Our corporate governance model is designed to ensure we uphold internationally recognized standards of ethical conduct as expected by organizations, customers, business partners, and employees. These guidelines are articulated in our T.O.P.I.C.C. Core Values (learn more in GRI 2-1) and in the Bracell Code of Conduct, which provides clear guidance on the conduct expected of employees and on creating long-term value for our communities, country, climate, customers, shareholders, and other stakeholders.

Additional guidance on ethical and transparent conduct for employees and contractors is provided in our:

• Anti-Corruption and Anti-Bribery Policy;
• Procurement Code of Ethics;
• Bracell Code of Conduct;
• Sustainability Policy;
• Human Rights Policy.

The leadership team implements Bracell’s annual operational plan in accordance with the management guidelines contained in certification standards. This includes developing plans to mitigate and prevent social and environmental risks and impacts. The approach to identifying and monitoring impacts is a topic addressed in Bracell’s Sustainability Policy.

Our governance structure for managing impacts is additionally described in disclosures GRI 2-9 and GRI 2-10.

Sustainability Governance

In addition to the Sustainability Steering Committee, Bracell also has a standing Crisis Committee. Both committees play a role in identifying opportunities for action and advising on measures to prevent and mitigate actual and potential business impacts in the short, medium, and long term.

Sustainability Steering Committee executives receive supporting advice from Bracell’s leadership, which has individual expertise in environmental, social, and governance (ESG) management and oversees ESG matters within the company. For instance, the leadership team led the development of the Bracell 2030 targets, with progress against those targets tracked by the Sustainability Steering Committee.

This oversight includes managing social and environmental risks and opportunities within our operations.

The Crisis Committee, in turn, deals with unexpected events and emergencies with the potential to impact our stakeholders, operations, and reputation. This Committee uses management workflows consistent with the nature of the emergency and local needs. In our Bahia operations, it has two organizational levels depending on how the crisis escalates, as outlined in our Crisis Prevention and Management Manual. In our São Paulo operations, the crisis committee is composed of key leadership personnel as relevant to the crisis situation (read more in disclosure GRI 2-17 ).

Risk management and due diligence

Consistent with the precautionary principle, Bracell’s approach to risk management is focused on protecting the environment and preventing adverse impacts on ecosystems in the locations where we operate. We have dedicated programs and key performance indicators addressing environmental performance, and are committed to creating positive environmental value in the short, medium and long term. These programs encompass due diligence, supplier screening, and ongoing monitoring of supplier performance.

We manage our operations in accordance with the guidelines outlined within our Risk Management Program (RMP), which has been developed in line with internationally recognized best practices. The Program—which has the precautionary principle and prevention of adverse impacts on the ecosystems and communities where we operate are two core pillars—covers information management, training, equipment, use of technology, and emergency response.

As part of the Program, we identify and assess the primary impacts, risks, and opportunities associated with our operations and determine the relative importance of different factors for the sustainability of the business. Based on this assessment, we continually monitor potential risks to our operations, neighboring communities, and the environment. The Program also includes proactive plans for mitigating impacts—either neutralizing or minimizing them to the extent possible. Through the program, we strive to create positive socio-environmental value over both the short and long term.

At Bracell, we:

• regularly update our identified aspects and impacts, in an exercise involving all our operations, in order to identify, prevent and mitigate any and all negative impacts;
• conduct assessments to identify and map out social and environmental risks before initiating any operation;
• assess products on health, safety and environmental risks; and
• regularly monitor the impacts from our operations and activities, and implement immediate mitigation measures focused on minimizing impacts.

Controls and prevention

Bracell’s Internal Audit department audits our processes on an ongoing basis. Audits are conducted in accordance with guidelines outlined in Standard Operating Procedures (SOP) to assess compliance with internal policies, procedures, applicable laws and regulations, regulatory standards, certification requirements, and international protocols.

Processes are mapped out, and a risk and control matrix is developed as part of the risk assessment process. Identified issues are reported to Bracell’s senior leadership team and the RGE group. Critical risks are followed up monthly.

Bracell also responds to questionnaires from banks pursuant to Resolution BCB No. 151, of Banco Central do Brasil (October 6, 2021), which mandates that financial institutions semi-annually submit information to the Central Bank regarding clients’ social, environmental, and physical and transition climate risks. We ensure the ESG risk management information in the questionnaires we submit to financial situations is accurately stated.