2022, training covering the topic of combating corruption was considered. They have been disseminated year after year in the Company, reaching the public of interest, with excellent internal evaluation for their didactics, interactivity and adaptation to the Company's reality. Training in e-learning format is available on the training portal, Escola de Negócios Klabin.

Own employees notified and trained on anti-corruption policies and procedures (by functional category)

Business partners notified and trained on anticorruption policies and procedures

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."