Bracell did not receive any significant fines in the year for noncompliance with laws and regulations in the social and economic area.  We did, however, receive delinquency notices for which we filed defense briefs, appeals or legal actions to annul those notices. Bracell has not been required to enter into any settlement of environmental liabilities with the competent authorities. Bracell has not received any significant fines (above R$ 1 million) due to non-compliance with environmental, social or economic laws and regulations.

Compliance, ethical conduct, integrity and transparency is a material topic for Bracell encompassing the implementation of good practices consistent with Company policies, applicable laws and regulations and industry standards, and ensure compliance by upholding ethics, integrity and transparency.

Bracell’s Code of Conduct is aligned with our Mission, Vision and our T.O.P.I.C.C Core Values; (Complementary teams, Ownership, People, Integrity, Customers, Continuous Improvement). It reflects our commitment to upholding globally recognized standards of ethics in our processes and practices, and to nurturing ethical mindsets among our employees and suppliers, and in our relations with stakeholders.

The Code of Conduct establishes guidelines for ethical conduct and embodies our commitment to maintaining ethical global business standards in daily processes and practices, as well as establishing the criteria for ethical behavior and integrity of employees, suppliers, customers and all our stakeholders.

Our Code of Conduct is shared with all of our employees at the moment of integration, soon after their admission. We also provide employees with self-training on RGE’s Code of Conduct to reinforce its guidelines.

Read here Bracell’s Code of Conduct.

Bracell operates in strict accordance with the RGE Group Global Anti-bribery and Anti-Corruption Policy and its principles and guidelines for ensuring compliance with applicable anti-bribery and anti-corruption laws, including Brazilian laws.

Bracell’s compliance culture stresses, among other things, that any failure to comply with these laws can result in civil and criminal liability both for the RGE Group and for the people involved, as well as significant reputational damage for RGE group and Bracell.

To ensure transparency, we regularly report to our stakeholders and the broader market on the key outcomes from our management of material topics, as prioritized in consultations of internal and external stakeholders (read more about the materiality process under GRI 3-2 and about Bracell’s material topics under GRI 3-3).

Culture of ethics and integrity

All employees are trained and informed about Bracell’s values, commitments and policies. They also attend training on department-specific technical and operational procedures, following a role-specific training matrix as part of Bracell’s Integrated Management System (IMS).

 

All our operations (100% of our forestry and mill operations in Bahia, São Paulo, Sergipe and Mato Grosso do Sul) are assessed on corruption risk in accordance with the RGE Group Anti-Corruption Policy (read more about Bracell’s operations structure in GRI 2-6).

Identified risks are addressed in internal policies containing procedures on identifying potential corruption risks and implementing prevention and mitigation measures.

Bracell also has a Whistleblowing Policy which is focused on internal processes and aimed at direct employees. This document sets out fundamental principles and procedures for reporting and investigating concerns. The Whistleblowing Policy, available in Portuguese only on the Bracell website, outlines:

1. how to raise concerns about possible inaccuracies in financial reports, internal controls or any other related matters; and
2. procedures for a fair and independent investigation with adequate follow-up to address each concern raised by employees.

Whistleblowers can report possible inaccuracies to the Internal Audit departments in all operations. Reports can be made by telephone, email, snail mail, face-to-face meetings, and other means of communication.

Other policies on ethical practices and conduct and ensuring compliance with laws and regulations are also available on Bracell’s website. These include our Code of Conduct, our Procurement Code of Ethics, and our Sustainability Policy. Click here to view our policies.

Each year we provide training on anti-corruption guidelines, consistent with the Bracell Code of Conduct, as part of our annual training program.

All 7,391 employees, representing 100% of the workforce, receive the Code of Conduct during the onboarding process, immediately after admission. They are also trained in integrity, anti-bribery and anti-corruption.

Other initiatives include the following:

• All members of the senior leadership team attend regular training on ethics and integrity, including training on the Code of Conduct;
• Employees in senior positions or who are responsible for conducting business partner due diligence receive additional, personalized training on RGE’s Business Partner due diligence process; and
• All Bracell suppliers receive copies of our Procurement Code of Conduct and undergo due diligence and a review of documentation and evidence demonstrating compliance with local, national and international laws and regulations, certification requirements, technical standards and regulatory standards.

Bracell has control mechanisms and procedures in place to ensure compliance. We define corruption as obtaining an undue advantage for one’s own or a third party’s benefit.

	2021	2022	2023
Total number of confirmed incidents of corruption	1	0	2
Nature of reported incidents	Corruption involving a supplier and an employee	0	fraud
Total number of confirmed incidents in which employees were dismissed or disciplined for corruption	1	0	1
Total number of confirmed incidents where contracts with business partners were terminated or not renewed due to violations related to corruption	1	0	1

Note 1: cases of corruption are those that have at least two people involved in the realization of abuse of power and private gains.
Note 2: in 2021, the Company investigated a reported case of fraud. As a result, the suppliers involved were barred from doing business with Bracell.
Note 3: In 2022, a case of fraud related to a forestry module was reported, which resulted in an internal audit. This audit led to the dismissal of the employees involved. Although the incident occurred in 2022, it was recorded in 2023, the year in which there was also an additional case of fraud, this time related to travel reimbursements, which resulted in the dismissal of an employee. In addition, it is important to note that in 2023 we did not record any cases of public corruption.

Bracell was not party to any judicial or administrative proceedings, either nationally or internationally, for unfair competition, corruption, anti-trust or monopoly practices.